Conflicts of Interest Policy

1. Purpose and Scope

1.1 Purpose

This policy establishes Qualitect Ltd's approach to identifying, declaring and managing conflicts of interest. The integrity of the platform and the services Qualitect provides depends on ensuring that no personal, financial or professional interest improperly influences Qualitect's work, decisions or outputs. Qualitect seeks to avoid conflicts of interest wherever reasonably practicable. Where avoidance is not possible, conflicts are declared, assessed, documented and managed transparently. This policy governs how Qualitect identifies, declares and manages conflicts of interest within its own organisation. Our approach is consistent with the requirements of ISO 9001 for defined organisational roles and responsibilities and with ISO 27001 for the segregation of conflicting duties. Qualitect is working towards formal accreditation against ISO standards relevant to its operations. References to ISO alignment describe the framework adopted and do not indicate current certification.

1.2 Scope

This policy applies to all directors, staff, contractors and anyone else acting on behalf of Qualitect whenever they carry out work for Qualitect, including platform development, content review, customer support and commercial activity. Platform Users remain responsible for identifying and managing conflicts of interest within their own organisations.

2. Definitions

Conflict of interest means any situation where a person's personal, financial or professional interests could improperly influence, or could reasonably be perceived to influence, their judgement or actions in carrying out their role.

An actual conflict exists where an interest is currently influencing, or could currently influence, a person's judgement or actions. A potential conflict exists where an interest could give rise to a conflict if a foreseeable event occurs. A perceived conflict exists where a reasonable third party could conclude that an interest might influence a person's judgement or actions, whether or not it does.

Declaration means notifying the appropriate person under Section 4 of an actual, potential or perceived conflict of interest.

3. What is a Conflict of Interest

Examples relevant to Qualitect's work include:

Financial: a personal or family financial interest in an organisation that benefits from Qualitect's services, decisions or generated content.

Personal or relational: reviewing or approving work produced by a close colleague, family member or business associate, for example an author also acting as the independent reviewer of their own work.

Professional or commercial: work that favours a particular product, service or organisation in which the person has an interest.

4. Declaration and Reporting

Anyone within the scope of this policy who identifies an actual, potential or perceived conflict of interest must declare it as soon as they become aware of it and before participating further in the affected work. Staff and contractors declare to the Compliance and Accreditation Lead. The Compliance and Accreditation Lead declares to the Chief Executive Officer. The Chief Executive Officer declares to the Compliance and Accreditation Lead. All declarations are recorded by the Compliance and Accreditation Lead in the Conflict of Interest Register. Anyone outside Qualitect who has a concern about a potential conflict of interest involving Qualitect may raise it through the Complaints Procedure.

5. Management and Mitigation

Once declared, a conflict is managed proportionately, for example by reassigning the affected work to a person with no interest, ensuring the author and the approver are different people, requiring independent review or oversight, excluding the conflicted person from the relevant decision or documenting the agreed mitigation and rationale where the conflict is minor and manageable.

6. Gifts and Hospitality

Anyone within the scope of this policy must declare any gift or hospitality offered or received in connection with Qualitect's work with a value above £50, whether as a single gift or hospitality event or cumulatively from the same source within any rolling twelve-month period, to the Compliance and Accreditation Lead. Declarations are recorded whether or not the gift or hospitality is accepted. Gifts or hospitality that could reasonably be perceived to influence a decision must be declined.

7. Records

Declarations made under this policy and their agreed mitigations are recorded in the Conflict of Interest Register, maintained by the Compliance and Accreditation Lead. Declarations are handled confidentially and shared only with those who need the information to assess or manage the conflict. Records are retained for a minimum of seven years unless a longer period is required by law or contractual obligation.

8. Breach

Failure to declare a known conflict of interest may be treated as malpractice and handled under the Malpractice and Misuse Policy.

9. Review

This policy is reviewed at least annually, or sooner following any significant incident or material change to Qualitect's operations.

10. Roles and Responsibilities

The Compliance and Accreditation Lead has day-to-day responsibility for this policy, receives declarations and maintains the Conflict of Interest Register. The Chief Executive Officer approves this policy and receives declarations made by the Compliance and Accreditation Lead.

11. Related Policies

Malpractice and Misuse Policy, Complaints Procedure, Data Protection Policy, Information Security Policy.

12. Contact Information

Email: hello@qualitect.co.uk
Registered office: Qualitect Limited, 32 Willoughby Road, London, N8 0JG
Trading address: 8a Stafford Street, London, W1S 4RU
Website: qualitect.co.uk