Conflict of Interests

Purpose

The purpose of this policy is to protect the integrity of QURE Group Ltd decision-making process, to enable our stakeholders to have confidence in our integrity, and to protect the integrity and reputation of staff.

All Dispute Resolution Staff will strive to avoid any conflict of interest between the interests of the Organisation on the one hand, and personal, professional, and business interests on the other. This includes avoiding actual conflicts of interest as well as the perception of conflicts of interest.

Scope

Examples of conflicts of interest include:

• An employee who deals with a complaint against a firm which once employed them
• An employee who is friends (rather than just professionally amicable) or related to a firm which is the subject of a complaint
• An employee, or a staff member’s friend or family who has a financial interest in a company which is the subject of a complaint

Introduction

A conflict of interest exists when the duties owed by an individual to the firm conflict with, or may possibly conflict with a personal, financial or other interest or duty that the individual holds and/or with the interests of someone who has a close personal connection to the individual (including, but not limited to, any children, in-laws, siblings, partner or spouse).

The existence of a conflict of interest does not therefore depend on whether the individual is influenced in their duties or decisions. It arises whenever an interest could reasonably be perceived as affecting, or having the capacity to affect, an individual’s ability to make impartial decisions.

Examples of a conflict of interest (but not limited to) include:

• Nepotism
  Nepotism is when someone hires, promotes or otherwise provides special treatment in the workplace to a family member or close friend. Nepotism is a conflict of interest because the family member or friend may receive job perks they don’t necessarily qualify for. To prevent this from occurring, employees and managers can disclose the relationship and not to be a part of hiring for that individual or role.

• Self-dealing
  Self-dealing is happening when an individual in a financial role at an organisation uses their knowledge of company finances or their access to funds to benefit themselves over the objectives of the business. To avoid this conflict of interest, individuals can choose to remain neutral and act how they would without the knowledge they possess.

• Gift issuance
  Gift issuance is another conflict of interest that occurs when someone at a company accepts gifts/hospitality from a client, supplier or another person they have a business relationship with.

• Insider trading
  Insider trading is when an individual has access to confidential information and uses that knowledge to further themselves or others they know. An individual can avoid insider trading by continuing to act ethically and without bias or removing themselves from the role if they feel too strong of a temptation to act out of order.

Disclosures

We review and consider our business practices to identify any possible conflicts of interest which might exist.

Colleagues undergo training to know what a conflict is, our processes surrounding this, such as disclosing relationships and potential conflicts.

Conflicts of interest will occur at some time. In some situations, simply disclosing and recording the interest may be the only necessary action. When a conflict arises, we will deal with the situation appropriately and look to manage and potentially mitigate any risks. A log of all conflicts of interest will be retained, including the actions taken to control or mitigate these.

Examples of actions that can be taken to mitigate the conflict include (but are not limited to)

• ‘Declarations of interest’ is a standing item at the beginning of every Committee meeting, so that attendees can declare any conflicts of interest in relation to that specific agenda. The Chair will decide on the course of action for managing each conflict. Both the declarations and any mitigating actions should be minuted.
• Not taking part in decisions relating to certain matters but still being present for any preceding discussion.
• Referring decision-making on certain matters to others.
• Not to act as a particular person’s supervisor.
• Standing aside from any involvement in a particular project.
• Keeping a Gifts and Hospitality Register.

Alternative Dispute Resolution (ADR) Official Conflicts

The purpose of this policy is to protect the integrity of the decision-making process, to enable our stakeholders to have confidence in our integrity, and to protect the integrity and reputation of staff.

All ADR Officials employed by QURE Group are required to recognise and disclose in writing any matter of which they are aware or become aware at any time, that could be regarded as being or creating a conflict of interest (whether actual, perceived, or potential) in relation to a particular dispute or any of the parties involved in the process. Upon disclosure, the ADR Official must not act or continue to act in relation to that dispute.

There is no definitive list of situations where an ADR Official must identify and disclose a conflict of interest. However, some common examples of this include the following:

• Any personal relationship that the ADR Official has with any of the parties.
• The ADR Official has acted (either personally or through a firm or business) in any capacity other than as a neutral in another process for any of the parties.
• The ADR Official being in prior possession of any confidential information about any of the parties or the subject matter of the dispute; and
• Any of the above matters involving a close member of the ADR Official’s family.

Where an ADR Official has a conflict of interest, they will cease their involvement in the dispute, and QURE Group will appoint an alternative ADR Official to resolve the dispute. If no alternative ADR Official is available, QURE Group will contact both parties to the dispute and advise them of the situation and discuss that an alternative ADR business must be sought to handle the dispute.