Conflict of Interest policy

STATEMENT OF INTENT

This policy sets out E Co’s commitment to maintaining high standards of integrity in offering an increasingly diverse set of services to a wider client base. The policy covers how E Co. will manage conflicts of interest that may arise in the provision of consultancy services in regulatory or policy areas closely related to contracts where the company provide market level services or in the provision of more than one market level contract in related sectors.

This policy shall apply to all E Co. employees, associates and service partners and in accordance with relevant contractual requirements, quality and monitoring procedures.

POLICY COMMITMENT

This policy commits E Co. to recognise, record, and where appropriate mitigate, circumstances where conflicts of interest can arise in the provision of services to more than one client in a related service area.

This policy commits E Co. to set out conflict of interest requirements to associates and service partners so that all representatives of E Co. share the company’s commitment to ensure decisions or actions are in the interests of our clients.

DEFINITIONS

This policy addresses three main types of conflict of interest:

Party Conflict – a situation in which our duties to one party conflict with our duty to another party.

Own Interest Conflict – a situation in which our duties to a party conflict with our own interests or those of our staff or subcontractors.

Confidential Information Conflict – a situation in which we are required to give information to one party but have a duty to another party to keep that information confidential.

PRINCIPLES

There is inherent subjectivity involved in matters of conflict of interest, where the all-important “question of degree” must be addressed. The following principles help to determine whether the approach taken to resolving the perceived or actual conflict is reasonable:

Independence

We will at all times maintain our independence from external influences that may affect our ability to hold the interests of the client paramount, without neglecting the legitimate interests of other parties.

Transparency

We must be able to defend our actions with documented evidence that we adhere to the conditions of engagement and fulfil our contractual obligations. We must always be able to provide evidence that we follow a code of ethics embedded in company policy, and that the practice is universal throughout the firm. This code of ethics includes our Anti-corruption Policy, Equality Policy, Modern Slavery Policy, Safeguarding Policy, Environmental and Social Policy, and Data Protection Policy.

Prior disclosure

We will identify and fully disclose any potential or real conflict of interest at the earliest opportunity, and continuously monitor developments in the firm, and with our contractors to ensure that subsequent events do not affect our previously stated position.

IMPLEMENTATION AND MONITORING

In handling potential conflicts of interest, the application of common sense, maintenance of trust and transparency are paramount.

The policy is supported by a clear methodology:

1. Orientation – Senior management will assess the risk level of all client engagements for real or perceived conflict of interest. For contracts that are rated higher risk, such as those where we carry out evaluation or assessment services, senior managers will perform additional checks and due diligence to identify potential issues, and establish a formalised disclosure procedure with the client.

2. Awareness – We recognise that a conflict of interest may arise at any stage of an engagement, from bidding through to delivery. An employee, associate or service partner will notify senior management of a potential conflict of interest at the point of identification (usually at the outset of discussions relating to a new business opportunity).

3. Assessment – Senior management and assignment staff will work together to determine the extent of the actual or perceived conflict. The assessment will take into account both the likelihood of an actual conflict, and the potential impact (financial or reputational) of a perceived or actual conflict for E Co., our clients and beneficiaries.

4. Disclosure – Where a perceived or actual conflict of interest cannot be avoided, and at the earliest opportunity, E Co. will disclose the nature of the conflict to the client, along with our assessment of its severity (likelihood and impact), and any proposed approach to mitigating the conflict.

4. Mitigation – Where mitigation is required and the client has provided a positive response to the proposed mitigation measures, staff and senior management will document the mitigating actions and implement them as agreed in order to address the conflict. Potential mitigation measures for a Party Conflict might include changing the timing of the assignments so that E Co’s obligations to one client have been discharged before starting work for the other client, or recusing ourselves from the part of the assignment that triggered the conflict. Potential mitigation measures for Own Interest Conflicts might include removing certain members of staff from the assignment or requiring the staff member to divest those assets. Potential measures to address Confidential Information Conflicts might include returning or destroying confidential information after an assignment, or recusing staff who accessed or generated the confidential information from working on the other assignment.

5. Monitoring and Reporting – Senior management will monitor compliance with mitigating actions and conformance with this policy at regular intervals and will support this policy with the same rigour as other company policies. At the individual level, relevant members of staff, associates and service partners will be responsible for complying with the policy and reporting on compliance.

APPLICATION TO SPECIFIC SCENARIOS

E Co, our staff, and contractors shall not carry out any assignment that would a) be in conflict with their prior or current obligations to other clients, or b) may place them in a position of not being able to carry out the assignment in the best interest of the client.

The scenarios below illustrate our approach to implementing this policy:

a. Conflict between consulting activities and procurement of goods, works or services

If we, or our contractors, are engaged by a client to provide goods, works or services for a project, we shall be disqualified from providing consulting services related to those goods, works or services, unless the potential conflict arising from this situation has been identified and resolved in a manner acceptable to the client. Conversely, if we or our contractors are engaged to provide consulting services for the preparation or implementation of a project we shall be disqualified from subsequently providing goods or works or services resulting from or directly related to our earlier consulting services, unless the potential conflict arising from this situation has been identified and resolved in a manner acceptable to the client.

b. Conflict between consulting assignments

E Co., including our personnel and sub-consultants, shall not be engaged for any assignment that, by its nature, may be in conflict with another assignment unless the potential conflict arising from this situation has been disclosed and resolved in a manner acceptable to the client.

c. Relationship with the client’s staff

E Co. personnel and sub-consultants who have a business or family relationship with a member of the client’s staff or of the project implementing agency’s staff may not be engaged for an assignment, unless the conflict stemming from this relationship has been disclosed and resolved in a manner acceptable to the client.

d. Relationship with the beneficiary organisations

E Co. personnel and sub-consultants who have a commercial or personal interest in beneficiary organisations or project implementing agencies may not be engaged for an assignment, unless the conflict stemming from this relationship has been disclosed and resolved in a manner acceptable to the client.

Last revised: 31 October 2020