CSS LLC

CONFLICT OF INTEREST POLICY

Purpose

CSS LLC is committed to conducting business and delivering services in a fair, transparent, accountable and impartial manner. This Conflict of Interest Policy deals with situations in which our employees may have an actual, perceived or potential conflict of interest between their public role and their personal interests.

The purpose of this policy is to set out a framework for employees and relevant persons to identify, disclose, manage and monitor conflicts of interest.

Key concepts and definitions

A conflict of interest arises from a conflict between the performance of a public duty and a private or personal interest.

A personal interest includes the private, professional or business interests of a person, or of the individuals or groups with whom they have a close association, such as relatives, friends or even enemies.

A conflict of interest may be actual, perceived or potential.

·       Actual: an actual conflict of interest occurs when there is a conflict between a person’s official duties and responsibilities in serving the public interest, and their personal interest.

·       Perceived: a perceived conflict of interest occurs when a reasonable person, knowing the facts, would consider that a conflict of interest may exist, whether or not this is the case.

·       Potential: a potential conflict of interest occurs where a person has a personal interest that could conflict with their official duties in the future.

Scope

This policy applies to all persons administered by or working for CSS LLC including:

·       employees, whether full-time, part-time, fixed-term or on contract;

·       board or committee members;

·       volunteers; and

·       suppliers or consultants whose contracts specify that they are bound by this policy.

Policy Statement

A conflict of interest may affect a person’s judgement as to what is in the public interest, or may lead to a bias in their decision making. It is not always possible to avoid a conflict of interest. A conflict of interest is not necessarily unethical or wrong.

It is important that any actual, perceived or potential conflict of interest is identified, disclosed and effectively managed (including avoided if possible). Management of conflicts of interest must be fair, transparent, accountable and free from bias.

Persons to whom this policy applies must

·       disclose any actual, perceived or potential conflict of interest;

·       seek independent advice about how a conflict will be managed; and

are encouraged to report any actual, perceived or potential conflict of interest that they observe.

Employee must disclose, and take reasonable steps to avoid, any conflict of interest.