Conflict of Interest Policy

Releasing Potential Conflict of Interest Policy (Qualifications) 2022-2023

1.0 Purpose:

The purpose of this policy is to protect our integrity as a Centre and the integrity of our qualifications and assessments. It is designed to support our staff by providing guidance on handling possible conflicts of interest that may happen because of our role as a Centre.

2.0 Scope:

This policy:

  • Defines what is meant by conflict of interest.
  • Describes the role of conflict of interest in the context of working with, or for, an awarding Centre.
  • Sets out the responsibilities for managing conflict of interest in the organisation.

3.0 Who does this policy apply to?

This policy applies to all individuals involved with any aspect of the planning, delivery or marking. Any other activity connected with external qualifications, tests, or assessments and supporting resources and services. This includes:

  • Permanent employees.
  • Fixed term employees.
  • Temporary employees, including agency staff.
  • Contractors and freelancers.
  • External assessors, examiners and Internal Moderators/Verifiers.

4.0 Definition:

4.1 A conflict of interest is a situation in which an individual, or organisation, has competing interests or loyalties. In the case of an individual, the conflict of interest could compromise, or appear to compromise, their decisions if it is not properly managed. For example:

  • Where the training delivery function and the Internal Verification/Moderation function rest within one individual or role within the Centre.
  • When an individual has a position of authority in one organisation or Centre function that conflicts with their interests in another organisation or Centre function.
  • Where someone (who delivers, assesses, internally verifies work or who makes qualification claims) has friends or relatives taking assessments or exams at the Centre.
  • When an individual has interests that conflict with their professional position as part of the team delivering/assessing/internally verifying/claiming for qualifications.
  • Where a role in the Centre has a commercial aspect in addition to a quality and/or standards aspect.
  • Where someone works for the Centre and is also a governor at a school, college, or training provider of the same qualifications.
  • Where a candidate for a qualification is also someone who delivers, assesses, internally verifies or makes claims for the qualification.
  • Where a candidate for a qualification is also an employee of the organisation.

4.2 Whilst it may be apparent to the individual that they do not have a conflict of interest, they need to consider whether the activity could be seen as a perceived conflict of interest.

A perceived conflict of interest is a situation where an outside observer could perceive that a Centre or individual has such a competing interest or loyalty. Perceived conflicts of interest must also be managed.

5.0 Commitment to managing potential conflicts of interest:

We will:

  • Make sure that when one part of the Centre creates and follows a procedure, it does not conflict with our responsibility to the awarding bodies that regulate our qualifications.
  • Assess and manage whether a conflict of interest may occur during any team restructures or changes to job roles within the Centre.
  • Review our processes relating to our awarding body activities every year to make sure that all conflicts of interest or potential conflicts of interest are logged, managed, and resolved.
  • Make sure that staff declare any friends or family sitting upcoming assessments at our Centre.
  • Ensure that where the training function is involved with a specific qualification, they are not involved in the assessment or Internal Verification of the qualification.

6.0 Process for reporting and managing conflicts of interest:

6.1 This policy will be circulated to all those involved in marking, assessing and internally moderating/ verifying student work as well as to staff undertaking qualifications internally.

6.2 Staff undertaking internal qualifications will be required to declare any conflict of interest in writing before submitting any work for assessment or undertaking any exams.

6.3 Line managers are responsible for checking that all new staff working in the Curriculum Team are made aware of this policy and understand how to raise potential conflicts of interest. Line managers will raise potential conflicts of interest at weekly Senior Leadership Team meetings.

6.4 Any potential or actual conflict of interest should be logged and kept on record by the Exams Officer. The Exams Officer must either resolve the issue or, for issues that cannot be resolved at this level, report the issue to the Head Teacher and (if appropriate at this time) the awarding body (ASDAN or NCFE). All records are required to be available for audit purposes.

6.5 Individuals must report any activity that might create a potential conflict of interest. If there is any doubt whether it represents a conflict of interest it should be raised to your line manager in the first instance.

6.6 The individual and line manager are both responsible for documenting the issue carefully, ensuring the Exams Officer is made aware and given copies of any documents.

6.7 An individual may want to raise concerns relating to conflict of interest directly with the awarding body. This can be done in confidence, and they are entitled to receive a response to their concerns. 

6.8 Any staff member considering paid or unpaid work outside Releasing Potential should inform their manager if they think there is any potential for a conflict of interest. If the staff member is unsure whether a conflict of interest might arise, they should discuss this with their line manager first and keep a record of that conversation.

Review date: 1st August 2023