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Draft, pending trustee approval

Conflict of Interest Disclosure Policy

To require trustees and senior staff to disclose a personal or financial interest that could affect an impartial decision.

Key provisions

  • A trustee discloses any relationship with a vendor, beneficiary, CSR partner or staff member that could influence a decision, before that decision is made
  • A trustee with a disclosed conflict does not vote on or sign off that specific matter
  • Related party transactions, as understood under Section 13 of the Income tax Act, are reviewed with particular care to avoid jeopardising the Trust's tax exempt status
  • Disclosures are recorded in the Trust's internal register, to be established as part of its governance manual

Escalation

Conflict of interest concerns go to the full Board of Trustees.

Policy record

ClassificationRecommended governance practice, directly relevant to Section 13 of the Income tax Act
Applicable legal referencesIncome tax Act 1961, Section 13, Indian Trusts Act 1882
Responsible roleManaging Trustee
Approval authorityBoard of Trustees, Dev's Foundation Trust
StatusDraft, not yet approved by the Trustees
Version0.1, draft
Review scheduleAnnually, or on a relevant change in law
This is a draft policy template written for site structure purposes. It has not been reviewed by a lawyer. Please have it checked against applicable Indian law, including the Digital Personal Data Protection Act 2023 where relevant, before publishing it as the Trust's actual policy.