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Policy statement
It is the policy of Thames Valley Chamber of Commerce (TVCC) to maintain principles of openness, fairness and impartiality and to avoid conflicts of interest in relation to the Thames Valley Berkshire and Oxfordshire Local Skills Improvement Plans (LSIPs).

Why is a policy necessary?
This policy is to protect the interests of TVCC and its work as the designated Employer Representative Body for the Local Skills Improvement Plans (LSIPs).

It is a requirement of the DfE LSIPs’ Grant Funding Agreement Terms that formal procedures are set up to manage conflicts of interest.
In the regular course of business, agents, Advisory Panel members and TVCC employees may have the opportunity to advance their own personal interests with or against the interests of the LSIPs. Acting in such a manner is unacceptable and must be avoided.
This policy seeks to ensure that all relevant interests are disclosed and that all individuals working for or on behalf of TVCC on the LSIPs for Thames Valley Berkshire and Oxfordshire comply with this policy and raise any matters of concern.

Scope and applicability
This policy applies to all individuals working for or on behalf of the TVCC whether permanent, fixed term or temporary, and wherever located, including consultants, associates, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of the Chamber, (collectively referred to as “Workers” in this policy). In the context of the LSIPs this also includes members of the Thames Valley Berkshire and Oxfordshire LSIPs’ Advisory Panel and any other employers and stakeholders’ organisations undertaking work on the LSIPs, whether paid or unpaid.

What is a conflict of interest?
A conflict of interest is any situation where TVCC, as Designated Employer Representative Body, or one of our Workers, engages in any activity or obtains any financial, economic or other personal interest (directly or indirectly), which might (or might be perceived to) compromise their impartiality and independence in the context of performing the LSIP activity.

A conflict of interest can occur when an individual or organisation is put in a situation or circumstance that impacts their ability to apply impartial and independent judgement or act in their role in relation to the LSIP, or could be, impaired or influenced by a secondary interest. Even if the individual or organisation does not actually benefit, a conflict can still occur if it appears a decision may have been influenced. The perception of competing interests, impaired judgement or undue influence can also be a conflict of interest.

Some examples of what could constitute a conflict of interest to be declared by a participant are as follows:
– A family member being employed by the DfE
– A close relative being a member of a stakeholder on the Advisory Panel
– Any gifts or hospitality offered and received in connection with the Grant Activities
– The provision of training or other training interests or relevant activity in the local area
– This list is not exhaustive.

Communication of the Policy and Record keeping
These Registers of Interest will be retained by the TVCC. As the Designated Employer Representative Body we will publish this Conflict of Interest policy and maintain a Register of Interests.

This policy will be circulated to all of those in Scope above, together with a Register of Interests Form. We will request all of those listed in Scope, to complete a Register of Interests Form at least annually and to update this immediately should anything change. They should also raise any concerns or potential issues as they arise.

Managing conflicts of interest
We will take all reasonable steps to avoid conflicts of interest while at the same time achieving the most effective engagement with and input into the Berkshire and Oxfordshire LSIPs, taking advantage of the knowledge and expertise available.

The terms of reference for the Advisory Panel clearly articulate the position as follows:
“Although the Advisory Panel does not have any direct financial decision-making responsibilities, it does have a significant influence on the LSIP reports, project activities and recommendations. It is therefore essential that any member who may have a pecuniary or non-pecuniary benefit from any discussions or decisions declares those at the outset (through a Conflict-of-Interest form) and again prior to any relevant discussion to enable potential conflicts to be recognised and managed appropriately.”
We will not therefore necessarily exclude people or organisations from a discussion, depending on the nature of and outcomes sought from that discussion. We will monitor to ensure that no one uses their position inappropriately and will ensure that actions agreed do not give them an unfair advantage.
People may be excluded from a discussion or decision making, however, in certain cases.

Responsibilities and raising concerns
The prevention, detection and reporting of actual, potential and perceived conflicts of interest is the responsibility of all those working on the LSIP. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Workers must notify Karen Pharo, the Chamber’s Head of Finance and Operations,, as soon as possible if it is believed or suspected that a conflict of interests exists, may exist, may be perceived to exist or may occur in the future.
All Workers are aware that they are responsible for the success of this policy and should ensure they use it to disclose any suspected danger of or actual wrongdoing.

If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of this policy, they should raise their concerns with Karen Pharo, the Chamber’s Head of Finance and Operations,
As the Designated Employer Representative Body the TVCC must notify the Department for Education “without delay of any situation constituting or likely to lead to a conflict of interest”. TVCC must also immediately take all necessary steps to rectify the situation. As the Designated Employer Representative Body we must also comply with any additional measures that the Department for Education may require.

Any employee or contractor who breaches this policy may face disciplinary action. We reserve our right to terminate our contractual relationship in terms of the LSIP with non-employee Workers if they breach this policy. This includes non-contractual relationships in terms of work on the LSIP.

If, as Designated Employer Representative Body, we are unable to reasonably satisfy the Department for Education, in respect of a conflict of interest, the Department for Education may remove the designation.

All Workers will be briefed on this policy, which will also be made available publicly on the Thames Valley Berkshire and Oxfordshire LSIPs’ websites.

Monitoring and review
TVCC monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are also subject to regular review to provide assurance that they are effective in countering any risks of issues arising from actual or potential conflicts of interest.

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