Declarations Of Interest

1. Introduction
1.1. This policy applies to the GBWR group (GBWR), presently Great Britain Wheelchair Rugby Limited (the ‘Parent’) and its subsidiary GBWR Trading Limited; the policy will also apply equally to any additional subsidiary(ies) which may form part of the GBWR group from time to time
1.2. GBWR funding comes principally from grants, sponsorship, and charitable donations (where charitable donations are received only by the Parent) for the sole purpose of meeting the Parent’s charitable objects. It is essential that all funds are used wisely and that GBWR is able to demonstrate good governance to its donors, partners, and members. This paper sets out the process for ensuring that all income is applied in accordance with the conditions or stipulations attached thereto, and that all expenditure is appropriately authorised and effectively controlled.
1.3. GBWR’s directors (‘Directors’, who may interchangeably be referred to as trustees when referring to the Parent) have a legal obligation to act at all times in the best interests of GBWR and in accordance with the articles of association (as amended from time to time). GBWR employees, workers, consultants, and volunteers (collectively, ‘Workers’) have similar obligations.
1.4. A conflict of interest (‘Conflict’) may arise where an individual’s personal, professional, or family interests (‘Interests’) could potentially conflict with those of GBWR.
1.5. Such Conflicts may create problems as they can:
• inhibit free discussion;
• result in decisions or actions that are not solely in the interests of GBWR; and/or
• risk the impression that GBWR has acted improperly.
1.6. The aim of this policy is to protect both GBWR and the individuals involved from any actual or perceived impropriety.

2. Declarations of interests and the register of interests
2.1. Accordingly, GBWR asks Directors and Workers to provide declarations of interests (‘Declarations’) prior to any relevant discussion or decision-making; although other instances will apply, this can include occasions involving contracting suppliers or during recruitment processes.
2.2. A form for Declarations is provided for Directors to list the types of Interest to be declared, however Directors should be alert to other potential Conflicts as they arise, which may not be categorised Interests on the provided form. See the anti-bribery and corruption policy for further details on disclosing gifts or hospitality.
2.3. To be effective, Directors must update their Declarations annually and also when any changes occur; an opportunity for Directors to declare any new Interests is provided at each board meeting also. The responsibility to declare all new Interests at the earliest opportunity is with each individual Director.
2.4. If you are not sure what to declare, or whether/when your Declarations need to be updated, please err on the side of caution. If you would like to discuss this issue, please contact the CEO or CFOO for confidential guidance.
2.5. Directors’ Interests will be recorded on a register of interests (‘Register’) for each company in the GBWR group, which will be maintained by the board secretary (as that role is fulfilled from time to time by each company).
2.6. The Registers will be accessible by the Directors of each company in the GBWR group and all Registers will be accessible by the group chair, CEO, and CFOO.

3. Data protection
3.1. The information provided will be processed in accordance with all applicable data protection laws as they may be amended from time to time.
3.2. Directors and Workers should see the personnel policy on data protection for further information.
3.3. Data will be processed only to ensure that Directors and Workers act in the best interests of GBWR: the information provided will not be used for any other purpose.

4. What to do if you face a conflict of interest
4.1. If you are a Director or Worker with GBWR you should not be involved in decisions where a Conflict exists and the outcome of the decision directly affects you, or any person or body identified within the Interest.
4.2. You should declare your Interest at the earliest opportunity and withdraw from any subsequent decision making; you may participate in discussion where your expertise or knowledge provides particular insight which the discussion and decision making would be disadvantaged without.
4.3. You may also participate in discussions from which you may indirectly benefit, for example, where the benefit is received universally by a wider category of individuals (eg, a Director or Worker who also holds a club committee role may participate in discussions which benefit all GBWR members universally), or where the benefit to you (or any person or body identified within the Interest) is immaterial. Nevertheless, you should declare your Interest before such discussion commences.
4.4. If you fail to declare an Interest that is known to the chair of the company (or chair of any relevant meeting) and/or the CEO, one of them will make that Interest known on your behalf.

5. Decisions taken where a Director or Worker has a potential Conflict and the chair’s role in managing Conflicts
5.1. In the event of the board being made aware of a potential Conflict, the chair will decide (according to the criteria at 4.2 and 4.3) if the conflicted party should be absent from the discussion and, where the potential Conflict is raised in advance, be excluded from distribution of applicable meeting papers. The conflicted party may also voluntarily absent themselves from conflicted discussions/agenda items.
5.2. Where a member of the board disagrees with the chair’s decision on exclusion of a potentially conflicted party, agreement will be reached by simple voting majority where the conflicted party is not entitled to vote, and the chair will hold the deciding vote in any instance of a tie.
5.3. Where the conflicted party disagrees that they are conflicted, the chair will lead a discussion with board members to agree if the conflict warrants exclusion; agreement will be reached by simple voting majority where the conflicted party is not entitled to vote, and the chair will hold the deciding vote in any instance of a tie.
5.4. In any case where the chair is the conflicted party, the role of the chair will be fulfilled by the senior independent director.
5.5. In the event of the board having to decide upon a question in which an absent Director or Worker has a potential Conflict, all decisions will be made by vote, with a simple majority required.
5.6. A quorum must be present for the discussion and decision; interested parties will not be counted when deciding whether the meeting is quorate.
5.7. Directors or Workers may not vote on matters affecting their own Interests and they must absent themselves from the discussion, except where the exceptions at 4.2. and 4.3 are applied.
5.8. All decisions under a potential Conflict will be recorded by the board secretary (as that role is fulfilled from time to time by each company) and reported in the minutes of the meeting. The report will record:
• the nature and extent of the potential Conflict;
• an outline of the discussion; and
• the actions taken to manage the potential Conflict.
5.9. Where a Director benefits from the decision to a material level (see clause 4.3), this will be reported in the group accounts and annual report in accordance with the current Charities Statement of Recommended Practice (SORP).
5.10. All payments or benefits in kind to directors will be reported in the group accounts and annual report, with amounts for each director listed for the year in question.
5.11. Where a Worker is connected to a party involved in the supply of a service or product to the charity, this information will also be fully disclosed in the group accounts and annual report.
5.12. Independent external moderation will be used where Conflicts cannot be resolved through the usual procedures.

6. Managing contracts
6.1. If you have a Conflict, you must not solely be involved in managing or monitoring a contract in which you have an interest.
6.2. Monitoring arrangements for such contracts will require provisions for an independent challenge of bills and invoices, and termination of the contract if the relationship is unsatisfactory.
6.3. For further information see:
• the Charity Commission’s publications CC11: Trustee expenses and payments, CC3: The essential director: what you need to know, what you need to do, and CC29: Conflicts of interest: a guide for charity directors; and
• the Chartered Governance Institute UK & Ireland’s publication: Managing conflicts of interest in a charity (England and Wales).

V013 approved by the GBWR Board of Trustees at the meeting held March 2025
To be reviewed by the GBWR Board of Trustees March 2027