WESTON ARK CHARITY -CONFLICTS OF INTEREST POLICY 

Document Version: 1.0 

Owner: Board of Trustees

Approved: July 14 2025 

Next Review: July 2027

Applies to: Trustees, staff, volunteers, contractors, and anyone acting for Weston Ark 

Our Commitment 

Weston Ark Charity is a Christian organisation committed to demonstrating God's love through practical support for low-income families and individuals. Operating from the Hughenden Centre, we host community services including the Ark Café and venue hires, alongside supporting a Foodbank outlet operated by dedicated Foodbank volunteers. 

We are committed to the highest standards of integrity, transparency, and accountability. All decisions must be made solely in the best interests of the charity, free from personal, financial, or external influence. This policy protects our charity's assets, integrity, and public reputation. 

What is a Conflict of Interest? 

A conflict of interest is any situation where a person's personal interests or loyalties could, or could be seen to, prevent them from making decisions only in the best interests of Weston Ark Charity. 

Two Main Types: 

Financial Conflicts: Where you or someone connected to you could gain money or benefits from a charity decision. 

• Example: Your business being considered for a contract with the charity 

• Example: Your spouse's company providing services to the charity 

Loyalty Conflicts: Where your duty to Weston Ark competes with loyalty to another organisation or person. 

• Example: Serving on the board of another charity applying for the same funding 

• Example: Being a leader at a partner church negotiating venue hire terms 

Connected Persons 

The rules apply not just to you, but to your "connected persons" including: 

• Spouse, civil partner, or partner 

• Children, parents, siblings (and their spouses/partners) 

• Business partners 

• Companies where you hold significant interest (20% or more) 

• Organisations where you hold positions of control or influence 

When in doubt, treat someone as a connected person and declare the potential conflict. 

The Three-Step Process 

Step 1: IDENTIFY and Declare 

• Upon appointment: Complete Declaration of Interests via the SharePoint Forms system 

• Annually: Review and update your declaration through SharePoint Forms At meetings: Declare any relevant interests at the start of each meeting 

• Ongoing: Declare conflicts as soon as you become aware of them 

Step 2: PREVENT the Conflict from Influencing Decisions 

• Provide any necessary information before discussion begins 

• Withdraw from the meeting during discussion and voting 

• Do not vote on the matter 

• Do not count towards the quorum for that decision 

Step 3: RECORD the Conflict and Decision 

• All conflicts and management actions recorded in meeting minutes 

• Maintain confidential Register of Interests on SharePoint 

• Clear rationale documented showing decisions made in charity's best interests 

High-Risk Situations 

Payments to Trustees or Connected Persons Trustees cannot profit from their position. Payments for goods or services to trustees or connected persons are only permitted if all six legal conditions are met: 

• No prohibition in governing document 

• Decision objectively in charity's best interests 

• Reasonable payment amount 

• Written agreement specifying payment 

• Minority of trustees receiving benefits 

• Conflict properly managed per this policy 

If any condition cannot be met, prior written authority from the Charity Commission is required. 

Employment of Trustees or Connected Persons Employment requires express power in governing document or Charity Commission authority. Must demonstrate open recruitment, reasonable remuneration, and proper conflict management. 

Gifts and Hospitality

Operational procedure: Annex A: Gifts and Hospitality sets thresholds and the step-by-step process. It applies to trustees, staff, volunteers, contractors, and anyone acting for Weston Ark.

System of record: all offers given or received must be entered in the Gifts and Hospitality Register (SharePoint Forms list) within 10 working days. 

Register owner: Technology and Systems Lead maintain the SharePoint list and reports annually to the Trustees. 

• Under £25: May be accepted (declare if part of regular pattern) 

• £25-£100: May be accepted but must be declared and recorded in the SharePoint register 

• Over £100: Must be refused unless accepting on behalf of charity 

• Cash or vouchers: Always refuse 

Responsibilities 

All Trustees Must: 

• Read and comply with this policy 

• Continuously identify potential conflicts 

• Make timely, complete declarations 

• Act with integrity and transparency 

• Ensure Annex A: Gifts and Hospitality is issued and kept aligned with this policy. 

• Ensure the Gifts and Hospitality Register is reviewed by Trustees at least annually. 

Chair of Trustees Must: 

• Lead policy implementation 

• Ensure declarations are standing agenda item 

• Facilitate conflict discussions 

• Ensure proper recording in minutes 

• Follow Annex A and record any offer given or received in the SharePoint Register within 10 working days. 

Staff and Senior Volunteers Must: 

• Operate in the charity's best interests 

• Declare relevant conflicts to Chair of Trustees 

• Not participate in decisions affecting their own remuneration or terms

• Follow Annex A and record any offer given or received in the SharePoint Register within 10 working days. 

Breaches and Consequences 

Failure to declare known interests or acting contrary to this policy constitutes a serious governance failure and potential breach of legal duties. Confirmed breaches may require reporting to the Charity Commission as serious incidents and could result in removal from position. 

Data Protection 

Information in declarations and registers is processed under UK GDPR legitimate interests basis. Special category data (religious beliefs, etc.) processed under Article 9(d) conditions with appropriate safeguards. All information held confidentially and used solely for conflict management purposes. 

8. Related documents

Annex A: Gifts & Hospitality (Procedure). Financial Controls. Data Protection policy.

Policy Approved by Board of Trustees - 14 September 2025