Conflict of Interest Policy

Approved by CCMAC on 2 November 2023

Purpose of the Policy 

In order to maintain the integrity of, and public confidence in CCMAC’s processes it is essential that the work of CCMAC is not compromised by any conflict of interest by its Committee members (or those who execute its work).

The overall purpose of this policy is to protect the legitimacy, integrity, trust and credibility of CCMAC and of those directly involved in its activities. This policy is principles-based so does not provide an exhaustive list of criteria for the identification of any conflict.

CCMAC recognises the commitment and dedication of the members who participate in CCMAC’s activities and it seeks to ensure that there is a local and increasingly diverse representation within its Committee. 

As a result this policy maintains a balance between the need to minimise the reporting burden and ensuring the integrity and independence of the CCMAC process, as laid out in the CCMAC constitution and that the Committee continues to build and maintain public trust.

The CCMAC Conflict of Interest Policy is designed to ensure that conflicts of interest are identified, communicated to the relevant parties, and managed in order to avoid any adverse impact on CCMAC processes, thereby protecting the individual, the organisations represented at CCMAC, CCMAC, and the public interest. The individual and CCMAC should not be placed in a situation that could lead any reasonable person to question, and perhaps discount or dismiss, the work of CCMAC simply because of the existence of a conflict of interest. 

Understanding Conflict of Interest

Committee members have a duty to act in the best interest of CCMAC, or, where appropriate, of the Organisation or electorate that affiliated them as a member to CCMAC. 

A conflict of interest, or conflict of loyalty, is any situation where a Committee member’s external interests or interest they owe to another person or body, may influence a Committee member’s decision making. This should include any business and personal interests and those of a Committee member’s spouse, partner, family or close relatives.

A perceived conflict of interest is where a member’s external interest could be seen to influence their decision, even if it doesn’t. It’s important to recognise where conflicts might be perceived, even if the members feels confident it won’t affect their decision. 

If a situation constitutes or could be perceived to be a conflict of interest, it’s best to treat it as one.

There are situations in which a committee member’s commitment to the aims and objectives of CCMAC as set out in the Constitution conflicts with their commitment to the body which appointed them. In this situation that latter commitment must take precedence;  the committee member is correctly representing the organisation that appointed them, but must make this overriding interest explicit to CCMAC.

But there may also be situations when a committee member’s commitment to the aims and objectives of CCMAC conflicts with a body which they are a member of, which is not affiliated with CCMAC.  These situations may indeed cause conflicts of interest, or perceived conflict, but in this context, they can be an important and positive part of the decision-making process. In such situations they should be stated to the Committee in the interest of transparency.

Identifying Conflicts of Interest

As soon as a Committee member is aware of a conflict, actual or perceived, they should raise this with the Chair.

If a member has a short term interest or a conflict of interest they should declare that interest at the start of any meeting or discussion relating to the area of conflict.

If it is an ongoing conflict (eg new commitment), this should be recorded into the Register of Interests.

 Managing Conflicts of Interest

Having a conflict of interest doesn’t always mean a Committee Member shouldn’t be involved in decision-making. However, it’s the duty of CCMAC to make sure conflicts are managed properly so decisions taken by the Committee are balanced and there is no risk they might be influenced by private interests. 

When a Committee member declares a conflict of interest, the Chair will seek agreement from CCMAC on how to manage it.

The degree of risk would be assessed on  the extent of member’s involvement in both interests, sums of money involved and the degree of controversy.

If CCMAC judges the conflict to be low risk, and the Committee member is able to meaningfully contribute, the Committee may choose to note the interest of that member formally in the minutes, but allow them to participate in the discussion. The member should be excluded from any voting that takes place. 

If the conflict is high risk and the Committee member is unable to participate without being influenced (or if it might be seen that way by an outside observer), CCMAC should ask the member to step away from the discussion and it should be recorded in the minutes that they have not had any part in discussion, decision making or voting.

Review of Conflict of Interest.

The policy will be reviewed annually in time for re-adoption at the CCMAC annual meeting.

Clapham Common Management Advisory Committee

November 2023