Conflicts of Interest Policy and Register

A full policy for identifying, recording and managing trustee conflicts of interest and loyalty, with registers of conflicts, trustee payments and gifts.

Editable Word document
11
10pages
Guidance notes included
aml consultancy solutions

Charities

Conflicts of Interest Policy and Register

About this document

What it’s for

A policy that explains how the charity’s trustees (and senior staff) identify, declare, record and manage conflicts of interest and conflicts of loyalty, including the rules for paying trustees or connected persons. It comes with an annual declaration and three registers: declared conflicts, trustee payments and benefits, and gifts and hospitality.

When to use it

  • Adopt it when the charity is set up and review it every year
  • Use the registers at every board meeting
  • Refer to it whenever the charity might contract with, pay or benefit a trustee or someone connected to them

What’s inside

The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.

  1. Purpose
  2. Scope
  3. Definitions
  4. Legal background
  5. Roles and responsibilities
  6. Identifying and declaring interests
  7. Managing conflicts
  8. Payments and benefits to trustees and connected persons
  9. Gifts and hospitality
  10. Staff and volunteers
  11. Records
  12. Breaches of this policy
  13. Training, monitoring and review
  14. Related documents

Also included

  • Schedule 4 – Register of gifts and hospitality

How to complete it

  • Insert the charity’s name and the gifts threshold in clause 9
  • Check clause 8 against the trustee benefit clause in your governing document
  • Adopt it at a board meeting and record the minute reference in the document control table
  • Ask each trustee to complete the Register of Interests form in this pack

Key points to check

  • The Charity Commission’s guidance CC29 was updated in April 2026 – check it before you adopt the policy
  • Paying a trustee without proper authority is a breach of trust and may have to be repaid

Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.

Included in the pack

Charities

£20

for every document in this category

Editable Microsoft Word files

Guidance notes in every document

Written for UK businesses

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