Conflict of Interest – Crosby Training

POLICIES & PROCEDURES:
CONFLICT OF INTEREST

1. SCOPE:

This policy applies to all individuals working for or on behalf of Crosby Training. This document supports specific conflicts of interest procedures that relate to all areas of the business including teaching and assessment delivery.

2. POLICY STATEMENT

The purpose of this policy is to protect the reputation and integrity of Crosby Training’s business activities and its decision-making processes. This document offers guidelines on Crosby Training’s Conflict of Interest Policy and provides some practical assistance to its staff on how they should manage potential or actual conflicts of interest. Anybody employed by or acting on behalf of Crosby Training is personally responsible for ensuring that they adhere to the policy and procedures in this document.

A conflict of interest is defined here as a situation where Crosby Training leaders or an employee has competing interests or loyalties, which could lead to a subjective, biased or corrupt decision being made by this organisation or employee. This policy and associated procedures, supports us in ensuring that working relationships with colleagues, stakeholders, partners and learners do not conflict with our requirement to engage in a legal, transparent, ethical and responsible manner.

Crosby Training recognises that conflicts of interest could arise that could lead to individuals making decisions based on personal interest instead of the interests of this organisation or that which is ethically correct. We are aware that in the course of our work, a perceived or potential conflict could arise and we have a duty to identify, manage and mitigate such conflicts of interest. When competing interests impair our ability to make objective, unbiased business or assessment decisions, we have a conflict of interest. Conflict of interest may take the form of financial interests in a supplier’s business, recruiting a close family member or engaging in employment outside Crosby Training.

All reasonably foreseeable conflicts of interest will be identified and monitored by our organisation. Where a potential conflict of interest is identified, we will follow the procedures outlined in this document.

DATA PROTECTION: Information provided will be processed in accordance with data protection principles as set out in the GDPR 2018 and Data Protection Act 1998. Data will be processed only to ensure that staff act in the best interest of the company. The information provided will not be used for any other purpose.

3. PROCESS

3.1 Assessing the risks to Crosby Training arising from potential conflicts of interest is an integral part of the overall and ongoing risk management process. All reasonably foreseeable conflicts of interest will be identified and monitored by our organisation Identified conflicts of interest are mitigated as far as possible and are monitored as part of overall risk management and internal control processes.
Periodic reviews of our conflicts of interest policy and procedures are undertaken as part of our governance and accountability processes.

3.2. The Senior Management Team is responsible for ensuring this policy is complied with throughout and across the organisation, including their personal compliance. They are responsible for reporting and acting on any identified or potential conflicts of interest that are specific to another member of the SMT or the Governance staff.

3.3. The HR staff and the Operations’ manager are responsible for ensuring colleagues comply with this document and complete the Conflict of Interest section of the Induction document. Line managers are also responsible for the overall monitoring the activities and performance of those they are managing.

4. MANAGEMENT RECEIVING A CONFLICT OF INTEREST NOTIFICATION

All managers/senior colleagues receiving information on actual or potential conflicts of interest will ensure that potential conflicts not causing a significant risk to the business are appropriately recorded, monitored and managed.

Conflicts, or potential conflicts, that may pose a significant risk to the business must be escalated to the Governance board.

All declarations are to be reviewed on an annual basis and this responsibility is shared by line managers and the senior management team.

5. COLLEAGUES

No colleague shall provide or accept preferential treatment (including discounts on services) to or from any colleague where such a transaction may adversely affect the business, learners, centres or other relevant parties. Such actions may also be construed as bribery and may be subject to criminal prosecution.

To assist us in managing significant risks with regards to potential conflicts of interest, individuals must tell us about any relevant risk and/or issue in relation to a conflict of interest (or potential conflict) that has come to their attention. This will be covered as part of the onboarding and induction process where new starters will complete a conflict of interest declaration that will be shared with their line manager. If any change of circumstances is made that could result in any potential conflict of interest, the Conflict of Interest declaration should be updated with the manager.

If a conflict of interest arises, or it is anticipated that one may arise, colleagues must inform the manager in protection of the business and individuals. If there is any doubt whether or not an activity represents a conflict of interest, the matter should be raised in this way, in order that an objective assessment may be made. Concerns may be raised in confidence. Please see the Whistleblowing Policy for further information.

If colleagues have a query relating to conflicts of interest, which is not included in this policy, they must refer the matter to a member of the Senior Management Team.

All potential conflicts of interest, which relate directly to the colleague themselves, must be discussed with the line manager and recorded on the individual’s HR file under ‘Conflict of Interest’. The record must contain information on how the conflict of interest will be managed.

Conflicts of Interest relating to another individual (e.g. such as conflicts reported under the Whistleblowing policy) will be recorded by HR subject to confidentiality particularly in relation to the confidential recording of information.

6. QUALITY ASSURANCE & ASSESSMENT RELATED ROLES

Quality Assurance and Assessment Related Roles applies to all working for or on behalf of Crosby Training in the context of assessment, whereby they may be producing, reviewing, marking or conducting assessments. The aim of the procedure is to ensure that integrity of the assessment process is being upheld and protected at all times and abides by our regulatory responsibilities for Conflicts of Interest as outlined in for example, Ofqual’s General Conditions of Recognition.

7. SPECIFIC AREAS FOR CONSIDERATION

7.1 Additional paid work.
Colleagues are expected to devote their working time to Crosby Training as outlined in their contract of employment. Any colleague considering undertaking additional paid work (on either an employed or self-employed basis) or voluntary work outside Crosby Training must seek their line manager’s written agreement beforehand, as stipulated in the colleague’s contract of employment. Colleagues are not permitted to take on any such activities that could be deemed to compete or conflict with Crosby Training’s activities.
All other individuals (e.g. quality assurance assessment related roles) must follow the procedures set out within their contract for services.

7.2. Potential for conflicts with regards to qualifications.
Colleagues engaged in a team or role, which has access to qualification assessment materials, content, or mark schemes may not be permitted to undertake Crosby Training assessed qualification due to the risk of a high conflict of interest and the potential impact on our regulatory requirements. Such colleagues must speak to their line manager prior to registering for a qualification.

Anyone who has access to confidential assessment material for a qualification is not permitted to deliver external training on that qualification. Such colleagues must consult with their line manager should they wish to attend these training events.

8. REVIEW

This policy and its procedures will be reviewed annually and as part of our Quality Assurance requirements. It will also be reviewed following changes to Government updates and statutory guidance in relation to Covid-19 and company risk assessment policies and processes.

Relevant Policies

_{Policy docs : Conflict of Interest Policy: V2022 MP Review Jan 2026}