This policy outlines Safety Training Awards intention to identify and monitor all potential or actual conflicts of interest that may affect the delivery and / or assessment of our qualifications now or in the foreseeable future. It has also been designed to support centres in identifying potential or actual cases of conflict of interest and how to appropriately manage them.
To reduce the risk of a conflict of interest happening we record possible cases that have been identified to date and any arrangements that are in place to prevent them from occurring.
Safety Training Awards are required to adhere to the General Conditions of Recognition and the Regulatory Principles. From time to time we may be required to provide our regulators with evidence that we are complying with their requirements in relation to conflicts of interest, and to prevent such conflict creating an incident or having an adverse effect on our qualifications.
Definitions of Conflict of Interest
For the purpose of this policy we have adopted the definition used by the regulatory authorities regarding conflicts of interest. A conflict of interest exists in relation to Safety Training Awards in the following way:
- Its interests in any activity undertaken by it, on its behalf, or by a member of staff which have the potential to lead it to act contrary to its interests in the development, delivery and award of qualifications in accordance with the requirements of the regulators conditions of recognition
- A person who is connected to the development, delivery or award of qualifications at Safety Training Awards has interests in any other activity which have the potential to lead that person to act contrary to their interests in that development, delivery or award and impact on our compliance with the requirements set out by the regulator’s conditions of recognition
- An informed and reasonable observer would conclude that either of these situations was the case.
Definition of an Adverse Effect / Management of Incidents
For the purpose of this policy we have adopted the definition used by the regulatory authorities regarding an adverse effect / management of incidents:
An act, omission, event, incident or circumstance has an adverse effect if it:
- Gives rise to prejudice to learners or potential learners, or adversely affects
- Adversely affects the ability of Safety Training Awards to undertake the development, delivery or award of qualifications in accordance with its General Conditions of Recognition and Regulatory Principles
- The standards of qualifications which Safety Training awards makes available or proposes to make available, or
- Public confidence in Safety Training Awards qualifications.
A conflict of interest is where an individual or organisation has competing interests or loyalties. Conflicts of interest may occur in a variety of circumstances and it is possible that people working alongside and/or for Safety Training Awards may encounter potential conflicts of interest from time to time.
Examples of Conflicts of Interest
It is not possible to provide a definitive list of examples of conflicts of interest that could compromise the integrity of Safety Training Awards assessments and qualifications. However, the following situations could lead to perceived or actual conflicts of interest (this list is not exhaustive):
- Tutors, Assessors, Markers / delivering, assessing, marking / quality assuring husband, wife, partner, members of their family or friends
- Tutors, Assessors, Markers, or IQAs assessing / quality assuring their own work
- Personal relationships with partners, family members or friends linked to centre personnel and / or learners that could influence decision making and qualification outcomes
- Subcontracting Tutors, Assessors, Markers, and IQAs from another ATC
- Agreeing to fulfil the mandatory roles in more than one ATC
- Business or commercial interests linked to Safety Training Awards and/or a centre that may affect professional judgement
- Mutually beneficial arrangements with centre and Safety Training Awards personnel which may compromise an individual’s ability to make reliable and professional judgements
- Where favourable arrangements have been negotiated, for example supplying information to certain individuals and/or groups who are preparing for or carrying out an assessment
- A person connected with Safety Training Awards or a centre who are engaging in some capacity or have a material financial interest in a business or enterprise that compete with Safety Training Awards
- A centre has an interest in any activity which has the potential to lead it to act contrary to its interests in the development, delivery and award of qualifications in accordance with the conditions of the centre
- A situation that may create the appearance of a conflict or present a conflict of interest in connection with a person who has influence over the activities or finances of Safety Training Awards.
The existence of such interests, as those above does not necessarily imply conflict, but is likely to give an appearance of conflict and as such should be declared to Safety Training Awards.
Conflicts of interest are a high risk area to the regulators therefore Safety Training Awards expect all Centres to be aware of any perceived or actual cases of conflict of interest and how to appropriately manage them. If you believe there is a perceived or actual cases of conflict of interest the Centre Co-ordinator is responsible for putting appropriate measures in place to mitigate any risk to the assessment process or learner journey.
An example of this may be the Tutor and Assessor on a course are husband, wife, partner, family member, close friend, this would be deemed as an ‘actual’ conflict of interest. To mitigate any risk to the assessment process or learner journey Safety Training Awards would expect that centre to appoint an ‘Independent person’ to the process. This could be a different Assessor or arrange for the IQA to carry out a face to face observation of the assessment, providing an independent review of the assessment process.
Conflict of Interest Principles
Safety Training Awards staff are obliged to abide by the following principles when identifying and managing potential and/or actual conflicts of interest:
- All management and staff must commit to identifying and managing all potential and/or actual conflicts of interest that may affect Safety Training Awards, and in doing so must report these cases to the quality assurance manager
- All staff must be proactive in identifying and managing cases of conflicts of interest that may affect Safety Training Awards effectiveness, compliance with regulatory requirements and/or our reputation
- Staff must be open about any cases of potential and/or actual conflicts of interest and not withhold any information or try to present them in a better light (managing conflicts of interest is about preventing cases from occurring that may have an impact on the operational effectiveness and regulatory compliance at Safety Training Awards)
- Must strive to identify and deal with conflicts of interest as soon as they are identified
- The control for the management of conflicts of interest must be proportionate to the risks associated with the identified cases.
Responsibility to Register a Conflict of Interest
All individuals this policy applies to have a responsibility to report potential and / or actual cases of conflict of interest. This must be done by disclosing how the conflict will be managed and monitored effectively by completing the ‘Conflict of Interest Disclosure Form’ via the ATCs Synergy account. Please refer to the Synergy resources area on our website for additional guidance on completing this form.
Safety Training Awards centres must comply with this conflict of interest policy and ensure ongoing compliance with the following:
Take steps to avoid or reduce any existing or potential conflicts of interest
Centres must consider how they should manage working arrangements to avoid potential conflicts of interest. For example, a member of staff at the centre undergoing an assessment must be assessed by an unrelated assessor.
Complete and submit a copy of the conflict of interest disclosure form to Safety Training Awards via the ATCs Synergy record
All sections on the form must be completed providing as much information as possible on how the centre will mitigate any risk.
Maintain up to date records of all conflict of interest
Centres must maintain accurate records of all existing and/or potential conflicts of interest, details of all mitigating actions must be included.
Update records with any changes in circumstances and notify Safety Training Awards of any changes
Centres must notify Safety Training Awards of any changes to circumstances relating to any previously declared conflicts of interest and must submit a new disclosure form via Synergy, detailing any changes which may lead to new or potential conflicts of interest
Inspect activities and assessments where there is a conflict of interest that cannot be avoided
Centres must carry out additional quality assurance monitoring activities in cases where conflicts of interest are unavoidable.
- Personal or professional relationship between IQA’s, markers, assessors, tutors, and learners
- All personnel undertaking mandatory regulated qualifications within their own centre
- Instances of mutual quality assurance activities between IQA’s.
Procedures for Dealing with Conflicts of Interest
Where any member of personnel at a centre believes there has been a breach of this policy, or if any unforeseen conflicts of interest arise, the Head of Compliance and Assurance must be notified and an investigation should be carried out immediately.
The process for the above is as follows:
- The conflict of interest disclosure form must be completed providing as much information as possible, ensuring all sections of the form are complete
- A conflict of interest disclosure form must be completed by all personnel on commencement with a centre declaring any conflict of interest; the form is to be completed even when there are no conflicts of interest to declare. The form should be submitted to Safety Training Awards via Synergy, which will be retained on the ATCs record for quality assurance and monitoring purposes. This also allows the ATC to monitor their conflicts of interest and update them accordingly
- If an individual has any changes to their declared circumstances they must notify the centre co-ordinator immediately by completing the conflict of interest disclosure form; the new information should be evaluated, dealt with accordingly and submitted to Safety Training Awards via Synergy.
When all information relating to conflicts of interest are received at Safety Training Awards they will be evaluated by the Compliance Team to identify if any further action is required. A written response of the outcome will be held on the ATCs Synergy record for audit and standardisation purposes.
Most situations will not require any further action other than the completion of the conflict of interest disclosure form, however by following this process Safety Training Awards can ensure that any follow up action is appropriately managed.
We advise centre co-ordinators to retain original copies of all forms for their own records and submit copies to the Head of Compliance and Assurance at Safety Training Awards.
If a breach of this policy is also classified as an adverse effect then the Head of Compliance and Assurance will inform the regulators in accordance with the procedures for dealing with an adverse effect. They will also inform the regulators of the reasonable steps that have been taken or propose steps to prevent, correct or mitigate the adverse effect.
Examples of actions that could mitigate the conflicts are as follows:
- Person(s) not taking part in the assessment or verification
- Referring decisions that affect the competence of learners to an independent person
- Agreeing not to be involved in a specific aspect of the centres activities or processes
- Referring the matter to the Head of Compliance and Assurance at Safety Training Awards for advice and guidance.
Monitoring and Review
This policy and its procedures will be reviewed regularly for improvements as part of our quality assurance requirements. This will ensure it is fit for purpose, reflects the services we deliver to our centres and that we are providing services which are relevant to the requirements of individual needs
Safety Training Awards
Last Updated: 15th June 2021