Conflict of Interest
1. Purpose
1.1 As members of Presbyterian Preschool Services Ltd., we have an obligation to act in the best interest of Presbyterian Preschool Services Ltd.. Hence, we need to avoid situations where there may be real, potential, or perceived conflicts of interest, which may arise where a member’s personal or family interest conflicts with those of Presbyterian Preschool Services Ltd.
1.2 Such conflicts may create problems that may result in the following:
a. Cause damage to Presbyterian Preschool Services Ltd.’s reputation which may lead to its inability to sustain operations;
b. Influence the members’ judgement and compromise objectivity when conducting Presbyterian Preschool Services Ltd.’s affairs;
c. Restrict free discussion, thus resulting in decisions or actions that are not in the interests of Presbyterian Preschool Services Ltd.; and
d. Risk the impression that Presbyterian Preschool Services Ltd. has acted improperly.
1.3 This Policy aims to protect both Presbyterian Preschool Services Ltd. and its members from any appearance of impropriety.
2. Definitions
2.1 “Member” refers to a board member, management member, staff member or volunteer member of Presbyterian Preschool Services Ltd.
2.2 “Policy” refers to the Conflict of Interest Policy.
2.3 “Interest” means any commitment, investment, relationship, obligation, or involvement, financial or otherwise that may influence a person’s judgement. This would include:
a. Direct interest – ownership in the name of the member / employee;
b. Indirect interest – ownership beneficially held through another investment, estate, trust, or other intermediary;
c. Vested interest – personal stake or involvement, which may or may not include an expectation of financial gain;
d. Deemed interest – a member / employee is deemed to have an interest which his / her relative / spouse holds an interest;
e. Potential interest – a member / employee does not have a direct / indirect interest currently but might become an actual interest in future; and
f. Perceived interest – a member / employee does not have any direct / indirect / potential interest, but an individual could reasonably think that there is an interest involved.
2.4 A conflict of interest arises when the personal interests of the member / employee may potentially interfere with the performance of his / her duties in Presbyterian Preschool Services Ltd.. When actual, potential, or perceived conflict of interest arises, the integrity, fairness and accountability of the person may be affected, which could impede the best interest of Presbyterian Preschool Services Ltd..
3. Declaration of Interests
3.1 Given the stated purpose of this Policy, we are asking: a. board and management members to declare their interests, and any gifts or hospitality received in connection with their role in Presbyterian Preschool Services Ltd.; and b. staff and volunteer members to declare when the transaction to be effected may result in a conflict of interest.
3.2 A declaration of interest form is provided for this purpose. The types of interest to be declared will include, but not limited to the following:
a. Members who have friends or other personal or business relationships must carefully consider whether those relationships create conflicts of interest with their entrusted role in Presbyterian Preschool Services Ltd..
Examples include:
i. Hiring a relative or friend as an employee or vendor,
ii. Buying or selling goods or services from / to a family business for which others might compete,
iii. Having a personal relationship where there is an immediate reporting relationship
iv. Volunteering and / or having memberships in any other charities, or
v. Receiving goods / services as beneficiaries.
b. Members must disclose any outside activities, financial interest or relationship that may pose a real, potential, or perceived conflict of interest. Disclosures are to be made to the Board / Senior Management of Various Divisions / Supervisors and Head of the Human Resources Department, with the required approval obtained before accepting any position as an office or director of an outside business.
3.3 To be effective, the declaration of interests needs to be updated in written form when any changes occur.
3.4 In situations where members are not sure what to declare, or whether / when your declaration needs to be updated, they are strongly encouraged to err on the side of caution or seek advice from the Executive Director / Board.
3.5 All disclosure of interest made by members and decisions made by the Executive Director / Board on such matters must be recorded, updated, and filed with the Finance and HR Manager (or his designee).
3.6 A register of interests shall also be used to record all gifts of a value over S$100 received by members.
4. Operating Procedures
4.1 If the Board needs to decide on an issue where the Board member(s) has / have an interest, it is the responsibility of the affected member(s)/incumbent to:
a. Identify the potential conflict of interest;
b. Not participate in discussion of the program or motion being considered;
c. Not vote on the issue; and
d. Shall leave the room while the issue is being discussed.
4.2 If the Board needs to decide on an issue where the Board member(s) has / have an interest, it is the responsibility of the Board to ensure that:
a. All decisions are made by vote, with a majority required based on the presence of a quorum; and
b. Interested Board members must not vote on matters affecting their own interests and shall leave the room.
4.3. It is the responsibility of the Board to:
a. Only decide to hire or contract with any vendor if they are the best qualified individuals available, and willing to provide the goods or services needed at the best price. The Board’s decision shall not be influenced in any way by the fact that a Board member has an interest in the contract.
b. Record in the minutes of the Board Meeting the potential conflict-of-interest, and the use of the procedures and criteria of this policy.
4.4 Disclosure involving Board members should be made to the Board’s chairperson. However, if the Board’s chairperson is involved in the conflict of interest situation, such disclosure shall be made to the Board.
4.5. It is the sole responsibility of any member of Presbyterian Preschool Services Ltd. to report any possible real, potential, or perceived conflict of interest. If it is an oversight of Presbyterian Preschool Services Ltd., the member shall promptly inform Presbyterian Preschool Services Ltd. that he has been put in such a position of conflict of interest.
4.6 No member of Presbyterian Preschool Services Ltd. shall derive any personal profit or gain, directly or indirectly, by reason of his or her participation with Presbyterian Preschool Services Ltd.. Each individual shall disclose to Presbyterian Preschool Services Ltd. any personal interest which he or she may have in any matter pending before the organisation and shall refrain from participation in any decision on such matter.
4.7. Any member of Presbyterian Preschool Services Ltd. or of a client organisation or vendor of Presbyterian Preschool Services Ltd. shall identify and declare his or her affiliation with such agency or agencies; further, he shall not participate in the decision affecting that agency.
4.8 Any member of Presbyterian Preschool Services Ltd. or its Consultants / Business Partners shall refrain from obtaining any list of clients for personal or private solicitation purposes at any time. during the term of their affiliation.
4.9 Any member who is also a user of the Presbyterian Preschool Services Ltd.’ services, or the caregiver of someone who uses Presbyterian Preschool Services Ltd.’ services shall not be involved in decisions that directly affect the service received by the person he / she cares for. He / She shall declare his / her interest at the earliest opportunity and withdraw from any subsequent discussion. The same applies of the conflict concerns any other reason(s).
4.10 A member of Presbyterian Preschool Services Ltd. may, however, participate in discussions from which he / she may indirectly benefit, for example where the benefits are universal to all users.
4.11 The Board of Presbyterian Preschool Services Ltd. shall have the right to suspend any involvement of any member / employee when it has come to their attention that a potential actual or perceived conflict has arose but has not been voluntarily disclosed by the relevant member.
5. Violations
5.1 Any violation will result in discipline, up to and including termination from employment or removal from the board, or expulsion from being a volunteer member of Presbyterian Preschool Services Ltd..