Conflict of Interest Policy for FREEFRAME CIC JULY 2026

This policy protects the reputation of our organisation. It means people can trust board members of FREEFRAME to make fair decisions.

All trustees of FREEFRAME have a duty to act in the best interests of FREEFRAME and our beneficiaries when making decisions.

As trustees we will avoid any conflicts of interest or loyalty (actual and perceived) between the interests of FFEEFRAME and our own personal, professional, and financial interests.

Examples of a conflict of interest include:

A trustee who is also a service user where a decision is being made about increasing of fees.

A trustee who is employed by another organisation, competing for the same funding/contracts.

A trustee who is related to a member of staff where a decision is being made about staff pay and conditions.

A trustee who has a financial interest in a business that may do work or provide services for our organisation.

Director Responsibilities

Directors must:

• Act in the best interests of the CIC and its community purpose.
• Declare any personal, financial, or professional interests that could influence, or appear to influence, decision-making.
• Update their declarations whenever circumstances change.
• Avoid using their position for personal gain or to benefit family members, friends, or associated organisations.
• Withdraw from discussions and decisions where they have a conflict of interest, unless permitted by the Articles of Association and agreed by the Board.
• Ensure all conflicts are recorded in the Register of Interests and meeting minutes.
• Maintain confidentiality of sensitive information obtained through their role.

Examples of Conflicts of Interest

A conflict may arise where a director:

• Owns or works for a company supplying training, consultancy, or other services to the CIC.
• Is involved in awarding contracts to a business in which they or a close family member have an interest.

• Receives payment from another organisation that competes with or collaborates with the CIC.
• Has a close personal relationship with an employee, contractor, or job applicant.
• Uses confidential information gained through the CIC for personal or commercial benefit.

Holds a leadership position in another organisation with competing interests.

Managing Conflicts

The Board should:

• Maintain an up-to-date Register of Interests.
• Require declarations of interest at the start of every Board meeting.
• Record all declared conflicts in meeting minutes.
• Ensure conflicted directors do not influence related decisions.
• Review the Conflict of Interest Policy annually.
• Provide governance training to directors on their legal and ethical responsibilities.

Success Measures

• 100% of directors complete an annual Declaration of Interests.
• Conflicts of interest are declared and recorded at every Board meeting.
• No decisions are made where an undeclared conflict has influenced the outcome.
• Annual review of the Conflict of Interest Policy completed.
• Board members receive regular governance and ethics training.

Each trustee will record details of any conflict of interest when they are appointed. This Register of Interests will be updated annually.

Declaration of conflict of interest will be a standard agenda item.

Trustees will identify and disclose any conflict of interest at the start of a meeting. The trustee will then either:

*A: Withdraw from the discussion, and not take part in the decision/vote

*B: Withdraw from the discussion, and may not be able to take part in the decision/vote, depending on the judgement of the other trustees present at the time

The disclosure of a conflict of interest and the actions taken will be noted in the minutes.

Signed

Date:

Document version control

Version number	Change or update	Author or owner	Date
1.0	First version	Angela jackson	11th July 26