Conflicts of Interest Policy

Conflicts of Interest Policy


The purpose of this Conflicts of Interest Policy is to establish guidelines and procedures for identifying, managing, and disclosing conflicts of interest that may arise among the directors, officers, employees, volunteers, and stakeholders of Anu Initiative CLG (“the Organization”).


This policy applies to all individuals involved with the Organization, including but not limited to directors, officers, employees, volunteers, and stakeholders.

Definition of Conflict of Interest

A conflict of interest occurs when an individual’s personal, financial, or other interests interfere, or appear to interfere, with the individual’s ability to act in the best interests of the Organization. Conflicts of interest may arise from relationships with individuals, organizations, or entities that have a direct or indirect interest in the affairs of the Organization.

Duty to Disclose

All individuals covered by this policy have a duty to disclose any actual or potential conflicts of interest to the Organization. Such disclosures should be made promptly upon becoming aware of the conflict of interest and should be provided in writing to the designated person or committee responsible for maintaining the Register of Interests.

Procedures for Managing Conflicts of Interest

a. Upon receiving a disclosure of a conflict of interest, the Organization shall evaluate the nature and extent of the conflict.

b. The Organization may form a Conflict of Interest Committee or designate a responsible individual to review and determine the appropriate course of action regarding the disclosed conflict.

c. The Committee or responsible individual shall consider all relevant information, including the potential impact on the Organization’s activities and the individual’s ability to act in the Organization’s best interests.

d. Based on the evaluation, the Committee or responsible individual shall develop an appropriate plan for managing the conflict, which may include recusal from decision-making processes or establishing safeguards to mitigate the conflict.

e. The plan for managing the conflict should be documented and communicated to the relevant parties involved.


The Organization shall maintain a Register of Interests, which includes the details of all disclosed conflicts of interest and the actions taken to manage them. The Register of Interests should be regularly updated and made available to relevant individuals within the Organization, such as directors, officers, and the Conflict of Interest Committee.


All disclosures made under this policy shall be treated with utmost confidentiality, as required by applicable local laws, i.e. GDPR, and may be disclosed if required by law or in cases where disclosure is necessary for the proper management of the conflict of interest.

Training and Education

The Organization shall provide regular training and education to its directors, officers, employees, volunteers, and other relevant individuals to ensure their understanding of this policy and their obligations to disclose conflicts of interest.

Compliance and Enforcement

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or association with the Organization. The Organization shall establish procedures to investigate alleged violations and take appropriate action if necessary.

Policy Review

This policy shall be reviewed periodically to ensure its effectiveness and may be amended as necessary to meet the evolving needs of the Organization.

Approved by:
Tejas Bhat
Alan Heraty
Ashley Dechnik
Daniel Mihai

v1.0 - Date: 7th of July, 2023 / Next Review: 7th of January, 2024