Conflict Disclosure Policy & Practices

This criterion evaluates the comprehensiveness and effectiveness of an organization's conflict of interest (COI) management system. It assesses whether the organization has a clearly defined policy, procedures, and practices for identifying, disclosing, and managing potential, actual, or perceived conflicts of interest across all levels (Board, management, employees, volunteers, contractors). The system must define a clear governance RACI (Board owns policy; Audit/Ethics Committee decides high-risk conflicts; Compliance administers; Line Management implements mitigations). The policy shall address specific categories including: related-party transactions (RPTs); gifts, hospitality, and inducements; outside business interests (OBI); personal account dealing (PAD); procurement; referral fees; research independence; and remuneration-linked conflicts. It must align with Shariah principles, specifically prohibiting activities where conflicts cannot be effectively mitigated to prevent injustice (Zulm) or betrayal of trust (Amanah). The framework must integrate with HR lifecycles (joiners/movers/leavers), procurement cycles, and data protection (GDPR) standards. For charities, it must explicitly align with Charity Commission guidance (CC29) and trustee duties.