1. Document Control
Policy Owner: Principal / Director
Responsible Committee: Management Committee
Approval Authority: Principal / Director
Effective From: 25/12/2025
Version: 1.0
Applies To: All employees, associates, visiting lecturers, contractors, volunteers, committee members and any individual acting on behalf of Equra College London.
2. Purpose
Equra College London is committed to integrity, transparency and impartial decision making. This policy sets out how actual, potential or perceived conflicts of interest are identified, declared and managed to protect students, staff, partners and the reputation of the College.
3. Scope
This policy applies to conflicts of interest arising in relation to:
a. Admissions and enrolment decisions
b. Assessment, grading and academic decisions
c. Recruitment, promotion and staff management
d. Procurement, contracting and supplier selection
e. Partner relationships and collaborations
f. Financial decisions, sponsorships and donations
g. Committee membership and governance roles
h. External employment or professional activity
4. Definition of Conflict of Interest
A conflict of interest arises where an individual’s personal, financial or professional interests could improperly influence, or be perceived to influence, their judgement, decisions or actions on behalf of the College.
Conflicts may be:
a. Actual – a real conflict exists
b. Potential – a conflict could arise in the future
c. Perceived – a reasonable person could believe a conflict exists, even if it does not
All three must be declared and managed.
5. Examples of Conflicts of Interest
Examples include, but are not limited to:
a. Assessing, admitting or grading a relative, close friend or partner
b. Participating in recruitment where a personal relationship exists
c. Holding a financial interest in a supplier, agent or partner organisation
d. Receiving gifts or hospitality linked to decision making
e. External employment or consultancy that overlaps with College interests
f. Involvement in partner organisations that benefit from College decisions
g. Using College information or resources for personal gain
6. Duty to Declare
All individuals covered by this policy must:
a. Declare any actual, potential or perceived conflict of interest as soon as it arises
b. Update declarations if circumstances change
c. Declare conflicts even where no wrongdoing is intended
Failure to declare a conflict may itself be treated as a breach of this policy.
7. How to Declare a Conflict
Conflicts must be declared:
a. In writing to the Principal / Director (or designated officer)
b. At the start of meetings where decisions are being made
c. Through any formal declaration process operated by the College
Declarations must include sufficient detail to allow the conflict to be assessed and managed appropriately.
8. Managing Conflicts of Interest
Once declared, the College will assess the conflict and determine appropriate management measures, which may include:
a. Requiring the individual to withdraw from discussions or decisions
b. Reassigning decision making to an independent person
c. Implementing oversight or additional approval controls
d. Restricting access to certain information
e. In rare cases, prohibiting involvement in a particular activity
All decisions will be proportionate, documented and transparent.
9. Conflicts in Assessment and Academic Decisions
Where a conflict arises in assessment, moderation or academic decision making:
a. The individual must not mark, moderate or influence outcomes
b. Alternative markers or decision makers must be appointed
c. The process must be documented to protect fairness and integrity
10. Conflicts in Procurement and Financial Decisions
Individuals involved in procurement or financial decisions must:
a. Declare any personal or financial interest
b. Not participate in supplier selection or approval where a conflict exists
c. Comply with financial controls and authorisation requirements
11. Gifts, Hospitality and Inducements
Gifts or hospitality that create, or could be perceived to create, a conflict of interest must be declared and managed in line with the Fraud, Bribery and Corruption Policy.
12. Record Keeping
The College will maintain a record of declared conflicts of interest and actions taken to manage them. Records will be stored securely and handled in line with data protection requirements.
13. Breach of Policy
Failure to declare or appropriately manage a conflict of interest may result in:
a. Management action
b. Disciplinary action
c. Termination of contracts or appointments
d. Reporting to partners or regulators where required
14. Monitoring and Review
This policy will be reviewed annually and updated where governance, regulatory or operational changes require revision.
15. Related Policies and Documents
a. Staff Conduct, Recruitment and Professional Standards Policy
b. Fraud, Bribery and Corruption Policy
c. Whistleblowing, Public Interest Disclosure and Ethical Reporting Policy
d. Academic Governance and Quality Assurance Policy
e. Academic Misconduct Procedure
f. Data Protection Policy