Effective Date: 08/05/2025
Review Date: 08/05/2026
Approved by: Board of Trustees

1. Policy Statement
The Global Health Access Trust (“the Trust”) is committed to ensuring that all decisions and activities are made solely in the best interests of its charitable mission. Trustees, staff, and volunteers must avoid situations where personal or professional interests could conflict, or appear to conflict, with their duties to the Trust.

This policy is designed to protect the integrity of the Trust’s decision-making, maintain public trust, and ensure compliance with charity law and the Charity Commission's guidance on managing conflicts.

2. Scope
This policy applies to:

- All Trustees

- Employees, contractors, and volunteers

- Advisory committee members or associated third parties involved in Trust activity or decision-making

3. What is a Conflict of Interest?
A conflict of interest may arise where a trustee or staff member’s personal, professional, or financial interests interfere—or appear to interfere—with their duty to act in the best interests of the Trust.

Examples include (but are not limited to):

- Financial benefit to a trustee (directly or via a connected person or organisation)

- Decisions involving family members or business partners

- Involvement in organisations applying for funding from the Trust

- Receiving gifts or hospitality that could influence judgement

4. Legal Duties of Trustees
Trustees have a legal duty to:

- Act only in the best interests of the charity

- Avoid situations where personal interests conflict with their responsibilities

- Declare any actual or potential conflict of interest as soon as it arises

Not receive any financial benefit unless it is explicitly authorised in the governing document or by the Charity Commission

5. Declaration of Interests
Trustees must complete an annual Declaration of Interests form listing any relevant interests (financial or non-financial)

Interests must include those of close family members and any organisations to which the trustee is connected

A register of interests will be maintained and updated regularly by the Governance Lead or Secretary

6. Managing Conflicts
If a conflict arises:

Declaration: The individual must declare the nature of the conflict to the Board immediately

Record: The conflict will be recorded in the minutes and the Conflict Register

Action: The conflicted person must not take part in any related decision, discussion, or vote

Withdrawal: Where appropriate, the individual will be asked to leave the room during discussion

Independent Review: The remaining trustees will determine whether the conflict is manageable or requires further action

7. Trustee Benefits and Authorised Payments
No trustee may receive a financial benefit from the Trust unless it is:

- Permitted in the Trust’s governing document

- In the best interests of the charity

- Properly documented and approved by unconflicted trustees

- Compliant with Charity Commission requirements

8. Breaches of Policy
Failure to disclose a conflict of interest may result in:

- Disciplinary action

- Removal from the Board

- Reporting to the Charity Commission

9. Review
This policy will be reviewed annually by the Board of Trustees and updated in line with Charity Commission guidance.

Contact for Governance & Compliance Enquiries:
Richard Banyard
Subject Line: Conflict of Interest – Private