Policy 044: Conflict of Interest

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Policy 044: Conflict of Interest

1. Purpose and Scope

1.1 This Policy explains in an open, transparent and accessible way how ACM identifies,

manages and mitigates conflict of interest and/or bribery. 

1.2 This policy describes how the Academy of Contemporary Music (ACM) looks upon the issue of conflicts of interest and/or bribery.

1.3.  This policy applies to all staff and is designed to protect ACM as a business and the integrity of our qualifications. It is also designed to protect our staff by providing guidance on handling possible conflicts of interest that may arise.

2. Policy Statement

Conflict of Interest

Definition of a Conflict of Interest

2.1. A conflict of interest is a situation in which financial or other personal considerations may compromise, or have the appearance of compromising, a staff member’s professional judgment in teaching, management, administration, or other professional activities.

2.2 Conflicts of interest have the potential to bias directly or indirectly many activities or aspects of the ACM’s endeavour. This is especially so when staff members are in a position to set ACM policies, manage contracts, select equipment and supplies, involve students in sponsored projects, or when they have managerial and administrative roles for which objectivity and integrity are paramount.

2.3 The appearance of a conflict of interest may be as serious and potentially damaging as an actual conflict. Reports of conflicts based on appearances can undermine public trust in ways that may not be adequately restored even when the mitigating facts of a situation are made known. Apparent conflicts, therefore, have to be evaluated and managed in the same way as known conflicts.

2.4 A conflict of interest exists in relation to an awarding body where:  

1. An awarding body’s interests in any activity undertaken by it, on its behalf, or by a member of its Group have the potential to lead it to act in any way contrary to its interests in complying with its Conditions of Recognition;  
2. A person who is connected to the provision of the awarding body’s qualifications has interests in any other activity which have the potential to lead that person to act in any way contrary to his or her interests in that provision by the awarding body in compliance with its Conditions of Recognition; or 
3. An informed and reasonable observer would conclude that either of these situations was the case.”

Activities which are ordinarily permissible

2.5 Performance of professionally-related activities such as gigs, recordings, writing for publications, service on review boards and panels.

2.6 Service as a consultant to outside organisations.

2.7 Service on boards and committees of organisations, public or private, which do not distract unduly from ACM obligations.

Activities which appear to present potential conflicts of interest or commitment

2.8 Relationships that might enable an employee to influence ACM’s dealings with an outside organisation in ways leading to personal gain or to improper advantage for anyone.

For example, an employee could have a financial interest in an enterprise with which ACM does business and be in a position to influence relevant business decisions. Ordinarily such problems may be resolved by full disclosure as well as making appropriate arrangements that clearly exclude that employee from participating in the decisions.

2.9 Situations in which the time or creative energy an employee devotes to extra-ACM activities, including those listed above, appears substantial enough to compromise the amount or quality of his/her participation in the teaching or administrative work of ACM itself.

2.10 Activities (gigs, recordings, writing, conferences, teaching, consultancy agreements etc) for which employees are personally remunerated that involve, or might be perceived to involve, ACM, its name, or facilities/ equipment without prior permission.

Activities which present such serious problems as to be incompatible with ACM policies

2.11 Situations in which the individual assumes responsibilities for an outside organisation that divert his/her attention from ACM duties, or create other conflicts of loyalties.

2.12 Situations in which an employee would be marking the assessments of friends or relatives pursuing ACM qualifications.

Potential Areas of Conflict

2.13 Conflicts of interest can arise in a variety of circumstances, for example:

• When an individual works for or carries out work on ACM’s behalf, who has friends or relatives taking ACM assessments or examinations.
• When an individual has a position of authority in one organisation that conflicts with his or her interests in another organisation.
• when an individual has interests that conflict with his or her professional position.
• when an individual works for or carries out work at ACM, but may have personal interests – paid or unpaid – in another business which either uses ACM services, or offers similar services.

2.14 Conflicts can arise from commercial interests, academic situations, ethical or religious views or personal relationships. The most common are those arising from commercial interests and close personal relationships. The existence of an actual, perceived or potential conflict of interest does not necessarily imply wrongdoing on the part of anyone. However, any private, personal, or commercial interests which give rise to such a conflict of interest must be recognised, disclosed appropriately, and either eliminated or managed.

Bribery

2.15 Under the Bribery Act 2010, a bribe is a ‘financial or other advantage’ offered, promised or given to induce a person to perform a relevant function or activity improperly, or to reward them for doing so.

2.16 Under the Bribery Act, individuals can be prosecuted for accepting bribes or offering bribes. In addition, ACM can be prosecuted for failing to prevent bribery committed to obtain or retain business or a business advantage for ACM by an employee or other individual or organisation performing services for ACM.

Individual Responsibility

2.17 Individuals within ACM have responsibility for ensuring that they are familiar with the Conflict of Interest Policy.

2.18 The most important feature of the policy is the requirement that an individual disclose any activity that might give rise to a potential Conflict of Interest. 

2.19 The individual and line manager are equally responsible for ensuring that the issue is documented.

2.20 An individual may wish to raise concerns relating to conflict of interest directly with Human Resources. This may be done in confidence and they are entitled to receive a response to their concerns. It should be noted that individuals are protected under ACM’s Whistle-blowing Policy.

2.21 If the staff member is unsure whether a conflict of interest might arise, they should discuss this with their line manager first. The line manager should contact Human Resources Department if they need advice on whether a situation presents a conflict.

Management and Supervisory Roles

2.22  Staff members who hold a line management or supervisory role have an obligation to make a disclosure in all cases where they find themselves involved in:

• (a) the recruitment, selection, or appointment of an applicant; or
• (b) the appraisal, promotion, discipline, or other management activity of a staff member; or
• (c) the authorisation of any financial payments (e.g. timesheets, expenses claims, salary changes) for a staff member with whom they have a personal relationship, or who is known to them privately through their commercial interest, or whose known religious/ethical views or strong personal values may be perceived to be in conflict with their own.

Contracts and Agreements

2.23 Staff have an obligation to disclose in writing to a responsible person associated with the contract or agreement that they believe that a conflict of interest does or could exist in respect of their involvement in the contract or agreement. If a staff member who is negotiating an agreement on behalf of ACM has an interest such that it could appear to a reasonable observer that negotiations are biased, the staff member should disclose that interest.

2.24  In specific cases, there may be benefits to both staff and ACM for staff to hold other part-time employment simultaneously with their ACM employment. However, there also exists a potential for a perceived or real conflict of interest or commitment where more than one employment relationship exists at any particular time.

2.25 Staff should disclose their intention to hold other employment concurrently with their ACM employment, and they should seek formal ACM approval for such arrangements in accordance with the exclusivity clauses in the Staff Handbook.

Outside Activities or Earnings

2.26 In undertaking any outside activities or earnings, staff must abide by the terms of their contract of employment. Where a member of staff is engaged in outside activities, they must advise their line manager of any potential conflict of interest or any perception of a conflict of interest with their obligations to ACM.

Receipt of Gifts

2.27 It is not acceptable for a staff member to give or receive a gift, favour, or benefit, that may: compromise his/her judgment or have the appearance of so doing; create a conflict of interest; damage relationships with others; or indicate any favouritism or prejudice towards a person or group of people. Staff should consider the cultural context in which the gift, favour, or benefit was offered, and endeavour to avoid giving offence.

Assessing Conflicts of Interest

2.28 Line Managers must determine the permissibility of various activities, and assess the degree to which disclosed activities may pose a risk to the staff member, ACM, and other organisations which may be affected. Below is a suggested list of questions for use in evaluating potential conflicts of interest or commitment.

The list is not exhaustive and other questions related to special circumstances can be added, as appropriate.

• Has all relevant information concerning the staff member’s activities been disclosed?
• Do the relevant staff member’s financial interests suggest the potential for conflicts or the appearance of conflicts or bias?
• Do the staff member’s reported external time commitments exceed permissible (or reasonable) levels?
• Is there any indication that the staff member in his/her professional role has improperly favoured any outside body or appears to have had incentive to do so?
• Has the staff member inappropriately represented ACM to outside bodies?
• Does the staff member appear to be subject to incentives that might lead to conflicts or bias?
• Is there any indication that obligations to ACM are not being met?
• Is the staff member involved in a situation that might raise questions of bias, inappropriate use of ACM assets, or other impropriety?
• Do the current engagements of the staff member represent potential conflicts between outside interests (e.g. working on projects simultaneously for competing business interests)?
• Could the proposed activity withstand public scrutiny? 

3. Responsible Parties

3.1 Implementation and compliance with the Policy, and corresponding Procedure will be overseen by the following designated staff:

• Head of Human Resources

3.2 Decisions and appropriate actions in support of the implementation of the Policy will be authorised by the following designated staff: 

• Head of Human Resources 
• Staff with Line Management responsibilities

4. Reference Points

4.1 Internal

• Academic Misconduct
• Assessment
• Equality and Diversity
• Staff Handbook
• Staff Disciplinary
• Student Complaints & Grievances 
• Whistle-blowing

4.2 External

• Data Protection Act  2018 
• Bribery Act 2010

5. Date of Approval and Next Review 

Version: 1.2

Approved on: 01 Sep 2025

Approved by: Academic Board 

Next Review: August 2026

Download: 044 POL_Conflict of Interest