Conflicts of interest policy

Scope

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

Responsibility

All staff and non-executive members of The Housing Ombudsman (THO) will avoid any conflict of interest between the interests of THO on the one hand, and personal, professional, and business interests on the other. This applies where a conflict may be perceived as well as where one definitively exists and all such instances must be recorded for transparency. Examples of conflict of interests include:

1. A colleague or non-executive member who holds a public office elsewhere in an organisation that may interact with THO.
2. A colleague who is participating in a decision to award a contract and has shares in one or more of the businesses under consideration, or is a director, partner or employee or related to someone who is*.
3. A colleague who is dealing with a complaint about their current landlord, a previous landlord from within the last three years or from an individual personally known to them.

We do not expect that non-executive members will have conflicts due to their employment by a Scheme member/ customer representative group, or by being a resident of a Scheme member, as non-executives will not consider individual complaints and their role is purely advisory. However, to support transparency, all such interests must be recorded and must be declared at the start of each meeting.

Identification, recording and reviewing

Upon appointment and whenever there is a change, each colleague or non-executive member will make a full, written disclosure of their interests, including all private, personal (such as relationships, and posts held, that could potentially result in a conflict of interest) and financial interests relevant to decision-making, the management of contracts, complaint handling and giving policy advice.

An annual reconfirmation of the disclosures and register of interests will be led by the Project, Programme and Governance Lead to ensure these remain up to date and to identify areas of potential conflict for management.

Declarations of gifts and other benefits should be separately recorded as and when received.

Conflict management

During all meetings or activities, colleagues and non-executive members will disclose any interests in a transaction or decision.

After disclosure, the colleagues or non-executive member may be asked to leave the room for the discussion by the Chair and, if so, will not be able to take part in the decision or any further discussions related to the matter.

Any such disclosure and the subsequent actions taken will be noted in the minutes.

Colleagues who are tenants of member landlords, or have been in the last three years, should declare this and bring to the attention of their line manager to ensure they are not allocated cases from these members. The line manager should counter-sign the declaration to confirm they are aware of the declaration.

Where colleagues have a personal relationship with a complainant who has raised a complaint that is allocated to them, they should inform their line manager immediately, who will reallocate the case.

Additional mechanisms may be put in place to ensure possible conflicts are appropriately managed. This may include internal audit reviews or social media checks. These will be overseen by the Director of Finance and Corporate Performance and managed by the Project, Programme and Governance Lead.

Whistleblowing arrangements are in place to address concerns where an activity that is deemed illegal or unethical exists.

This policy is meant to supplement good judgment; colleagues and non-executive members should respect its spirit as well as its wording.

* A relative may be a child, parent, grandchild, grandparent, brother, sister, spouse or civil partner of the committee member or any person living with the committee member as his or her partner.