- The Huairou Commission has a policy on conflicts of interest that requires those with a conflict or those who think they have a conflict/potential conflict to disclose it.
- The policy applies to all Huairou Commission staff, and those associated with the delivery of Huairou Commission work, consultants, volunteers including Board and Committee members and Directors, and members, referred hereinafter as “Huairou Persons”.
- The purpose of this Policy is to prevent Conflicts of Interest where possible and if not possible, to deal with them in an ethical and responsible manner, to disclose them and to mitigate the risk of Conflicts of Interest.
- Conflict of interest is defined as “a situation in which a person’s loyalties or interest are, might be, or might be perceived to be in conflict with those of their organization. This could be as a result of a private relationship or association with a person, group or entity with whom you might also have a professional relationship or association. It could also be as a result of a private interest or activities conducted during or outside of working hours”.
- This policy focuses on conflict of interest and sets the minimum procedures to effectively manage conflicts of interest, to create an environment where “Huairou Persons” are comfortable declaring any conflict they might find themselves in, this will enable Huairou Commission to manage its exposure to fraud and corruption. This policy is in line with the Huairou Commission Anti-Fraud and Corruption Policy as well as Huairou Commission code of conduct.
- Huairou Commission members can implement the policy using their own procedures and forms. The policy supersedes individual member’s policies on Conflict of Interest, except when the members’ own conflict of interest policies are more restrictive.
- Huairou Commission will put in place the following procedures to ensure implementation of the Policy.
- All existing and new employees and Board members shall read and attest that they have read the Conflict of Interest Policy:
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- In addition to any disclosures made above, certain designated persons will complete a Disclosure Statement every year. Such designated persons will generally be officers of the organization, senior management, and other specialized positions – disclosures submitted under this policy will be considered confidential and will only be communicated on a need -to-know basis;
- Any breach of this policy, including failure to make timely, complete, and accurate disclosure of an existing or potential conflict of interest, shall subject the person involved to appropriate disciplinary action, up to and including termination of employment/engagement.
- Prohibits interested board members from voting on any matter in which there is a conflict interest.
- Annex H provides examples of situations where conflict of interest might arise, those examples are not exhaustive and are only meant to provide some common areas where conflict might arise.