The purpose of this policy is to assist charity trustees of Diversity Sligo to effectively identify,
record and manage any conflicts of interest in order to protect the integrity of Diversity Sligo
and to ensure that the charity trustees act in the best interest of their charity.
The Diversity Sligo board of trustees (called the ‘board of charity trustees’ in this policy) aims to ensure that the charity trustees
- are aware of their obligations to disclose any conflicts of interest that they may have,
- and to comply with this policy to ensure they effectively manage those conflicts of interest as representatives of Diversity Sligo.
This policy applies to the trustees of Diversity Sligo.
- Definition of conflicts of interests
A conflict of interest is any situation in which a charity trustee’s personal interests or loyalties could,
or could be seen to, prevent the charity trustee from making a decision in the best interests of
the charity. This personal interest may be direct or indirect, and can include interests of a person
connected to the charity trustee.
These situations present the risk that a person will make a decision based on, or affected by, these
influences, rather than in the best interests of the charity and therefore must be managed
This policy has been developed because conflicts of interest commonly arise, and do not need to
present a problem to the charity if they are openly and effectively managed. It is the policy of Diversity Sligo as well as a responsibility of its charity trustees, that ethical, legal, financial
or other conflicts of interest be avoided and that any such conflicts (where they do arise) do not
conflict with their obligations to Diversity Sligo.
Diversity Sligo will manage conflicts of interest by requiring charity trustees to:
- avoid conflicts of interest where possible
- identify and record any conflicts of interest
- carefully manage any conflicts of interest, and
- follow this policy and respond to any breaches.
5.1 Responsibility of the board of charity trustees
The board is responsible for:
- establishing a system for identifying, disclosing and managing conflicts of interest across the
- monitoring compliance with this policy; and
- reviewing this policy on an annual basis to ensure that the policy is operating effectively.
The charity trustees should ensure they are aware of their legal obligations in the management
and control of their charity and should refer to the Charities Regulator’s ‘Guidance for Charity
Trustees’ for further information on this see the Charities Regulator website3.
5.2 Identification and disclosure of conflicts of interest
Once an actual, potential or perceived conflict of interest is identified, it must be entered into Diversity Sligo’s register of interests, as well as being raised with the board of charity trustees. The
register of interests must be maintained by David McLoughlin, Trustee, and record all information related to
- a conflict of interest (including the nature and extent of the conflict of interest and any steps taken to address it).
Confidentiality of disclosures
Disclosures will be made to the board of charity trustees and the secretary to the board.
- Action required for management of conflicts of interest
6.1 Conflicts of interest of members of the board of charity trustees
Once the conflict of interest has been appropriately disclosed, the board of charity trustees (excluding the disclosing charity trustee and any other conflicted person) must decide whether or not a conflicted charity trustee should:
- vote on the matter (this is a minimum),
- participate in any debate, or
- be present in the room during the debate and the voting.
In exceptional circumstances, such as where a conflict is very significant or likely to prevent a charity
trustee from regularly participating in discussions, it may be worth the board of charity trustees
considering whether it is appropriate for the person with the relevant conflict to resign from the board of charity trustees.
6.2 What should be considered when deciding what action to take
In deciding what approach to take, the board of charity trustees will consider whether the conflict needs to be avoided or simply documented
- whether the conflict will realistically impair the disclosing person’s capacity to impartially participate in decision-making
- alternative options to avoid the conflict
- the charity’s objects and resources, and
- the possibility of creating an appearance of improper conduct that might impair confidence in, or the reputation of, the charity.
The approval of any action requires the agreement of at least a majority of the board of charity trustees (excluding any conflicted charity trustee) who are present and voting (if applicable) at the meeting. All details regarding the conflict of interest, including the action arising, will be recorded in the minutes of the meeting.
- Compliance with this policy
If the board of charity trustees has a reason to believe that a person subject to this policy has failed
to comply with it, it will investigate the circumstances.
If it is found that this person has failed to disclose a conflict of interest, the board of charity trustees
may take action against the person. This may include seeking the person’s resignation from the
If a person suspects that a charity trustee has failed to disclose a conflict of interest, they must
- discuss with the person in question,
- notify the board of charity trustees,
- or notify the person responsible for maintaining the register of interests, namely David McLoughlin.
For questions about this policy, contact the board of charity trustees or David McLoughlin, Trustee by phone on 087 99 307 13.