Conflict of Interest Policy

Potential conflicts of interest are inherent in any business; therefore, it is not possible in all circumstances to avoid a conflict of interest. The purpose of this Conflict of Interest (COI) policy is to outline a suitable approach and response to the identification and management of such conflicts of interest.

Given the nature of business of Ekco, conflicts of interest may arise on occasion. Real or perceived conflicts of interest, when not appropriately disclosed and addressed, can undermine confidence in the integrity of the organisation and commercial relationships with clients.

Scope

This policy applies to all Ekco employees, including directors, permanent & part-time staff, contractors, suppliers, and agents.

Policy Principles

Disclosure requirements: employees and representatives should disclose any potential conflicts of interest promptly and in writing. This disclosure should cover both personal and professional relationships or situations that may create a conflict.

Avoidance and mitigation: avoiding and mitigating conflicts of interest is preferred, including recusal from decision-making, abstaining from involvement in certain transactions or discussions, or transferring responsibilities to others unaffected by the conflict.

Transparency: transparency helps in identifying, addressing, and preventing conflicts of interest. All relevant parties should be made aware of potential conflicts and the actions taken to manage them.

Ethical decision making: ethical behaviour and standards are expected from all employees & company representatives.

Multiple Clients

Conflicts of interest may arise when an employee acting on behalf of Ekco and the “client”, finds themselves in a position whereby sensitive or privileged client information is in scope by way of other work undertaken on behalf of another “client”. This can arise in two manners:
• An existing client retained by Ekco (Retrospective Conflict)
• New clients contracting Ekco to undertake future services (Prospective Conflict)
In both cases, Ekco will endeavour to disclose and notify of such instances to all clients affected by such.

Disclosures

A key element in avoiding an actual or perceived conflict of interest is to ensure that a process is in place under which those employed by Ekco, provide full disclosure of any potential conflicts which may arise in the course of their employment. This will always ensure that, Ekco is acting in the best interests of the contracting client. All levels of employee in Ekco, follow a code of confidentiality when dealing with all our clients’ business, especially given the nature of our services.

Notifications

To enhance client confidence, Ekco takes all reasonable steps to prevent conflicts of interest from occurring where possible. Situations may nevertheless arise whereby communication will be required to be made to clients, notifying of such an instance.
A formal communication will be made in such cases which will document the following:
• A summary overview of the conflict of interest in question and the circumstances of how it has arisen;
• The notification will be in writing;
• It will be clear, fair and not misleading;
• It will contain enough detail, considering the nature of the Client and their business;
• It will enable the client to make an informed decision.

Raising Concerns

The guidelines and recommendations contained herein should be considered and applied where relevant, and Employees should raise any queries regarding potential conflicts of interest to their line manager/supervisor/director.

Exceptions

There are no exceptions to this policy statement.

Last Updated: December 2023