Conflicts of Interest Policy
This document outlines Trained Academy’s intention to identify and monitor all actual or potential conflicts
of interest that may affect Trained Academy both now and in the foreseeable future, and in doing so,
records possible conflicts of interest that have been identified to date and the arrangements in place to
prevent these from occurring.
It may from time to time be provided to the regulators upon request to satisfy them of Trained Academy
ability to comply with their requirements in relation to conflicts of interest, and to prevent such conflict
having an ‘Adverse Effect’ (as defined by the regulators).
Trained Academy will review this document annually as part of our self-evaluation arrangements. However, a review will be commissioned earlier should an issue arise in relation to an actual or potential conflict of interest and/or in response to customer, learner or regulatory feedback.
Definition of a conflict of interest:
For the purposes of this policy we have adopted the definition used by the regulatory authorities in relation to conflict of interests. In essence a conflict of interest exists in relation to Trained Academy where:
- Its interests in any activity undertaken by it, on its behalf, or by a member of its staff 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 regulator’s Conditions of Recognition.
- A person who is connected to the development, delivery or award of qualifications at Trained Academy has interests in any other activity which have the potential to lead that person to act contrary to his or her interests in that development, delivery or award and impact on our compliance with the requirements of the regulator’s Conditions of Recognition.
- An informed and reasonable observer would conclude that either of these situations was the case.
As an organisation that keeps all aspects of its business under review, individual teams are expected to identify and inform the Head of Quality and Standards (Paula Litherland) or in their absence, the Operations Director (Nicky Whitehurst) or the Sales and Marketing Director (Paula Litherland), of any actual/potential conflicts of interest that could impact Trained Academy and which are not already identified in the table at the end of this policy.
In addition, they are required to manage and monitor any identified conflicts of interest that relate to their area of operations (as outlined in the table at the end of this document). Should the status of any identified conflict, or the associated controls change, then the manager for the team should inform the Operations Director and/or the Commercial Directors so they can update, as required, the details in the table at the end of this policy.
Conflict of Interest Principles
In implementing our approach to identifying and managing actual/potential conflicts of interest staff are required to abide by the following principles:
- All managers and staff must buy into and commit to identifying and managing all actual/potential conflicts of interest that may affect Trained Academy and, in doing so, raise possible conflicts of interest with the Head of Quality and Standards (or if appropriate the Operations Director or Sales and Marketing Director).
- Staff must be proactive in the identification and management of conflicts of interest that may affect, for example, Trained Academy’s effectiveness, level of regulatory compliance and/or reputation.
- Staff must be open about the nature of any potential/actual conflicts of interest and not try to hide or present them in a better light – managing conflicts of interest is about preventing issues from occurring that may impact on our operational effectiveness and/or regulatory compliance
- Strive to identify and deal with conflicts of interest as soon as they are identified
- Controls for managing any potential conflicts of interest must be proportionate to the risks associated with the identified conflict(s)
Dealing with conflicts of interests and/or breaches to the procedures outlined in this policy
Where any member of staff believes there has been a breach of this policy, or if unforeseen conflicts of interest emerge, the Head of Quality and Standards will be informed and an investigation carried out immediately along with a review of the associated procedures. Such reviews will be led by the Head of Quality and Standards and the outcomes reported to the governing body.
If the breach is also classified as an Adverse Effect, then the Head of Quality and Standards will immediately inform Ofqual in accordance with our procedure for dealing with Adverse Effects. In doing so, they will inform Ofqual of the reasonable steps that have been taken or intend to take to prevent, correct or mitigate the Adverse Effect. Including details of any reviews Active IQ will carry out.
For information, the Ofqual definition of an Adverse Effect is:
An act, omission, event, incident, or circumstance has an Adverse Effect if it –
(A) Gives rise to prejudice to Learners or potential Learners.
(B) Adversely affects – (i) the ability of the awarding organisation to undertake the development, delivery or award of qualifications in accordance with its Conditions of Recognition, (ii) the standards of qualifications which the awarding organisation makes available or proposes to make available, or (iii) public confidence in qualifications.
If you have any queries about the contents of the policy, please contact the Head of Quality and Standards:
E: email firstname.lastname@example.org
T: 07968 172 602
“Trained Academy LTD declare that this is a business run by two directors but there may be occasions when family are on courses since the intention is to develop a business that they can share some of the workload in the future.” Attention will be given to the allocation of the assessor to ensure that the assessor is not related or has a close relationship in any other capacity to the learner.