Conflict of Interest Policy

Conflict of Interest Policy
Version Number		IBS/COIP/2026Apr/V001
Member of Staff Responsible		Ibrahim Sirkeci
Record of Revisions to Policy
Date	Details	Approved by
Apr 2026	Published	Board of Directors
Apr 2026	Reviewed	Board of Directors
July 2023	Reviewed	Board of Directors
Date of Current Policy		April 2026
Next Review Date		April 2027
Review to be approved by		Board of Directors

1. Introduction

1.1 The International Business School (IBS) is committed to the highest standards of integrity, transparency, and ethical conduct. Conflicts of interest, whether actual, potential, or perceived, can undermine trust in decision‑making and must be identified and managed appropriately.

1.2 This policy sets out IBS’s framework for identifying, declaring, managing, and recording conflicts of interest to ensure decisions are made fairly, independently, and in the best interests of students and the institution.

2. Purpose

2.1 The purpose of this policy is to:

• protect the academic and corporate integrity of IBS;
• safeguard the interests of students, staff, and stakeholders;
• ensure compliance with Office for Students (OfS) expectations regarding governance, fairness, and transparency;
• provide clear guidance on identifying and managing conflicts of interest.

3. Scope

3.1 This policy applies to:

• all IBS staff (permanent, temporary, part‑time, and visiting);
• Board members and committee members;
• contractors, consultants, agents, and partners acting on behalf of IBS;
• students only where they are acting on behalf of IBS, including in paid or voluntary roles.

3.2 Partner institution staff delivering IBS programmes under collaborative arrangements are also subject to these principles.

4. Definition of a Conflict of Interest

4.1 A conflict of interest arises when an individual’s personal, financial, professional, or familial interests could compromise, or be perceived to compromise, their judgment, decision‑making, or actions on behalf of IBS.

4.2 Conflicts may be:

• Actual – currently influencing decisions;
• Potential – likely to arise in the future;
• Perceived – could reasonably be seen to influence judgment, even if this is not the case.

4.3 Examples include:

• personal or family relationships with students, staff, applicants, suppliers, or partners;
• external employment or consultancy overlapping with IBS interests;
• financial interests in organisations supplying goods or services to IBS;
• involvement in recruitment, assessment, or progression decisions where a personal connection exists.

5. Principles

IBS applies the following principles, drawing on sector good practice:

5.1 Transparency: All relevant interests must be disclosed promptly and in writing.

5.2 Integrity: Decisions must be made solely in the interests of IBS and its students.

5.3 Proportionality: Conflicts will be managed in a way that is appropriate to the level of risk.

5.4 Accountability: Individuals are personally responsible for declaring conflicts and complying with management actions.

5.5 Fairness: No individual should gain improper advantage, nor should any student or staff member be disadvantaged.

6. Declaration of Interests

6.1 All staff and Board members must declare:

• actual or potential conflicts of interest;
• close personal or family relationships with students, applicants, staff, suppliers, or partners;
• significant external employment, consultancy, or business interests.

6.2 Declarations must be made:

• on appointment;
• annually (where required, e.g. Board members);
• whenever circumstances change.

6.3 Declarations must be submitted in writing to Human Resources or the Directorate, as appropriate.

7. Managing Conflicts of Interest

7.1 Once declared, IBS will determine appropriate management actions, which may include:

• removal from decision‑making or assessment activities;
• reassignment of duties or line management;
• appointment of an independent decision‑maker;
• recording the conflict in a register for audit purposes.

7.2 Individuals with a declared conflict must not participate in related decisions unless explicitly authorised in writing.

8. Specific Guidance

8.1 Teaching, Assessment and Students

• Staff must not assess, supervise, or make academic decisions relating to students with whom they have a personal or family relationship.
• Any such relationship must be declared immediately.

8.2 Recruitment and Admissions

• Staff must not be involved in admissions or recruitment decisions where a personal relationship exists with an applicant.

8.3 Staff Recruitment and Management

• Individuals must not participate in recruitment, appraisal, promotion, or disciplinary processes involving close associates or relatives.

8.4 External Interests and Consultancy

• Substantial external commitments must not conflict with IBS duties and must be declared in advance.

8.5 Procurement and Suppliers

• Conflicts involving suppliers or procurement decisions must be declared, and independent oversight applied.

9. Confidentiality and Data Protection

9.1 All conflict of interest declarations are handled in accordance with UK GDPR and the Data Protection Act 2018.

9.2 Information will be shared strictly on a need‑to‑know basis and retained for audit and governance purposes only.

10. Non‑Compliance

10.1 Failure to declare or appropriately manage a conflict of interest may result in:

• disciplinary action under staff or student procedures;
• removal from governance roles;
• termination of contracts, where appropriate.

11. Monitoring and Review

11.1 IBS will monitor the effectiveness of this policy and maintain appropriate registers of interest.

11.2 The policy will be reviewed periodically, or sooner if required by regulatory or organisational change.

12. Alternative Formats

12.1 This policy is available in alternative formats upon request.

This policy has been informed by sector good practice, including published conflict of interest guidance used by UK higher education providers.