This document outlines both:
- the broad approach to identifying and monitoring all actual/potential conflicts of interest that may affect DtN both now and in the foreseeable future and
- the possible conflicts of interest that have been identified to date and the arrangements in place to prevent these from re-occurring.
It has been written to demonstrate compliance with current Ofqual General Conditions of Recognition, and Qualifications Wales Standard Conditions of Recognition condition A4, A8, G4 and I1 (updated annually to maintain compliance with latest recommendations) and may from time to time be provided to the regulators upon request to satisfy them of our ability to comply with their requirements in relation to conflicts of interest and to prevent such conflict becoming ‘Adverse Effects’ (as defined GCOR J1.8).
In covering conflict of interest (COI) policies between learner and tutor/assessor the curriculum content is clearly defined and the learner would be aware of conflicts that may already exist relating to course content at a very early stage. The assessor would need to determine before commencement of the course whether these conflicts would be potentially troublesome if the learner were admitted to the course. Regular discussion would be held learner and tutor/assessor to determine the ongoing impact of the COI. It is proposed that an independent panel (defined as in Breaches of this Policy below) be established to settle any arbitrary issues learner and tutor/assessor including personality issues and both learner and tutor/assessor would have indicated their agreement at the start of the course to agree to the panel’s findings (as in Conflict of Interest principles below).
This Policy is intended for the use of all DtN employees, volunteers or anyone acting on the behalf of DtN (for example quality assurers, writers, and markers).
Definition of a conflict of interest
A conflict of interest exists where a member of staff, volunteers or anyone working on the behalf of DtN has interests in any other activity which have the potential to lead that person to act contrary to the interest of DtN.
Conflict of interest principles
In implementing the approach to identifying and managing actual/potential conflicts of interest all DtN employees, volunteers and people acting on the behalf of DtN are required to:
- commit to identifying and managing all actual/potential conflicts of interest that may affect DtN and in doing so raise possible conflicts of interest with their line manager if in doubt.
- be proactive in the identification and management of conflicts of interest that may affect DtN effectiveness, level of regulatory compliance or reputation.
- be open about the nature of any potential/actual conflicts of interest and not try to hide or present them in a better light. Managing conflicts of interest is about preventing issues from occurring that may impact on our operational effectiveness and/or regulatory compliance.
- strive to identify and deal with conflicts of interest sooner rather than later.
- ensure the controls for managing any potential conflicts of interest are proportionate to the risks associated with the identified conflict(s).
- sign a declaration of interest prior to commencing work with the DtN and from then on annually.
Conflicts of Interests will also be requested and declared at the start of each organisational meeting (e.g. Board meetings).
Identified conflicts of interest should be identified and managed. All instances should be reported to the principal and logged on the Conflicts of Interest Spreadsheet and monitored.
Overall DtN compliance regarding identifying and managing any conflicts of interest will be reviewed regularly by the board.
Breaches of this Policy
Should any member of staff/ volunteer believe there has been a breach of this policy, or unforeseen conflicts of interest emerge, the principal or a member of the board must be informed, and an investigation carried out immediately along with a review of the associated procedures. Such reviews will be led by the principal (unless they are under investigation, in which case the investigation would be led by a board member or if required an alternative member of staff or external party will be appointed to carry out the review) and the outcomes reported to the board.
If the breach is also classified as an Adverse Effect then the principal must promptly inform the appropriate regulatory organization. In doing so they will document the reasonable steps that have been taken or they intend to take to prevent, correct or mitigate the Adverse Effect. Details of any reviews that have or will be carried out should be included.
This policy will be reviewed biennially as part of our self-evaluation arrangements. However, a review will be commissioned earlier should an issue arise in relation to an actual or potential conflict of interest and/or in response to customer, learner or regulatory feedback.
If you have any queries about the contents of the policy, please contact DtN via email email@example.com.