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Conflict of Interest Policy

Approved By

Full Council

Author

Dan Gwalter

Confidentiality
Public
Date Published
November 4, 2025
Document Reference

WES-POL-0003

Notes

Owner (Role)
Secretary
Policy Group
Governance and Conduct
Review Date
November 4, 2027
Status
Published
Version

1.0

Visible on Website
  • 1. Purpose
  • 2. Scope
  • 3. Definitions
  • 4. Policy Statement
  • 5. Roles and Responsibilities
  • 6. Policy Detail and Procedures
  • 6.1 Annual Declarations
  • 6.2 Meeting Participation
  • 6.3 Register of Interests
  • 6.4 Breach Handling
  • 7. Related Policies and References
  • 8. Compliance and Breach Handling
  • 9. Review and Version Control
  • 10. Approval Record

1. Purpose

This policy ensures that the Western Equestrian Society (WES) maintains transparency, impartiality, and integrity in its decision-making processes. It sets out the expectations for Council members to identify, declare, and manage any conflicts of interest - whether actual, potential, or perceived - that could interfere with their duties to the Society.

Conflicts of interest are not inherently wrong or uncommon. What matters is that they are declared early and managed responsibly, so that WES decisions are made - and seen to be made - in the best interests of the Society as a whole.

2. Scope

This policy applies to all members of the WES Council as described in the WES Constitution. It covers all governance activity, including:

  • Discussions and decisions at Council meetings
  • Voting on motions or appointments
  • Participation in working groups or panels
  • Use of WES funds or resources
  • Relationships with external organisations or individuals

It does not apply to general members unless they are acting in an official governance role.

3. Definitions

  • Conflict of Interest: A situation in which a Council member's personal, financial, or professional interests could influence - or be perceived to influence - their decision-making on behalf of WES.
  • Pecuniary Interest: Any situation where a Council member (or their family or business) could gain or lose financially based on a Council decision.
  • Non-pecuniary Interest: Personal connections, friendships, rivalries, or reputational issues that could bias a member's judgement or actions.
  • Perceived Conflict: Even if a member believes they are acting impartially, the situation may still appear to others as a conflict - and must be handled accordingly.

4. Policy Statement

All Council members are expected to act in the best interests of the Western Equestrian Society at all times. Decisions should be made fairly, objectively, and without undue influence from personal interests.

Where a conflict of interest exists - or might reasonably be perceived to exist - the Council member must declare it and withdraw from the relevant discussion and/or vote. This principle applies regardless of intent or outcome.

Failure to follow this policy undermines trust and accountability and may result in disciplinary action.

5. Roles and Responsibilities

Role
Responsibility
Secretary
Maintain the Register of Interests; ensure annual declarations are collected and stored; support the Council in interpreting this policy.
Council Members
Complete an annual Declaration of Interests; update their declaration when circumstances change; withdraw from discussion and voting where a conflict exists.
Chairperson
Facilitate fair participation in meetings; act on reported conflicts; ensure records of declarations and withdrawals are minuted where appropriate.

6. Policy Detail and Procedures

6.1 Annual Declarations

  • All Council members must complete a Declaration of Interests upon appointment and annually thereafter.
  • Interests may include professional roles, family connections, financial relationships, or affiliations with other organisations.
  • Updates must be submitted within one month of any material change.

6.2 Meeting Participation

  • Council members are individually responsible for identifying and declaring conflicts relevant to agenda items.
  • The Chair will not prompt declarations at the start of every meeting - instead, members must withdraw from discussion and/or voting if their participation could reasonably be seen as biased or self-interested.
  • The Chair may record the withdrawal in the minutes where necessary for transparency.

6.3 Register of Interests

  • A confidential Register of Interests will be maintained by the Secretary and reviewed annually.
  • Access will be limited to the Chair and Secretary unless disclosure is agreed or required.

6.4 Breach Handling

  • Failure to declare a conflict of interest, or participation in decision-making despite a known conflict, will be treated as a breach of this policy.
  • Such breaches will be managed through the Society's disciplinary process.

7. Related Policies and References

  • WES Code of Conduct
  • WES Constitution
  • WES Disciplinary Procedure
  • WES Declaration of Interest Policy (WES-POL-0004)

8. Compliance and Breach Handling

Breaches of this policy will be referred to the Chair and handled through the WES Disciplinary Procedure. This may include investigation, formal warning, or removal from Council depending on severity. Where reputational risk exists, a holding statement may be prepared to reassure the membership that the matter is being addressed.

9. Review and Version Control

Version
Date
Author
Changes Made
0.1
18/07/2025
DG
Initial policy draft
0.5
08/10/2025
DG
Changes following Chairman's review
1.0
04/11/2025
DG
Published

10. Approval Record

Approved By
Date
Notes
Full Council
04/11/2025
Approved for immediate use