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Conflict of Interest Policy for DWI

Purpose

The purpose of this policy is to assist the Steering Committee of Disabled Women Ireland to effectively identify, record and manage conflicts of interest in order to protect the integrity of Disabled Women Ireland and to ensure that all Steering Committee members act in the best interest of the organisation.

Objective

The Steering Committee of Disabled Women Ireland will ensure that all Committee members are aware of their obligations to disclose any conflicts of interest they may have, and to comply with this policy to ensure they effectively manage those conflicts of interest as representatives of Disabled Women Ireland

Scope

This policy applies to: the Board of Directors, the Steering Committee and members of the Working Groups of Disabled Women Ireland.  It also applies to anyone working for or on behalf of Disabled Women Ireland in any capacity.

Definitions of Conflicts of Interest

A conflict of interest is any situation in which a Board Member, a Steering Committee Member or Working Group members’ personal interests or loyalties could, or could be seen to, prevent that person from making a decision in the best interest of the organisation.  This personal interest may be direct or indirect, and can include interests of a person connected to the member of Disabled Women Ireland. 

These situations present the risk that a person will make a decision based on, or affected by, these influences, rather than in the best interests of the organisation and therefore must be managed accordingly. 

Policy

This policy has been developed because conflicts of interest commonly arise, and do not need to present a problem to the organisation if they are openly and effectively managed. It is the policy of Disabled Women Ireland as well as a responsibility of its Board and Steering Committee, that ethical, legal, financial or other conflicts of interest be avoided and that any such conflicts (where they do arise) do not conflict with their obligations to Disabled Women Ireland.

Disabled Women Ireland will manage conflicts of interest by requiring Board Members, Steering Committee Members and Working Group Members to: 

  1. avoid conflicts of interest where possible 

  2. identify and record any conflicts of interest 

  3. carefully manage any conflicts of interest, and 

  4. follow this policy and respond to any breaches. 

Responsibility of the board of Disabled Women Ireland

The board is responsible for: 

  1. establishing a system for identifying, disclosing and managing conflicts of interest across the organisation; 

  2. monitoring compliance with this policy; and 

  3. reviewing this policy on an annual basis to ensure that the policy is operating effectively. 

Identification and disclosure of conflicts of interest

Once an actual, potential or perceived conflict of interest is identified, it must be entered into Disabled Women Ireland’s register of interests, as well as being raised with the Steering Committee. The register of interests must be maintained by the Secretary, and record all information related to a conflict of interest (including the nature and extent of the conflict of interest and any steps taken to address it).

Confidentiality of disclosure

All interests shall be outlined on a Declaration of Interest Form which will be completed annually by all members of the Board, Steering Committee and Working Groups.  The forms will be returned to the Secretary who will record them on the Register of interests.  The Register of Interests will be available to the Steering Committee. 

Action required to manage conflicts of interest

Conflicts of interest of members of the steering committee or Working Groups

Once the conflict of interest has been appropriately disclosed, the steering committee (excluding the disclosing person and any other conflicted person) must decide whether or not a conflicted person should: 

  1. vote on the matter (if applicable)

  2. participate in any debate, or 

  3. be present in the room during the debate and the voting. 

In exceptional circumstances, such as where a conflict is very significant or likely to prevent a Steering Committee Member from regularly participating in discussions, it may be worth the Steering Committee considering whether it is appropriate for the person with the relevant conflict to resign their position. 

What should be considered when deciding what action to take 

In deciding what approach to take, the Steering Committee will:: 

  1. consider whether the conflict needs to be avoided or simply documented 

  2. whether the conflict will realistically impair the disclosing person’s capacity to impartially participate in decision-making 

  3. alternative options to avoid the conflict 

  4. the organisations assets and resources, and 

  5. the possibility of creating an appearance of improper conduct that might impair confidence in, or the reputation of, the organisation. 

The approval of any action requires the agreement of at least a majority of the Steering Committee (excluding any conflicted person) who are present and voting at the meeting. All details regarding the conflict of interest, including the action arising, will be recorded in the minutes of the meeting. 

Compliance with this policy

If the Steering Committee has a reason to believe that a person subject to this policy has failed to comply with it, it will investigate the circumstances.  If it is found that this person has failed to disclose a conflict of interest, the Steering Committee may take action against the person. This may include seeking the person’s resignation from the organisation.

If a person suspects that a Steering Committee or Working Group member has failed to disclose a conflict of interest, they must discuss it with the person in question and  notify the Steering Committee through the Secretary.

Contacts 

For questions about this policy, contact the Steering Committee through the Secretary.