Conflict of Interest Policy

This policy applies to Board and committee members, staff, volunteers, interns, consultants, suppliers, implementing partners and any person involved in AFRDA decision-making, procurement, recruitment, financial approval, programme selection, partnership management or representation.

A conflict of interest exists where a private interest, family or personal relationship, financial interest, outside role, loyalty or other external consideration could influence - or reasonably appear to influence - a person’s ability to act objectively for AFRDA.

• Actual conflict: the person’s private interest directly affects a current decision or duty.
• Potential conflict: circumstances could develop into a conflict.
• Perceived conflict: a reasonable observer could believe judgement may be influenced, even if no improper influence occurs.
• Institutional conflict: an AFRDA funding, partnership or organisational relationship could compromise independence or public trust.

• A decision-maker is involved in awarding work to a company owned by a relative, close friend or business associate.
• A recruitment panel member assesses an applicant with whom they have a personal relationship.
• A representative uses confidential information, AFRDA’s name or community contacts for private business or political benefit.
• A consultant helps design an assignment and later competes for it without independent safeguards.
• A partner or supplier seeks preferential treatment through a personal relationship with AFRDA leadership.
• A person accepts gifts, hospitality, commissions, discounts or favours connected to an AFRDA decision.
• An outside role or loyalty conflicts with AFRDA’s donor, programme or public-interest obligations.

• Conflicts must be disclosed promptly, including where a person is uncertain whether a conflict exists.
• Board members and senior personnel complete periodic declarations, and participants in procurement, recruitment, partnership and financial decisions declare relevant interests before taking part.
• A conflicted person must not influence the decision while AFRDA determines the appropriate control.
• Management options may include recording the interest, limiting access to information, recusal from discussion or voting, removal from evaluation or supervision, independent review, additional approval, retendering, rejection of a transaction or termination of an arrangement.
• AFRDA maintains confidential records of declarations and management decisions. Individual declarations are not published unless disclosure is required or appropriately authorised.

• Cash, cash equivalents, commissions, loans, secret benefits or personal favours connected to AFRDA decisions are prohibited.
• A modest, infrequent and culturally appropriate token may be accepted only when lawful, not linked to a decision and unlikely to create an obligation or appearance of influence.
• Excessive, repeated, secret or procurement-related hospitality must be refused and reported.
• AFRDA representatives must never request a gift or benefit from a community member, applicant, supplier, partner or beneficiary.

Relatives and close associates of AFRDA representatives are not automatically excluded from legitimate opportunities. They must compete through a fair and documented process, and the related AFRDA representative must not participate in selection, approval, supervision, evaluation or payment. Higher-risk related-party arrangements require independent scrutiny and may be rejected where the conflict cannot be adequately managed.

Suppliers, applicants and partners should disclose any relationship or interest that could affect an AFRDA decision. Attempting to conceal a relationship, influence a decision improperly, create false competition or offer an inducement may result in disqualification, contract action, reporting to a donor or authority, or other appropriate measures.

Reports may be made confidentially or anonymously. AFRDA protects genuine reporters from retaliation and restricts access to declarations and related records. A person who has a conflict should disclose it rather than attempt to decide alone whether it is harmless.

Failure to disclose a conflict, misuse of position or acceptance of an improper benefit may result in removal from a decision, disqualification, contract remedies, disciplinary action, recovery of losses, termination or referral to a competent authority. AFRDA reviews this policy and its controls regularly to protect fairness and public trust.