Conflicts of Interest Policy

1Purpose

1.1Every decision under the CSR framework must be made on its merits and in the interests of the programme, and must be seen to be so. This policy sets out how Eurabelt Fuels Ltd identifies and manages conflicts of interest so that decisions are impartial and auditable.

2Scope

2.1This policy applies to the directors, employees and representatives of Eurabelt who take part in, or can influence, any decision about an application, a partnership or a contribution under the framework.

3What a conflict of interest is

3.1A conflict of interest arises where a person’s personal interests, or the interests of a connected person, could influence, or could reasonably be seen to influence, the performance of that person’s duties for Eurabelt. It may be actual, potential or perceived.

3.2Examples include:

• being a trustee, director, employee, member, volunteer or beneficiary of an organisation that applies for or holds a partnership;
• a family member or close associate holding such a position;
• a financial interest in an applicant or partner, or in a supplier to it;
• having received a gift, hospitality or other benefit from an applicant or partner;
• a commercial relationship between an applicant or partner and a business in which the person has an interest.

3.3A connected person includes a spouse or partner, a parent, child or sibling, a close business associate, and any organisation in which any of them has a significant interest.

4Declaration

4.1Every person within scope must declare any interest that could give rise to a conflict:

• on taking up their role, and at least once a year after that;
• as soon as they become aware of a new conflict;
• at the start of any meeting or assessment in which the conflict is relevant.

4.2Declarations are made in writing to Compliance and recorded in the register of interests. If in doubt, a person should declare.

5Management of conflicts

5.1Where a conflict is declared, the person concerned takes no part in the assessment, discussion, decision or monitoring of the matter, and does not receive the papers relating to it, unless Compliance decides in writing that other measures are sufficient. The decision is taken by people without a conflict, and the declaration and the measures taken are recorded with the decision.

5.2An application from an organisation connected with a director, employee or representative of Eurabelt is assessed under the same requirements as every other application, and its connection is disclosed in the record.

6Private charitable activity

6.1Private charitable activities by company principals or employees are separate matters not covered by the CSR Framework Policy (EBF-CSR-POL-06). They must not be presented as activities of the programme, and must not influence decisions under it.

7Breach and review

7.1Failure to declare a conflict, or to follow the measures agreed, may lead to disciplinary action and to the review of any decision affected. Concerns may be raised under the Complaints and Speak-Up Policy (EBF-CSR-POL-11).

7.2This policy is owned by Compliance and reviewed at least once a year.