Conflict of Interest Policy

Company No. 16143537 | 50 St. Clements Road, Nechells, Birmingham, B7 5AF

Apex Up CIC Conflict of Interest Policy 

1 Policy statement 

As a community interest company, Apex Up CIC must always act in the best interests of the  community we serve. This policy helps our directors, staff and volunteers recognise and  manage situations where their personal interests could conflict, or appear to conflict, with the  interests of the organisation. It reflects the duties set out in our Articles of Association. 

2 Purpose and scope 

This policy explains what a conflict of interest is, how to declare one, and how we manage it.  It applies to all directors, staff and volunteers, and to anyone involved in our decisions,  contracts or spending. 

3 What is a conflict of interest 

A conflict of interest arises where someone’s personal, family, financial or other interests could  influence — or could reasonably appear to influence — a decision they take on behalf of Apex  Up CIC. Examples include having a financial interest in a supplier we use, being related to  someone we employ or fund, or holding a role in another organisation we work with. 

4 Declaring an interest 

Everyone has a duty to declare any actual or potential conflict of interest as soon as they  become aware of it, whether personal or by virtue of a duty to another organisation. Directors  must declare the nature and extent of any interest in a proposed transaction or arrangement  before it is discussed. 

5 Managing a conflict 

Where a director has a conflict of interest in a matter, they will, in line with our Articles,  withdraw from the relevant part of the meeting, not count towards the quorum for that item,  and not vote on it, unless the other directors formally authorise otherwise. The Board records  how each conflict is managed and may set conditions to protect the organisation’s interests. 

6 Register of interests, gifts and hospitality 

We keep a register of directors’ interests, which is reviewed at least once a year and updated  as interests change. We only accept modest, reasonable gifts or hospitality, and anything  beyond token value is declared and recorded, so that no one’s judgement is, or appears to  be, influenced. 

7 Breaches and review 

Failing to declare a conflict of interest is a serious matter and may be dealt with under our  disciplinary or volunteer procedures, or, for directors, under company law. This policy links to  our Financial governance and Whistleblowing arrangements and is reviewed at least annually.

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Apex Up CIC Conflict of Interest Policy 

Approval and adoption 

This Conflict of Interest Policy has been approved and adopted by the Board of Directors of  Apex Up CIC. It will be reviewed at least every twelve months, and sooner if there is a change  in legislation, national or local guidance, or following any relevant incident or learning. 

Signed on behalf of the Board of Directors of Apex Up CIC: 

Muhammed Zahir 

Director, Apex Up CIC 

Date: 4 June 2026