Conflict of Interest Policy

Al-Waris Foundation is committed to maintaining high standards of integrity, transparency and accountability in its decision-making.

Trustees have a legal duty to act only in the best interests of the charity.

Conflicts of interest may arise where a trustee's personal interests, relationships, duties or loyalties could, or could reasonably be perceived to, influence their judgement when acting for Al-Waris Foundation.

A conflict does not necessarily mean that anyone has acted improperly.

However, conflicts must be identified, declared, managed and recorded appropriately.

Al-Waris Foundation will manage conflicts in accordance with:

Where this policy conflicts with the Constitution or applicable law, the Constitution and applicable law take precedence.

The purpose of this policy is to:

This policy applies primarily to:

Relevant principles also apply to:

The legal duties applying specifically to trustees remain distinct from the obligations of other persons.

A conflict of interest exists where a person's interests or duties conflict, or may conflict, with their responsibility to act in the best interests of Al-Waris Foundation.

Conflicts may be:

A conflict currently exists.

Circumstances could reasonably develop into a conflict.

A reasonable person could believe that a person's judgement may be influenced, even where the individual believes they can remain impartial.

All three categories should be taken seriously.

Conflicts generally arise as:

A person's personal or financial interests may conflict with the interests of the charity.

A person's duty or loyalty to another person or organisation may compete with their duty to Al-Waris Foundation.

A conflict of loyalty does not necessarily involve financial benefit.

Conflicts may include situations where a trustee or decision-maker:

This list is illustrative and not exhaustive.

Particular care must be taken where a decision could benefit someone connected with a trustee.

The meaning of a connected person must be determined in accordance with the charity's Constitution and applicable charity law.

Depending on the circumstances, this may include:

Trustees must not assume that a transaction is acceptable merely because the direct recipient is not themselves.

Trustees must:

Trustees must not use their position to secure unauthorised personal advantage.

Al-Waris Foundation will maintain a Register of Interests.

Trustees should declare relevant interests:

The register may include:

Each trustee should complete or confirm a declaration of interests at least annually.

The declaration should confirm that:

Annual declarations do not replace the obligation to declare conflicts as they arise.

At the beginning of Board meetings, trustees should be given an opportunity to declare:

A conflict should also be declared immediately if it becomes apparent later during the meeting.

The declaration should be recorded in the minutes.

A declaration should provide enough information for the unconflicted trustees to understand:

A trustee should not deliberately minimise or conceal the extent of a conflict.

Once a conflict is identified, the unconflicted trustees must determine how it should be managed.

Depending on the circumstances, this may involve:

The response should be proportionate to the seriousness of the conflict.

Where required by the Constitution, law or the circumstances, a conflicted trustee must withdraw from relevant discussion and decision-making.

The minutes should record:

The conflicted trustee should not attempt to influence the decision outside the meeting.

A conflicted trustee must not vote where:

The minutes should record abstention or absence from the vote.

Where a trustee is excluded from a decision because of a conflict, the remaining trustees must ensure that the meeting or decision satisfies applicable quorum requirements.

The Constitution must be checked where necessary.

If insufficient unconflicted trustees remain to make a valid decision, the charity must not simply proceed.

Appropriate advice or Charity Commission authority may be required.

A trustee or connected person must not receive a benefit from Al-Waris Foundation unless it is properly authorised.

A benefit may include:

Any proposed trustee or connected-person benefit must be checked against:

A conflict-management process cannot itself make an otherwise unauthorised trustee benefit lawful.

Where Al-Waris Foundation proposes to purchase goods or services from a trustee or connected person, the Board must establish that:

Competitive quotations should be obtained where appropriate.

The conflicted trustee must not improperly influence supplier selection.

Employment of a trustee or connected person requires particular care.

Before proceeding, the Board must establish:

A person's relationship with a trustee must not give them automatic entitlement to employment.

See the Safer Recruitment Policy.

Family relationships must be declared where relevant to charity decisions.

This includes decisions concerning:

A family relationship does not automatically prevent involvement with Al-Waris Foundation.

However, decisions must be demonstrably made in the charity's interests rather than for private benefit.

Where a trustee or connected person:

the interest must be declared and carefully managed.

The Board should consider:

Any proposed loan involving:

must be assessed carefully.

The charity must establish that the arrangement is lawful and in its best interests.

Terms should be documented.

A conflicted trustee must not determine the terms of their own arrangement.

Proper reimbursement of reasonable expenses incurred by trustees while carrying out charity duties is generally distinct from trustee remuneration.

Expenses should:

A trustee must not use expense reimbursement to obtain unauthorised private benefit.

Trustees may donate to Al-Waris Foundation.

A donation does not normally create a conflict merely because the donor is a trustee.

However, a conflict may arise if the donation:

Such circumstances must be declared and considered.

Where a trustee or connected person has a relationship with a prospective grant recipient, the interest must be declared.

The conflicted trustee should not improperly participate in:

Grant decisions must comply with the Grant Making Policy.

Anyone involved in procurement must declare relevant interests in:

Procurement must not be manipulated to favour a trustee, family member, friend or connected business.

See the Procurement and Purchasing Policy.

Conflicts may arise in overseas work where trustees or representatives have:

These must be declared.

Local familiarity can be valuable to the charity, but it must not be used to bypass due diligence or procurement controls.

A trustee, volunteer or project representative must disclose where they have a close relationship with a prospective beneficiary if that relationship could influence selection.

Charitable assistance must be distributed according to legitimate charitable criteria.

Family, friendship, status or influence must not create improper preferential access.

Trustees and other decision-makers must not accept gifts or hospitality that could:

Gifts and hospitality should be handled under the Gifts and Hospitality Policy.

Significant or relevant gifts should be recorded.

A trustee may owe duties or loyalties to another organisation.

Examples include serving as:

The trustee must still make decisions solely in Al-Waris Foundation's best interests when acting as an Al-Waris Foundation trustee.

Where competing loyalties make impartial participation inappropriate, the conflict should be managed in the same way as another conflict.

A trustee must not:

Similarly, a trustee should not improperly disclose confidential information belonging to another organisation to Al-Waris Foundation.

This policy applies to decisions made outside formal Board meetings.

A person exercising delegated authority must declare relevant conflicts before making a decision.

Where the person is conflicted, the matter should be referred to an appropriate unconflicted decision-maker.

Delegation must not be used to bypass conflict controls.

Urgency does not remove the need to manage conflicts.

Where an urgent decision is required:

Board minutes should record sufficient information to demonstrate appropriate conflict management.

This may include:

Sensitive personal information should not be recorded unnecessarily.

For significant conflicted transactions, the charity should record why the decision was in its best interests.

This may include:

This provides an audit trail and protects both the charity and trustees.

The Register of Interests should be:

The Board should periodically confirm that trustees have completed their declarations.

Al-Waris Foundation may publish appropriate information about trustee interests where:

The charity should not publish unnecessary personal information merely because it appears in the internal register.

Failure to disclose a relevant conflict may be a serious governance matter.

The Board should consider:

Deliberate concealment will be treated more seriously than an inadvertent omission.

Where a person breaches this policy, Al-Waris Foundation may take action including:

A serious unmanaged conflict may amount to a serious incident, particularly where it results in:

The Board should consider the Serious Incident Reporting Policy and current Charity Commission requirements.

Where trustees are uncertain about:

the safest approach is to declare the interest and obtain appropriate advice before proceeding.

Professional legal, accounting or regulatory advice should be obtained where necessary.

This policy supplements the Al-Waris Foundation Constitution.

It does not amend or override the Constitution.

In particular, decisions concerning:

must comply with the governing document.

Where there is uncertainty, the Constitution must be checked before a decision is made.

This policy should be read alongside:

This policy will be reviewed:

Version: 2.0 Status: Approved Approved by: Board of Trustees Approval date: 25/08/2026 Next scheduled review: 24/08/2027