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Policy 3.2 Integrity, privacy and security How we keep people and information safe

Conflict of interest

What counts as a conflict of interest at Just Gold and how conflicts are declared, recorded and managed.

Easy Read

This policy is about conflicts of interest.

A conflict is when personal interests could affect your work.

Working for a competitor can be a conflict.

Accepting gifts or favours can be a conflict.

Decisions that affect your family can be a conflict.

Fill in a declaration form every year.

Tell the CEO about new conflicts straight away.

The CEO keeps a confidential record.

Small conflicts get a plan, like stepping out of a decision.

In plain language

A conflict of interest is when personal interests could affect your work for Just Gold. Examples are working for a competitor, accepting gifts or making decisions that affect family. Everyone fills in a declaration form each year and reports new conflicts straight away. The CEO reviews every declaration and keeps a confidential record. Minor conflicts get a plan, such as stepping out of a decision.

Full policy

Section 3: Integrity, privacy and security

Trust is essential to our work. This section governs how we manage information, declare interests, and use resources. It sets out the ethical boundaries for professional integrity, including how we protect private data and public confidence in Just Gold's brand.

Policy statement

Integrity means acting in the best interest of community, not personal gain. All individuals engaged with Just Gold must declare any actual, potential, or perceived conflicts of interest. We do not tolerate hidden agendas or divided loyalties.

Examples of conflicts

  • Working with or for a competitor while engaged by Just Gold.
  • Receiving gifts, payment, or favours from clients, suppliers, or partners.
  • Participating in decisions that affect a family member or close associate.
  • Using Just Gold information or resources for personal or financial benefit.

Declaration process

  • All team members must complete a Declaration of Interest form annually.
  • New conflicts must be disclosed immediately via the staff portal or to the CEO.
  • Disclosures are reviewed by the CEO and recorded in a confidential register.

Management

  • Where a conflict is minor, a management plan will be created (for example, stepping out of decisions).
  • Significant or unresolved conflicts may result in role change, exclusion from specific work, or disengagement from the enterprise.

Application

Applies to staff, contractors, board members, interns, and collaborators. It also informs procurement decisions and subcontracting.

Status
Under review
Version
2.0
Last updated
14 May 2025
Effective date
14 May 2025
Review date
March 2027
Owner
CEO, Just Gold