United Kingdom

Last updated: May 2025

Purpose and Scope 

The purpose of this policy is to set out the process and responsibilities for ensuring that conflicts of interest when they arise do not compromise Greggs Foundation’s ability to impartially and objectively pursue its charitable purpose.    

This policy applies to all Foundation trustee directors, volunteers (including non-trustee director committee members) and staff.  

Definitions 

A Conflict of interest is any situation in which an individual’s personal or professional interests and/or loyalties conflict with those of the Foundation.  Conflicts of interest include, but are not limited to: 

• Direct financial gain or benefit e.g. payment to a trustee director for services provided to the Foundation, or award of a grant or contract to an organisation in which a trustee director, volunteer or employee has an interest; 

• Indirect financial gain e.g. employment of a spouse or partner of a trustee director.     

At the Foundation, conflicts of interest are most likely to occur in relation to grants.  A conflict of interest may occur if a trustee director, volunteer or employee is, for example:  

• a trustee director or employee of an organisation applying for/receiving a grant;  

• a beneficiary or member of such an organisation;  

• closely related to someone who is any of the above;  

• stands to benefit from a grant as a contractor to the grantee organisation 

A conflict of interest may also occur if a Foundation trustee director, volunteer or employee is themselves, or has a close relationship with, a person or organisation that is:  

• a donor or potential donor;  

• a current or potential funding partner;  

• a supplier of services to the Foundation. 

Such conflicts may create problems; they can:  

• inhibit free discussion 

• result in decisions or actions that are not in the interests of the Foundation  

• risk the impression that the Foundation has acted improperly.  

The aim of this policy is to protect both the organisation and the individuals involved from any appearance of impropriety.  

The declaration of interests  

All trustee directors, volunteers and employees must declare any external personal or professional interests and those of their spouse, partner, family and close relatives where they may receive a direct or indirect financial gain.  Trustee directors, volunteers and employees must notify the chair of any meeting they are attending of any conflict of interest relating to any organisation being discussed, whether as a grantee, partner, donor or supplier. 

In the event of the board having to decide upon a question in which a trustee director, volunteer or member of staff has an interest, all decisions will be made by vote, with a simple majority required.  A quorum must be present for the discussion and decision; interested parties will not be counted when deciding whether the meeting is quorate.  Interested trustee directors may not vote on matters affecting their own interests.  

All decisions under a conflict of interest will be recorded by the Foundation secretary and reported in the minutes of the meeting. The report will record:  

• the nature and extent of the conflict  

• an outline of the discussion  

• the actions taken to manage the conflict.  

The Foundation secretary should take special care to ensure that minutes or other documents relating to the item presenting a conflict are appropriately redacted for the person facing the conflict. A balance needs to be made to ensure that the person still receives sufficient information about the activities of the charity generally without disclosing such sensitive information that could place the individual in an untenable position.  

If a trustee director, volunteer or employee fails to declare an interest that is known to the Foundation secretary and/or the chair of the board, the Foundation secretary or chair will declare that interest.  

Where a trustee director benefits from the decision, this will be reported in the annual report and accounts in accordance with the current Charities SORP.  

All payments or benefits in kind to trustee directors will be reported in the Foundation’s accounts and annual report, with amounts for each trustee director listed for the year in question. 

Where a member of the Foundations’ staff are connected to a party involved in the supply of a service or product to the charity, this information will be fully disclosed in the annual report and accounts. 

Independent external moderation will be used where conflicts cannot be resolved through the usual procedures.  

Employees must notify the Foundation secretary of any conflicts relating to any grant recipient or applicant, donor, supplier or partner organisation that arise during the course of their work.  The Foundation secretary will ensure that any conflicted employee is not involved in assessment or decision-making related to the conflict. If the Foundation secretary has a conflict, they must notify the Foundation manager, who will ensure that they are similarly excluded from any related assessment or decision-making. 

Trustee directors, volunteers and staff must not be involved in managing or monitoring a contract in which they have an interest. Monitoring arrangements for such contracts will include provisions for an independent challenge of bills and invoices, and termination of the contract if the relationship is unsatisfactory. 

Record keeping  

The Foundation secretary will maintain registers of interests for trustee directors, volunteers and staff.  These will be updated annually for staff, quarterly for trustee directors and for all, as and when new conflicts are notified.   

Data protection  

The information provided will be processed in accordance with data protection principles as set out in the Data Protection Act 1998. Data will be processed only to ensure that trustee directors, volunteers and employees act in the best interests of the Foundation. The information provided will not be used for any other purpose.  

Breaches of the policy 

Trustee directors, volunteers and employees must notify the Foundation manager as soon as possible if they believe or suspect that a breach of this policy has occurred or may occur in the future.  Where any alleged conflict relates to the Foundation manager the Foundation chair should be notified.  

In most cases breaches of the policy will likely be unintentional so may, following investigation, be dealt with informally and through reminders of the requirement to work within this policy.  However, repeated failure to declare conflicts of interest, or deliberate attempts to gain benefit from concealing conflicts of interest, could result in formal action either through Greggs disciplinary procedures and/or disqualification from membership of committees and/or the board.