Conflicts of interest policy: model and examples
Use our model conflicts of interest policy to help you meet statutory requirements. Plus, see examples of policies from schools and trusts.
- Key facts
- Model policy
- How to create a conflicts of interest policy
- Examples from schools and trusts
Key facts
- This policy is non-statutory, but you do have a legal duty to manage conflicts of interest
- You can delegate the approval of this policy to an individual or committee
- The board determines the review cycle
- Your board (or depending on your scheme of delegation, your trust board) will write and be responsible for the implementation of this policy
Model policy
Model policy: conflicts of interest
We worked with Forbes Solicitors to create this policy. It takes account of relevant requirements and good practice.
You aren't required to have a conflicts of interest policy, but you do have a legal duty to manage conflicts of interest, and a policy can help you do this.
Read about the principles of conflicts of interest in our 1-page summary, and test your understanding of circumstances that create conflicts of interest with our example scenarios.
How to create a conflicts of interest policy
If you'd rather write your own policy, annex 4 of the Charity Commission's guidance on handling conflicts of interest gives tips on how to do it.
The guidance is for charities (including academy trusts) but maintained schools may find it useful too.
It says that, as a minimum, a conflicts of interest policy should:
- Define conflicts of interest
- Explain that trustees have a responsibility to declare conflicts of interest
- Explain what your governing document (for academies, this will be your articles of association) says about conflicts of interest
- Define all interests that trustees should declare, including business and personal interests and those of their spouse, partner, family and close relatives
- Define trustee benefits and highlight the requirement to get legal authority before carrying out any transaction involving a benefit
- Include guidance on the procedures to follow when a trustee has a conflict of interest
- Set out how and by whom the policy will be monitored and enforced
- Be widely communicated and understood within your trust
- Be part of a wider policy framework (for example, a handbook or code of conduct)
Examples from schools and trusts
- Diss High School, a single academy trust in Norfolk
- Gospel Oak School, part of an 11-school multi-academy trust (MAT) in the West Midlands
- Grand Avenue Primary and Nursery School, a maintained school in Kingston upon Thames (see 'governors conflict of interest')
- Ted Wragg Academy Trust, a 7-school MAT in Devon
- Compass Education Trust, a 3-school MAT in Essex