Conflict of Interest Policy

All activity carried out by PERSES and its approved centres involved in learner assessment:

  • PERSES relationship with CITB
  • External Quality Advisor with an interest or history with a centre
  • External Quality Advisor with relationship with an individual at a centre
  • PERSES contractor with a relationship with a centre
  • PERSES contractor with a relationship with an individual at a centre
  • Centre staff who have a relationship with a learner
  • Centre staff who have a relationship with each other
  • PERSES staff with a conflict with a contractor, centre or stakeholder Introduction

 

PERSES works with a number of centres and other organisations, as well as commerce and industry. It is therefore possible that such links may give rise to potential conflicts of interest. PERSES is therefore prepared through the following policy to detail how conflict of interest will be managed and reported.

This policy has been developed to ensure the integrity of units or qualifications developed, delivered and awarded by PERSES are upheld.

Definition

It is not possible to provide a comprehensive definition of the kind of circumstances which will give rise to a conflict of interest, but the following are examples of the most likely situations that will lead to perceived conflicts of interest. In any situation where an employee is uncertain as to the propriety of a given arrangement, advice should be sought from the governing body through line management.

A conflict of interest may be defined generally in two areas;

PERSES Staff and Contractors

A conflict between the official responsibilities of an employee of PERSES and any other interests the particular individual may have, e.g. where the individual may be in a position to influence PERSES business for actual or potential personal benefit or for that of a close family member, to seek such benefits at the expense of PERSES. Conflicts of interest are not restricted to cases in which an individual actually derives some advantage. They also arise and can be equally damaging where a conflict exists or appears to exist without any consequential behavioural impact.  PERSES policy on conflicts of interest does not imply any lack of trust in its staff or contractors. Moreover, it is designed to protect them against criticism by ensuring that they recognise and disclose such conflict situations and take steps to avoid and/or manage the situations as they arise.

 

PERSES Approved Centres

A conflict between the centre and their learners where the centre staff and learner have a personal relationship which could weaken the assessment process and the integrity of certificates subsequently issued. Additionally the conflict could arise if the centre staff involved in the assessment and internal quality assurance process are related and in a position to influence PERSES business for actual or potential professional or personal benefit through its activity.

Conflicts of interest are not restricted to cases in which an individual actually derives some advantage. They also arise and can be equally damaging where a conflict exists or appears to exist without any consequential behavioural impact. PERSES policy on conflicts of interest does not imply any lack of trust in its centres. Moreover, it is designed to protect them against criticism by ensuring that they recognise and disclose such conflict situations and take steps to avoid and/or manage them as they arise.

 

Disclosure and Review

PERSES Staff and Contractors

It is the duty of all staff and contractors of PERSES to disclose any actual or potential conflict of interest. Any employee or contractor who believes they have a conflict or potential conflict of interest should consult their line manager for advice and guidance on the best solution to mitigate the conflict.

Conflicts of interest should be reported to the line manager immediately and presented to the governing body for review. The record of disclosure shall cover the type of potential conflict, the nature of the activity, a description of all parties involved, the potential financial interests and rewards and any other information which the employee feels necessary to evaluate the disclosure. All disclosures will be reported to the governing body.

After appropriate evaluation, it may be determined that a proposed or ongoing agreement and the employee’s personal interests show no conflict or apparent conflict and are acceptable without further review. Conversely, it may be determined that some questions of propriety requiring a higher level of review have been identified. For each situation, the conflict register must be completed to demonstrate due diligence has been exercised and the conflict managed. Contractors must declare their conflicts of interest to the PERSES member of staff who engaged them for the piece of work.

Approved Centres

Centres must demonstrate that they have identified potential conflicts of interest and have a policy of managing the risk. Where the conflict directly impacts on the assessment process the External Quality Advisor should be notified prior to any assessment being conducted. The centre should have systems in place to manage the conflict, this could include increased sampling.