Conflict of Interest Policy

1. PURPOSE

All Members of Anglican Preschool Services Ltd. (“APS”) have the obligation to act in its best interest. There should be no vested or personal interest or interest of third party. Members should therefore avoid situations whereby a member’s personal interest or interest of a third party, whether real, potential or perceived, conflicts with that of APS.

Such conflicts may create problems that may result in the following:

a. Cause damage to APS’s reputation which may lead it its inability to sustain operations;
b. Influence the Members’ judgement and compromise objectivity when conducting APS’s affairs;
c. Restrict free discussion, thus resulting in decisions or actions that are not in the interest of APS; and
d. Risk the impression that APS has acted improperly.

This Policy aims to protect both APS and its members from any impropriety or appearance of impropriety.

2. PRINCIPLES

a. APS’s vision, mission & values rather than for personal gain must be upheld at all times.
b. Where conflicts of Interest are inevitable, the affected party/parties must declare such Interest(s) as soon as possible, and refrain from discussion and decision-making on the matter.
c. Member’s respective roles shall be clearly differentiated so as to safeguard the independence of decisions and to avoid possible conflict of interest which may otherwise arise.

3. DEFINITIONS

“Board” means Board of Directors of APS.

“Board Committee” means any committee of the Board as the Board may constitute from time to time and at any time.

“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;
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 not include an expectation of financial gain; and
d. “Deemed interest” – a Member is deemed to have an interest which his/her spouse/domestic partner holds an interest.

“Member” means any of the following as the context requires:

a. members of APS;
b. directors of APS;
c. members of Board Committees and Other Committees;
d. employees; and
e. volunteers.

“Other Committees” means any other committees that APS or the Board may establish pursuant to any direction of any government agency or authority.

“Policy” means this Conflict of Interest Policy.

4. CONFLICT OF INTEREST SITUATIONS

A conflict of interest arises when the personal interests of the Member may potentially interfere with the performance of his/her duties in APS. When actual, potential or perceived conflict of Interest arises, the integrity, fairness and accountability of the Member may be affected, which could impede the best interest of APS.

Each situation will be assessed on its own facts to determine if the Interest in question will give rise to a potential conflict. While it is not possible to enumerate all situations which would constitute a conflict, below are some instances for your guidance:

a. Additional paid employment
Where any Employee of APS has other paid employment or engage in any trade or business or any remunerative economic activity of any kind whatsoever or hold any office or position of profit.

b. Contract with Vendors
Where any Member has a personal or financial Interest in any business transaction or contract that APS may enter into.

c. Interest in other organisation that have dealings/relationships with APS
Where any Member has an Interest in any organisation that has dealings or a relationship or is associated with APS.

d. Close relationship with Employees of APS
Where an employee is a family member or has close affiliation with a Member or any recruitment of employees who is a family member or who has close affiliation with a Member.

e. Receipt of Gifts and Services
Where any Member receives a gift or services from any organisation that has dealings or relationship or is associated with APS.

f. Remuneration and other payments
Payment in cash or in kind to any Member by any organisation that has dealings or a relationship or is associated with APS. For avoidance of doubt, members of the Board and its Board Committees, Other Committees and volunteers shall not receive any remuneration from APS.

g. Employees serving as members of the Board Employees of APS shall not serve as a member of the Board or Board Committees or Other Committees as it can give rise to issues of conflict of Interest and role conflicts.

The above list is not exhaustive. In any other situations or matters where an actual, potential or perceived conflict of Interest is or may be encountered, Members should adhere to the general principles set out in this Policy.

5. DECLARATION OF INTEREST

Given the stated purpose of this Policy, we are asking all Members to declare their interests, and any gifts or hospitality received in connection with their role in APS, and to declare when any transactions of APS to be effected may result in a conflict of interest, using the Conflict of Interest Disclosure Form annexed to this Policy (hardcopy submission or online via the QR code).

To be effective, the Conflict of Interest Disclosure Form needs to be updated at least once every two years and also when any changes occur.

In situations where Members are not sure what to declare, or whether/when the declaration needs to be updated, they should err on the side of caution or seek advice from the Board/Senior Leadership team/Reporting Officer.

All disclosure of Interest made by Members and decisions made by the Board/Senior Leadership Team on such matters must be recorded, updated and filed with the head of Human Resource Department (or his designee).

A register of interests shall also be used to record all gifts of a market value over S$5,000 received by Members.

6. OPERATING PROCEDURES

If the Board needs to make a decision on an issue where a Board member(s) has/have an interest, it is the responsibility of the Board member(s) to:

a. Identify the potential conflict of interest;
b. Not participate in discussion of the programme or motion being considered; and
c. Not vote on the issue.

If the Board needs to make a decision on an issue where a Board member(s) has/have an interest, it is the responsibility of the Board to ensure that:

a. All decisions are made by vote, with simple majority required based on the presence of a quorum; and
b. Interested Board member must not vote on matters affecting their own interests.

If the Senior Leadership Team needs to make a decision on an issue where a Senior Leadership Team member(s)/Employee has/have an interest, it is the responsibility of the Senior Leadership Team member(s) to:

d. Identify the potential conflict of interest;
e. Not participate in discussion of the programme or motion being considered; and
f. Not vote on the issue.

It is the responsibility of the Board/Senior Leadership Team 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 decision shall not be influenced in any way by the fact that a Member has an interest in the contract.
b. Records in the minutes of meeting to potential conflict of Interest, and the use of the procedures in this policy and criteria of selection.

It is the sole responsibility of any Member of APS to report any possible real, potential or perceived conflict of interest. If it is an oversight from APS, the Member shall promptly inform the Board/Senior Leadership Team that he/she has been put in such a position of conflict of Interest.

No Member of APS shall derive any personal profit or gain, directly or indirectly, by reason of his or her participation with APS. The Member shall disclose to APS any personal interest which he/she may have in any matter pending before APS and shall refrain from participation in any decision on such matter.

Any Member of APS or of a client organisation or vendor of APS shall identify his/her affiliation with such agency/agencies; further, he/she shall not participate in the decision affecting that agency.

Any Member of APS 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.

Any Member who is also a user of APS’s services, or the carer of someone who uses APS’s services shall not be involved in decisions that directly affect the service received 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).

A Member of APS may, however, participate in discussions from which he/she may indirectly benefit, for example where the benefits are universal to all users of APS’s services.

The Board/Senior Leadership Team shall have the right to suspend any involvement of any Member 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.

7. VIOLATIONS

Any violation will result in discipline, up to and including termination from employment or removal from the Board, or expulsion from being a volunteer member of APS.