Policy - Conflict of Interest
Section: Human Resource Policies
Policy Owner: Ignition633 Ministries Nigeria Human Resources
Policy Name: Conflict Of Interest Policy
Origination Date: March 2026
Conflict of Interest Policy
Purpose
This policy establishes guidelines to identify, disclose, and manage conflicts of interest within our organization. It promotes transparency, ethical decision-making, and maintains the integrity of our business operations and relationships. The policy helps protect our organization's reputation and ensures compliance with applicable laws and regulations.
Scope
This policy applies to all employees, officers, directors, contractors, and representatives acting on behalf of the organization. It covers all business activities, transactions, and relationships where potential conflicts may arise between personal interests and organizational duties. The policy extends to immediate family members of covered individuals whose activities may create actual or perceived conflicts of interest.
Policy
Disclosure Requirements
- Employees must promptly disclose in writing any actual or potential conflicts of interest to their immediate supervisor and the compliance department within 5 business days of becoming aware of the conflict, as outlined under No Solicitation of Other Programs or Events in the Solicitation Policy.
- Annual disclosure statements must be submitted by all covered individuals, detailing financial interests, outside employment, and relationships that could create conflicts.
- All disclosures will be reviewed by the Ethics Committee and documented in a confidential registry maintained by Human Resources.
Prohibited Activities
- Employees may not use their position, company resources, or confidential information for personal gain or benefit, as outlined in the Solicitation Policy.
- Accepting gifts, entertainment, or favors exceeding $100 in value from any entity doing business with the organization is strictly prohibited.
- Employees cannot engage in outside employment or activities that compete with or impair their duties to the organization.
Management and Mitigation
- The Ethics Committee will review all disclosed conflicts and develop appropriate management plans within 10 business days.
- Affected individuals must recuse themselves from decisions or activities where conflicts exist and follow prescribed mitigation measures.
- Regular monitoring and auditing will be conducted to ensure compliance with management plans and policy requirements, in conjunction with Solicitation Policy guidelines.
Enforcement and Consequences
- Violations of this policy will result in disciplinary action up to and including termination of employment.
- The organization reserves the right to pursue legal action for serious violations resulting in financial or reputational harm.
- All enforcement actions will be documented and reviewed annually to ensure consistent application of consequences.
Reporting and Training
- All employees must complete annual conflict of interest training and certify their understanding of policy requirements alongside Solicitation Policy training.
- Suspected violations should be reported through the confidential whistleblower hotline or to the compliance department.
- The Ethics Committee will provide quarterly reports to the Board of Directors on policy compliance and significant conflicts.
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This policy will be reviewed annually and is subject to change. Any changes will be communicated to all employees promptly.
For any questions or further assistance regarding this policy, employees should contact the HR department at hr.nigeria@ignition633.org.