Conflict Of Interest Policy
Untitled Document



1. Purpose
1.1 As members of the Management Committee and Staff of the Association, which is a Charity, we have an obligation to act in its best interest. Hence, we need to avoid situations where there may be real, potential or perceived conflicts of interest, which may arise where a member’s personal or family interest conflicts with those of the Charity.
1.2 Such conflicts may create problems that may result in the following:
a. Cause damage to the Charity’s reputation which may lead to its inability to sustain operations;
b. Influence the members’ judgment and compromise objectivity when conducting the Charity’s affairs;
c. Restrict free discussion, thus resulting in decisions or actions that are not in the interests of the Charity; and
d. Risk the impression that the Charity has acted improperly.
1.3 This Policy aims to protect both the Charity and its members from any appearance of impropriety.
2. Definitions
2.1 “Charity” refers to the Securities Investors Association (Singapore) (SIAS) as the issuer of this document.
2.2 “Member” refers to a Management Committee member or management member or staff member or volunteer member of the charity.
2.3 “Policy” refers to the Conflict of Interest Policy.
2.4 “Interest means any commitment, investment, relationship, obligation, or involvement, financial or otherwise that may influence a person’s judgement. This would include:
a. Direct interest – ownership in the name of the member/staff;
b. Indirect interest – ownership beneficially held through another investment,estate, trust or other intermediary;
c. Vested interest – personal stake or involvement, which may or may notinclude an expectation of financial gain; and
d. Deemed interest – a member/staff is deemed to have an interest which his/herspouse/domestic partner holds an interest
2.5 A conflict of interest arises when the personal interests of the member/staff may potentially interfere with the performance of his/her duties in the charity. When actual, potential or perceived conflict of interest arises, the integrity, fairness and accountability of the person may be affected, which could impede the best interest of the charity.
3. Declaration of Interests
3.1 Given the stated purpose of this Policy, we are asking:
a. Management Committee and management members to declare their interests, and any gifts or hospitality received in connection with their role in the Charity; and
b. staff and volunteer members to declare when the transaction to be effected may result in a conflict of interest.
3.2 A declaration of interests form is provided for this purpose. The types of interest to be declared will include, but not limited to the following:
a. Members who have friends or other personal or business relationships must carefully consider whether those relationships create conflicts of interest with their entrusted role in the Charity. Examples include:
i. hiring a relative or friend as an employee or vendor,
ii. buying or selling goods or services from / to a family business for which others might compete,
iii. having a personal relationship where there is an immediate reporting relationship,
iv. volunteering and/or having memberships in any other charities, or
v. receiving goods/services as beneficiaries.
b. Members must disclose any outside activities, financial interest or relationship that may pose a real, potential or perceived conflict of interest. Disclosures are to be made to the Management Committee/senior management/supervisors and head of the Human Resources Department, with the required approval obtained before accepting any position as an officer or director of an outside business.
3.3 To be effective, the declaration of interests needs to be updated in written form at least annually and also when any changes occur.
3.4 In situations where members are not sure what to declare, or whether/when your declaration needs to be updated, they are strongly encouraged to err on the side of caution or seek advice from the Management Committee/ senior management/supervisors.
3.5 All disclosure of interest made by members and decisions made by the Management Committee/senior management of the charity on such matters must be recorded, updated and filed with the head of the Human Resources Department (or his designee).
4. Declaration of Interests
4.1 If the Management Committee needs to make a decision on an issue where the Management Committee member(s) has/have an interest , it is the responsibility of the Management Committee member(s) to:
a. Identify the potential conflict of interest;
b. Not participate in discussion of the program or motion being considered; and
c. Not vote on the issue.
4.2 If the Management Committee needs to make a decision on an issue where the Management Committee member(s) has/have an interest, it is the responsibility of the Management Committee to ensure that:
a. All decisions are made by vote, with a two-thirds majority required based on the presence of a quorum; and
b. Interested board members must not vote on matters affecting their own interests.
4.3 It is the responsibility of the Management Committee to:
a. Only decide to hire or contract with any vendor if they are the best qualified individuals available, and willing to provide the goods or services needed at the best price. The Management Committee’s decision shall not be influenced in any way by the fact that a Management Committee member has an interest in the contract.
b. Record in the minutes of the Management Committee Meeting the potential conflict of interest, and the use of the procedures and criteria of this policy.
4.4 It is the sole responsibility of any member of the Charity to report any possible real, potential or perceived conflict of interest. If it is an oversight of the Charity, the member shall promptly inform the Charity that he has been put in such a position of conflict of interest.
4.5 No member of the Charity shall derive any personal profit or gain, directly or indirectly, by reason of his or her participation with the Charity. Each individual shall disclose to the Charity any personal interest which he or she may have in any matter pending before the organisation and shall refrain from participation in any decision on such matter.
4.6 Any member of the Charity or of a client organisation or vendor of the Charity shall identify his or her affiliation with such agency or agencies; further, he shall not participate in the decision affecting that agency.
4.7 Any member of the Charity or its Consultants / Business Partners shall refrain from obtaining any list of clients for personal or private solicitation purposes at any time during the term of their affiliation.
4.8 Any member who is also a user of the Charity’s services, or the carer of someone who uses the charity’s services shall not be involved in decisions that directly affect the service received by the person he / she cares for. He / She shall declare his / her interest at the earliest opportunity and withdraw from any subsequent discussion. The same applies if the conflict concerns any other reason(s).
4.9 A member of the Charity may, however, participate in discussions from which he / she may indirectly benefit, for example where the benefits are universal to all users.
4.10 The Management Committee of the charity shall have the right to suspend any involvement of any member/staff when it has come to their attention that a potential actual or perceived conflict has arose, but has not been voluntarily disclosed by the relevant member.
5. Violations
5.1 Any violation will result in discipline, up to and including termination from employment or removal from the Management Committee, or expulsion from being a volunteer member of the charity.