Conflict of Interest Guideline of BIGD
Objective:
The objective of this guideline is to ensure that all employees of BRAC Institute of Governance and Development (BIGD), BRAC University are aware of their obligations to disclose any conflict of interest that they may have during their employment period at BIGD and to comply with this guideline to ensure that they effectively manage those conflicts of interest.
Definition of conflict of interest
Conflict of interest arises where an employee’s duty to BIGD is affected by a personal interest. In such cases, the line between personal and professional conduct may become blurred and interfere with an employee’s capacity to perform their position.
Personal interests may be financial or non-financial, and may be held in relation to:
Family members
Close friends
Associates.
Conflict of interest can not only be actual, but also potential. A potential conflict of interest is one which is foreseeable from the circumstances, but has not yet become actual (for example, where a job applicant is related to a recruitment panel member, but the applications have not yet been processed).Whether a conflict of interest (actual, or potential) exists depends on the circumstances.
Types of conflict of interest situations
There are many situations where a conflict of interest may arise. Some examples are:
a. Gifts and Entertainment: No person associated with BIGD shall accept any gift, entertainment, loan or anything else of value from any organisation or individual if it could be reasonably perceived that the gift is given with the intention to influence the employee at BIGD.
b. Family and Personal Relationships at BIGD: “Closely Related Persons” are the BIGD employee’s family members, those living in the same household as the employee or someone with whom the employee has a personal relationship. The employment of Closely Related Persons may raise questions regarding confidentiality, objectivity, fairness and integrity in work relationships.
This can negatively impact BIGD’s ability to recruit employees and can damage its reputation for ethical and fair conduct. In order to avoid conflict of interest, employees of BIGD must not:
i. Be in a supervisory, subordinate, or control relationship (e.g. having influence over conditions of employment) with Closely Related Persons; or
ii. Be involved in any hiring/retention decision regarding Closely Related Persons (including internal/external hiring, retention of external service providers/contractors and internal transfers); or
c. Inter-organizational conflict: BIGD employees should disclose any conflict of interest which may arise in the course of their work at BIGD. A conflict of interest may take various forms but arises when an employee is or may be in a position to influence BIGD’s business, research, or other decisions in ways that could lead to any form of personal gain for the employee or any Closely Related Person. For example, when BIGD partners or works with any other organization on any project, if any employee of BIGD or their Closely Related Persons are in leadership positions in the other organization, the existence of such a relationship should be disclosed to the relevant supervisor by any BIGD employee involved in that project. Justification of entering into contract with such organizations must be approved by the Executive Cluster and documented.
d. Other situations: It is not possible to list all situations that may give rise to a conflict of interest.
The situations described above are examples of common conflict of interest situations and do not represent an exhaustive list. Any other situations that may arise that involve an employee’s personal interests conflicting with the interests of BIGD should be disclosed and addressed in accordance with the general principles of this guideline.
Identification and disclosure of conflict of interest
All employees of BIGD must avoid conflict of interest or situations where their personal interest could conflict or appear to conflict with their employment duties and responsibilities.
They have a continuing responsibility for identifying, declaring and managing any actual or potential conflict of interest that applies to them.
Where an employee suspects that they may have a potential/actual conflict of interest, the employee needs to discuss any conflict of interest with their supervisor and seek guidance from the supervisor to determine if a conflict of interest exists and how to deal with it. If a potential/actual conflict of interest is identified, the employee must formally declare the conflict by using the Conflict of Interest Declaration form. Employees should provide all information on the reporting form relevant to the identified conflict of interest in order to allow the supervisor to fully assess whether a conflict of interest in fact exists. The supervisor in consultation with the Executive Cluster shall take a decision on as to the existence of any conflict and any action/steps to be taken by the employee to mitigate or remedy the conflict which shall be final and binding.
Consequences of breaching this policy
Conflicts of interest are not in themselves unethical or contrary to this policy. If an employee fails to identify (or, where required, manage/monitor) any actual/potential conflict of interest, this may result in disciplinary action or, depending on the seriousness of the circumstances, termination of employment.
Policy review
This policy will be reviewed every year to take account of any changed technology, legislation, expectations or practices.
Conflict of Interest Form
All employees of BIGD shall fill up and sign Form A (Conflict Of Interest Acknowledgement Form) and submit it to the HR Department.
In case any conflict of interest issue arises, current employees of BIGD shall fill up and sign Form B (Declaration of Conflict of Interest Form) and submit it to HR Department within 7 working days after potential conflict of interest arises or at the time the conflict of interest is identified.
Form-A (Conflict of Interest Acknowledgment Form)
I hereby acknowledge that I have read and fully understood the procedure of the Conflict of Interest Guideline of BRAC Institute of Governance and Development (BIGD), BRAC University, including the duty to disclose any known or potential conflicts which may arise during the term of my employment at BIGD. Furthermore, I agree to abide by the procedure outlined in this guideline for the duration of my employment with BIGD.
Name: __________________________________________________________
Designation: ______________________________________________________
Pin No.: __________________________________________________________
Dept.: ________________________________________________________
Signature: _______________________________________
Date: _______________________________________
Form- B (Declaration of Conflict of Interest Form)
Employee Name: ___________
Employee PIN No. __________
I __________ (name), hereby declare the following actual or potential conflict of interest:
1. Description of situation giving rise to the actual or potential conflict of interest :
2. Name of Company (s) or individual (s) involved with the actual or potential conflict of interest:
3. Nature of personal interest or involvement with company (s) or individual(s):
4. In agreement with my Supervisor, we have agreed to the following actions to be taken to mitigate the actual or potential conflict of interest :
The undersigned hereby acknowledge the above noted actual or potential conflict of interest and agrees to the above noted action to be taken to mitigate the actual or potential conflict of interest.
Signature of Employee: _________________
Signature of Supervisor: _________________
Signature of Executive Director: ____________
