Conflict of Interest Policy


Application

All members of SSQA

Purpose

To ensure that decision making on behalf of SSQA or its subsidiaries disclose and manage any conflict of interest they may have, and act in a manner consistent with their responsibilities, and the interests of the organization's stakeholders.


Policy

The guiding principles for the identification and management of conflicts of interest in any situations are:


1. All members of SSQA must be impartial and transparent at all times.


2. Conflicts of interest do not neccessarily imply wrong-doing. However, any interest which could give rise to a conflict of interest must be disclosed


3. Conflicts of interest must be recognised and handled appropriately; quickly and transparently.


4. In handling conflicts of interest, they must be:

5. If there is any doubt as to whether a conflict of intereset exists, they must be disclose to the matter to their manager or supervisor.


6. Consideration on how an impartial observer might reasonably percieve a conflict of interest situation or relationship, whether or not any wrong-doing is involved.


7. Conflicts of interest may raise complex issues, arising situations must be evaluated with the prudence and diligence.


8. Disclosure of conflicts of interest may involve disclosing personal information. This information must be handled due regard to the privacy of any individual or entity concerned.


9. individuals who have or are percieved to have a conflict of interest in the matter being considered must not take part in any discussion or decision on the matter giving rise to the conflict , unless the chair / relevant manager decided otherwise.


10. Persons who have a direct or indirect financial interest in the matter being considered must not take part in any decision about the matter.


Identification and effective management of conflicts of interest


11. Conflicts of interest must be disclosed to the their immediate manager or supervisor. When it comes to the committees, approach the relevant chair instead.


12. Each conflict of interest situation must be dealt with as soon asreasonably practicable after it is identified.


13. The situation must then be reviewed, managed and recorded by the relevant manager or chair in a manner that is appropriate to the circumstances. Relevance is determined with consideration to items 2, 6 ,7 ,9, 10 and other arising factors based on the nature of the supposed conflict.


14. Managers and supervisors must help to build awareness of conlict of interest situations, and support those who report to them to comply with their obligations under this policy.


15. Retaliation on reports made with no ill-intent will be harshly dealt with.