Conflict of Interest Policy
Last Revised on 20-May-2025
Purpose
The purpose of this policy is to assist the Board of Directors of Cork Unitarian Church to effectively identify, record and manage any conflicts of interest in order to protect the integrity of Cork Unitarian Church and to ensure that the Board of Directors act in the best interest of their charity.
Objective
The Board of Directors aims to ensure that its board members are aware of their obligations to disclose any conflicts of interest that they may have, and to comply with this policy to ensure they effectively manage those conflicts of interest as representatives of Cork Unitarian Church.
Scope
This policy applies to the church leadership of Cork Unitarian Church. This includes all Board of Directors members (i.e. elected members, coopted/appointed members, and de jure members). It also includes all employees and any volunteer in a leadership position.
Definition of "Conflicts of Interest"
A conflict of interest is any situation in which a church leader’s personal interests or loyalties could, or could be seen to, prevent them or others from making a decision in the best interests of Cork Unitarian Church.
This personal interest may be direct or indirect, and can include interests of a person connected to the church leader.
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 charity 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 Cork Unitarian Church if they are openly and effectively managed. It is the policy of Cork Unitarian Church as well as a responsibility of its Board of Directors, 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 Cork Unitarian Church.
Cork Unitarian Church will manage conflicts of interest by requiring church leaders to:
- avoid conflicts of interest where possible
- identify and record any potential conflicts of interest
- carefully manage any conflicts of interest
- follow this policy and respond to any breaches
Responsibility of the Board of Directors
The Board of Directors is responsible for:
- establishing a system for identifying, disclosing and managing conflicts of interest across the charity
- monitoring compliance with this policy
- reviewing this policy on an annual basis to ensure that the policy is operating effectively
The Board of Directors should ensure they are aware of their legal obligations in the management and control of Cork Unitarian Church and should refer to the Charities Regulator’s ‘Guidance for Charity Trustees’.
Identification and Disclosure of Conflicts of Interest
Once an actual, potential or perceived conflict of interest is identified, it must be entered into Cork Unitarian Church’s register of interests, as well as being raised with the Board of Directors. The register of interests must be maintained by the President of the Board of Directors, 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 Disclosures
The register of interests is to be confidential to the Board of Directors. Individual entries, not pertaining to a member of the Board of Directors, may be shared with the individual to whom that entry pertains.
Retention of entries is three years from the time the disclosure is no longer relevant.
Action Required for Management of Conflicts of Interest
Conflicts of Interest of Members of the Board of Directors
Once the conflict of interest has been appropriately disclosed, the Board of Directors (excluding the disclosing Board of Directors member and any other conflicted person) must decide whether or not a conflicted Board of Director member should:
- vote on the matter (this is a minimum)
- participate in any debate
- 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 charity trustee from regularly participating in discussions, it may be worth the Board of Directors considering whether it is appropriate for the person with the relevant conflict to resign from the Board of Directors.
What Should be Considered When Deciding What Action toTake
In deciding what approach to take, the Board of Directors will consider:
- whether the conflict needs to be avoided or simply documented
- whether the conflict will realistically impair the disclosing person’s capacity to impartially participate in decision-making
- alternative options to avoid the conflict the charity’s objects and resources, and
- the possibility of creating an appearance of improper conduct that might impair confidence in, or the reputation of, the charity
The approval of any action requires the agreement of at least a majority of the church committee (excluding any conflicted charity trustee) who are present and voting (if applicable) 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 Board of Directors 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 Board of Directors may take action against the person. This may include seeking the person’s resignation from Cork Unitarian Church.
If a person suspects that a church leader has failed to disclose a conflict of interest, they must:
- discuss with the person in question
- notify the Board of Directors, or the person responsible for maintaining the register of interests
Contacts
For questions about this policy, contact the Board of Directors or Neal Dunnigan at Chaplain@CorkUnitarianChurch.com.