Conflict of Interest Policy

Last updated: 18/05/2026

SECTION 1 — WHY THIS POLICY EXISTS
Why We Have This Policy
Coral Futures Research & Innovation Centre is governed by a board of six independent members, including two directors. Every member serves voluntarily, without personal financial benefit. The public trust that makes our work possible — from grant funders to individual donors to the communities we serve — depends on us making every decision with complete integrity.
A conflict of interest arises when a board member’s personal, professional or financial interests could — or could be seen to — influence a decision they are making on behalf of the organisation. This does not mean a board member has done anything wrong. It means a situation exists that must be managed transparently, so that every decision made by the board is, and is visibly seen to be, made in Coral Futures’ best interests alone.
This policy sets out how we identify conflicts of interest, how we manage them when they arise, and how we record them. It follows the three-step approach set out by the Charity Commission in guidance CC29 (Conflicts of interest: a guide for charity trustees) and is consistent with the Charity Governance Code.

SECTION 2 — WHO THIS POLICY APPLIES TO
Who This Policy Covers
This policy applies to all members of the board of Coral Futures Research & Innovation Centre, including:

Both directors
All independent board members
Any co-opted or advisory members attending board meetings in a decision-making capacity
Any employees or contractors who are involved in decisions where a conflict may exist

Volunteers who are not involved in governance decisions are not subject to this policy, though Coral Futures expects all representatives of the organisation to act with integrity at all times.

SECTION 3 — WHAT A CONFLICT OF INTEREST IS
What Counts as a Conflict of Interest
The Charity Commission identifies two common types of conflict of interest: financial conflicts and loyalty conflicts. Get Grants
Financial conflicts arise when a board member, or a person or organisation connected to them, could benefit financially from a decision made by the board. This includes, but is not limited to:

Contracts for goods or services awarded to a company in which a board member has a financial interest
Employment of a person connected to a board member
Grants or donations made to an organisation with which a board member is affiliated
Purchase or lease of property or equipment from a connected person or organisation
Any other arrangement from which a board member or connected person could derive direct or indirect financial benefit

Loyalty conflicts arise when a board member’s loyalty to another person, organisation or cause could prevent them from making a decision that is purely in Coral Futures’ best interests. This includes situations where a board member:

Also serves as a director, trustee or senior employee of another organisation that has a relationship with Coral Futures
Has a close personal relationship with someone whose interests are affected by a board decision
Has made public commitments to a position that conflicts with the organisation’s best interests

Connected persons for the purposes of this policy include: a board member’s spouse, civil partner or cohabiting partner; parents, children, siblings and their spouses; business partners; companies in which the board member holds a significant interest; and organisations of which the board member is a trustee or senior officer.
Important: A conflict does not have to be actual to require management. A perceived or potential conflict — where a reasonable person might question whether a board member could act impartially — must also be declared and managed under this policy.

SECTION 4 — THE THREE-STEP PROCESS
How We Manage Conflicts of Interest
The Charity Commission requires charity trustees to follow a three-step approach: identify a conflict of interest, deal with a conflict of interest, and record a conflict of interest. Here is how Coral Futures applies each step. Active Together

Step 1 — Identify
Board members are responsible for identifying their own conflicts of interest. This requires ongoing vigilance — not just at the start of a board term, but throughout the year as circumstances change.
Board members must identify and declare any conflict — actual, potential or perceived — before it becomes relevant to a board decision. Waiting until a conflict has already affected a decision is not acceptable.
At the start of every board meeting, the chair will ask all members to declare any interests relevant to items on the agenda. This declaration is in addition to, not a substitute for, the ongoing obligation to maintain and update the Register of Interests (see Section 6).
A conflict exists in relation to an agenda item if a board member:

Has a financial interest in any matter being discussed
Has a personal relationship with any individual or organisation affected by the decision
Has a professional or organisational affiliation that creates a loyalty conflict
Would gain any personal benefit, direct or indirect, from a particular outcome

If in doubt, declare. Board members are encouraged to raise potential conflicts even when they are unsure whether they constitute a formal conflict. The board will assess this collectively and record the outcome.

Step 2 — Deal With
Once a conflict has been identified, the board will take one or more of the following steps:
Remove the conflicted member from the decision. In most cases, the board member with a conflict will:

Declare their interest at the start of the relevant agenda item
Take no part in the discussion of that item
Leave the room (or, in a virtual meeting, remove themselves from the call) for the duration of the discussion and vote
Not be counted in the quorum for that item

Assess whether the decision can proceed. If the conflict is significant, the remaining board members will consider whether a valid and quorate decision can be made without the conflicted member, and whether the decision is clearly in the best interests of the organisation.
Consider independent advice. Where a conflict is complex or the board is uncertain how to proceed, independent legal or governance advice may be sought before a decision is made.
Minute the process. The steps taken to manage the conflict must be recorded in the board minutes, whether or not the item proceeds to a decision (see Step 3).
When conflicts cannot be managed: If a conflict is so significant that it cannot be managed through the steps above — for example, if the majority of the board has a conflict on a single issue — the board will seek independent advice and, if necessary, guidance from the Charity Commission.

Step 3 — Record
All declared conflicts of interest must be recorded in the board minutes. The record must include:

The name of the board member who declared the conflict
The nature of the conflict
The agenda item or decision to which it related
The steps taken to manage it (withdrawal from discussion, withdrawal from vote, etc.)
The outcome of the decision, and confirmation that it was made by the remaining non-conflicted members

The Register of Interests (see Section 6) must also be updated to reflect any new or changed interests identified at board meetings.

SECTION 5 — RECEIVING GIFTS AND HOSPITALITY
Gifts and Hospitality
Board members and staff should not accept gifts, hospitality or other benefits from organisations or individuals that have — or are seeking — a relationship with Coral Futures, where acceptance could create, or appear to create, a conflict of interest or an obligation.
Acceptable: Modest hospitality of a value that is normal in a professional context (for example, refreshments at a meeting or a token gift of negligible value). Any such hospitality received should be declared at the next board meeting if it relates to a current or prospective relationship with the giving organisation.
Not acceptable: Cash gifts of any amount; gifts or hospitality of significant monetary value; anything that could reasonably be interpreted as an attempt to influence a decision.
Where a board member is uncertain whether something constitutes an acceptable gift, they should consult the Chair of the Board before accepting it.
All gifts and hospitality received that are declared to the board will be recorded in the board minutes.

SECTION 6 — THE REGISTER OF INTERESTS
Our Register of Interests
Coral Futures maintains a Register of Interests in which all board members record their significant interests, relationships and affiliations that could give rise to a conflict of interest in the course of the organisation’s work.
What must be registered:

Directorships, trusteeships or senior roles in other organisations
Significant shareholdings or financial interests in businesses or organisations
Employment or consultancy arrangements
Close personal relationships with suppliers, contractors, grant-making bodies or other organisations with which Coral Futures has or may have a relationship
Any other interest that a reasonable person might consider relevant

When to update the register:
The register is reviewed and updated by each board member at least annually, and immediately whenever a new relevant interest arises. Board members are responsible for keeping their own entry accurate and current.
Access to the register:
The Register of Interests is available for inspection by the Charity Commission. It will be made available to any person with a legitimate reason for inspecting it, at the board’s discretion. A summary of declared interests may be published on this website as part of our commitment to transparency.
If you would like to view the Register of Interests, please contact us at governance@coralfuturesresearch.org.

SECTION 7 — DIRECTOR LOANS AND CONNECTED TRANSACTIONS
Director Loans and Connected Transactions
The board is aware that Coral Futures has received financial support in the form of zero-interest personal loans from its two founding directors, totalling nearly £20,000. These loans are formally documented in the organisation’s financial records and constitute connected transactions for the purposes of this policy.
These arrangements were entered into before this policy was formally adopted, in the context of establishing the organisation’s initial research infrastructure. The board has reviewed these arrangements and is satisfied that:

They were entered into in the genuine interests of the organisation
They do not confer any financial benefit on the directors beyond the eventual repayment of the principal sum
They are formally documented, recorded in the organisation’s accounts and disclosed in all relevant reporting
The directors concerned receive no interest, fees or other benefit from these loans

Any future connected transaction — including any further loans from directors or board members, or any contract for services involving a connected person — will be subject to the full conflict of interest management process set out in this policy before it is agreed, and will be recorded in the board minutes and Register of Interests.

SECTION 8 — BREACHES OF THIS POLICY
What Happens If This Policy Is Not Followed
Failure to declare a conflict of interest, or participating in a discussion or vote in which a conflict exists, is a serious governance failure. It may:

Render the relevant board decision invalid
Expose the organisation to legal challenge
Constitute a breach of the directors’ duties under the Companies Act 2006
Require reporting to the Charity Commission as a serious incident once CIO registration is confirmed
Damage the organisation’s reputation and the trust of its supporters, funders and community

Where a breach of this policy is identified, the board will:

Review the relevant decision to assess whether it needs to be revisited or reversed
Record the breach and the board’s response in the minutes
Consider whether any corrective action is needed
Take steps to prevent recurrence, including if necessary reviewing board member participation

The board member concerned will be given the opportunity to respond before any decision is made about consequences. The board’s response will be proportionate to the nature and circumstances of the breach.

SECTION 9 — RESPONSIBILITIES
Who Is Responsible for What
Each board member is responsible for:

Identifying their own conflicts of interest promptly and proactively
Declaring all conflicts — actual, potential and perceived — at board meetings and to the Chair as they arise
Maintaining an accurate and up-to-date entry in the Register of Interests
Withdrawing from discussions and votes where a conflict exists
Seeking guidance from the Chair if uncertain whether a conflict exists

The Chair of the Board is responsible for:

Ensuring this policy is understood by all board members
Opening each board meeting with an invitation to declare interests relevant to the agenda
Managing the process when a conflict is declared during a meeting
Maintaining the Register of Interests and ensuring it is reviewed annually
Seeking independent advice where conflicts cannot be managed by the board alone

If the Chair has a conflict: A deputy chair or the most senior non-conflicted board member will manage the process for that item.

SECTION 10 — POLICY REVIEW
Reviewing This Policy
This policy will be reviewed by the full board at least once every 12 months. It will also be reviewed immediately if:

A significant conflict of interest arises that is not adequately covered by this policy
There is a change in the organisation’s activities, structure or relationships that makes a review necessary
There is a relevant change in the law or in Charity Commission guidance

Any significant changes to this policy will be communicated to all board members and volunteers before taking effect.

SECTION 11 — REGULATORY REFERENCES
Regulatory and Legal Framework
This policy is informed by and consistent with:

Companies Act 2006 — Directors’ duties, particularly Section 175 (duty to avoid conflicts of interest), Section 177 (duty to declare interest in proposed transactions) and Section 182 (declaration of interest in existing transactions)
Charity Commission guidance CC29 — Conflicts of interest: a guide for charity trustees
Charity Commission guidance CC3 — The essential trustee: what you need to know, what you need to do
The Charity Governance Code — particularly the principles relating to integrity and board effectiveness
Coral Futures’ Articles of Association — provisions relating to directors’ interests and decision-making

Once CIO registration with the Charity Commission is confirmed, this policy will be reviewed to ensure full compliance with the Charities Act 2011 and any applicable Commission guidance for charitable incorporated organisations.

Our application to become a CIO is with the Charity Commission. In the meantime, Coral Futures operates as a Company Limited by Guarantee and can accept support and contributions, though charitable status and Gift Aid eligibility will begin once registration is confirmed.

Prepared: May 2026
Based on: UK Charity Commission guidance CC29, CC3, Companies Act 2006, Charity Governance Code