Well connected - or conflicted?

Well connected – or conflicted?

For many years, and more recently in my current role, I have observed that the recognition and management of conflicts of interest is something many organisations struggle with.

As a concept it appears well enough understood, but contextualising it to relevant worked examples within awarding organisations or EPAOs is often missed, particularly when these businesses are nested within a larger group of companies.

When we add a further complexity of working within a niche sector as a specialist organisation, then we come to the “it’s a small world” issue.

It isn’t always the case that such situations must be devoid of all conflicts, it is important however to be able to recognise them (whether they are actual, potential or perceived) and what you subsequently do with this information. Simply recording conflicts somewhere isn’t enough – what will you do? Can you re-organise a process to minimise the conflict? Can you remove it, or re-allocate a conflicted colleague? Can you recuse yourself from board meetings or ringfence sensitive information? Can you reschedule an event? Ultimately, are you able to refuse to work with someone?

Once you have put these mitigations in place, it is equally important to monitor them to check if they are effective or appropriate, making changes where needed as a result of this review.

Whether you are already recognised by Ofqual, or currently navigating your way through the recognition process, you will need to be familiar with the most up to date guidance and definitions as described here (https://www.gov.uk/guidance/ofqual-handbook/section-a-governance ), and the regulatory conditions these link to, against which you must at all times demonstrate compliance.

More widely, if you are part of a group of companies, you may wish to use this important exercise to review and evaluate your approach more generally as an organisation. This document (https://iccwbo.org/publication/icc-guidelines-conflicts-interest-enterprises/ )is published by the International Chamber of Commerce and contains some very useful definitions and examples. Transplant your organisation, your supplier network, key roles and partnerships into these scenarios, and it quickly becomes clear what conflicts you might have in play, how they can not only render you potentially non-compliant, but also the ethical dimension and how you wish to be perceived amongst your peers, partners and – importantly – your competitors or future customers.

By getting this right at all levels of your organisation (from board governance, through to operational administration), as an AO or EPAO you will provide a high level of confidence to all your stakeholders that your assessment judgments are valid, and can be trusted as objective, with no vested interest other than that of delivering a high quality outcome.

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