This Conflict of Interest Policy and Declaration form must be read by the parish/church entity employee or volunteer upon hiring, appointment to a specific role or election to the board of an entity, as an acknowledgement of having understood the policy and that he/she will fully disclose to an appropriate higher authority when a conflict of interest situation arises.
1. Definition of Conflict of Interest
1.1. Conflict of interest arises whenever the personal or professional interests of a board member, employee or volunteer are potentially interfering with the performance of their official duties to the organisations they serve in.
1.2. When actual, potential or perceived conflict of interest arises, the integrity, fairness and accountability of the parish/church entity could be affected.
2. Conflict of Interest Situations
Conflict of interest situations include but are not limited to the following:
2.1. Contract with vendors
2.1.1. Where parish/church entity employees or volunteers have personal interest in business transactions or contracts (or personal relationships with the vendor/contractor) that the parish/entity may enter into, such personal interest must be declared as soon as possible, and the individual should abstain from discussion and decision-making on the matter.
2.1.2. All such discussion and evaluation by the relevant approving authority in arriving at the final decision on the transaction/contract should be well documented.
2.2. Vested interest in other organisations that have dealings/relationship with the parish/church entity
2.2.1. Where parish/church entity employees or volunteers who have vested interest in other organisations that have dealings/relationship with the parish/church entity, and when matters involving the interests of both the parish/church entity and the other organisation are discussed, there should be a declaration of such interest and if necessary, followed by abstention from discussion and decision-making on such matters.
2.3. Recruitment of employees with close relationship
2.3.1. Recruitment of employees with close relationship (i.e. those who are more than just mere acquaintances) with parish/church entity employees or volunteers should go through the established human resource procedures for recruitment. Those involved should make a declaration of such relationships and should refrain from participating in the decision on the recruitment.
2.4. Involvement in Politics
2.4.1. Political involvement can give rise to questions about the impartiality of the individual, the impartiality of the area in which they work and the impartiality of the church as a whole. Employees or volunteers including Board and Committee members have to be discerning about involving themselves in controversial matters of public policy related to organisations which campaign on political or public policy issues.
2.4.2. Employees or volunteers including Board and Committee members cannot use their position in the Church as a means and platform to promote any other organisations of which they are a member. Likewise, they should not get involved with any organisations or groups that is illegal or banned by the Church.
2.4.3. Those involved in any political or related activities must declare their level of involvement, the nature and extent of involvement so that it can be fully considered in the light of the church. In some cases, it will also be appropriate to declare the political activities of family members.
2.5.1. Board members and volunteers should serve without remuneration for their voluntary service to the parish/church entity so as to maintain the integrity of serving for the mission and community good instead of personal gain. However, out-of-pocket expenses directly related to the service by board members or volunteers may be reimbursed.
2.6. Paid employees on the Board
2.6.1. Paid employees, including the executive head and senior employees employed by a church entity should not serve as a member of the board as it can pose issues of conflict of interest and role conflicts, and may raise doubts on the integrity of board decisions. The executive head and senior employees can attend board meetings, ex-officio, to provide information and facilitate necessary discussion but should not take part in the decision-making of the board.
2.7.1. Gifts, entertainment and other favours from any persons or entities which do or seek business with the parish/church entity, are prohibited.
2.8. Other references
2.8.1. Church entities involved in social and charity work should also refer to the Conflict of Interest policy guidelines recommended by the National Council of Social Services.
3. Disclosure Policy and Procedure
3.1 Transactions with parties with whom a conflicting interest exists may be undertaken only if all of the following are observed:
a) The conflicting interest is fully disclosed;
b) The person with the conflict of interest is excluded from the discussion and approval of such transaction;
c) A competitive bid or comparable valuation exists; and
d) The decision-making authority has determined that the transaction is in the best interest of the organisation.
3.2 Disclosure involving the parish priest or board members should be made to the Archdiocesan Office for Human Resource or the board chair (or if he/she is the one with the conflict, to the board vice-chair).
3.3 In the case of church entities, the board shall determine whether a conflict exists and in the case of an existing conflict, whether the contemplated transaction may be authorised as just, fair and reasonable to the church entity. The decision of the board on these matters will rest in their sole discretion, and their concern must be the welfare of the church entity and the advancement of its purpose.
3.4 All decisions made on such matters shall be minuted and filed.
3.5 This policy document must be read and understood by all employees and volunteers, especially those appointed to decision-making roles such as board members, upon the start of office.
3.6 Any disclosure of interest made by employees and volunteers where they may be involved in a potentially conflicting situation(s), must be recorded, filed and updated appropriately by all specified parties.
3.7 All employees and volunteers, especially those appointed to decision-making roles, must make an annual declaration regarding Conflict of Interest.