XX innovation recognises that conflicts of interest can arise in the normal course of business. What matters is how they are identified, declared, and managed. This policy sets out our approach to handling actual, potential, and perceived conflicts of interest in a transparent and accountable way.
What is a conflict of interest?
A conflict of interest arises when a personal interest, loyalty, or relationship could influence – or could reasonably be perceived to influence – a person’s judgement or decision-making on behalf of XX innovation. This includes financial interests, personal relationships, employment or consultancy relationships with other organisations, and any other situation where impartiality could reasonably be questioned.
How we manage conflicts
All directors and individuals acting on behalf of XX innovation are required to declare any relevant interests at the earliest opportunity. Declarations are recorded in a register of interests, which is maintained and reviewed regularly. Where a conflict is identified, the individual concerned will be excluded from the relevant discussion and decision. Decisions taken in the context of a declared conflict are recorded in meeting minutes, including the steps taken to manage the conflict.
This policy was adopted by the board of XX innovation Ltd in [June, 2026] and is due for review in [June, 2027].