MindHug Conflict of Interest Policy

1. Purpose

  1. When competing interests impair our ability to make objective, unbiased business decisions we have a conflict of interest. You may face a conflict of interest when your professional duties as an employee or contractor of MindHug Ltd (“MindHug”)and your personal interests diverge. They may take the form of financial interests in a supplier's or customer's business, recruiting a close family member or engaging in employment outside MindHug.

2. Scope

  1. This procedure applies to all employees, contractors and partners of MindHug (“Personnel”).

3. Objective

  1. To communicate our requirements in respect of conflicts of interest.

  2. To advise all Personnel of their obligation to disclose conflicts of interest and maintain high ethical standards.

  3. To ensure that all business decisions are made in the best interests of MindHug.

4. Associated documents

  1. Please see the MindHug Anti-Bribery Policy.

5. Principles

Expectations

  1. As MindHug Personnel, you are expected to:

    • Maintain the highest possible standard of integrity in all your business relationships, both inside and outside the organisation in which you work.

    • Reject any business practice which might reasonably be deemed improper (including improper practices which might benefit MindHug).

    • Never use your authority or position for personal gain.

    • At all times, act with impartiality, independence and integrity.

    • Avoid being, or giving the appearance of being, in a position which may result in an actual or perceived detriment to MindHug's reputation and/or interests.

Disclosure

2. You must disclose or seek direction on any issues which may potentially conflict with your responsibilities to MindHug.

Restrictions

3. You will not be permitted to engage in transactions on behalf of MindHug with organisations or individuals with which you have an interest. All decision making and transactions with the organisation concerned will be handled and managed independently.

6. Procedure

When do I make a disclosure?

6.1 It is not possible to define all situations or relationships which may create a conflict of interest, so each situation must be evaluated individually. However, some of the more obvious conflicts include:

(a) Having any interest, dealings or shareholdings in any business which either is a competitor, customer, supplier or MindHug partner or is seeking to become one.

(b) A close family member (including children, in-laws, partner or spouse) having any interest, dealings or shareholdings in any business which either is a competitor, customer, supplier or MindHug partner, or is seeking to become one. 

(c)Having a close or longstanding relationship/friendship with a business which either is a competitor, customer, supplier or MindHug partner, or is seeking to become one.

6.2 In all cases, individuals have a responsibility to assess the potential conflict. Actual or perceived conflicts of interest must be disclosed.

Where do I record my disclosure?

6.3 Disclosure should be made to Human Resources, who will log this disclosure on the MindHug Conflicts Register. You must also alert your Director. Employees making positive disclosures will be asked on an annual basis to review conflicts of interest.

Responsibilities

6.4 Actual conflicts of interest must be avoided and potential conflicts of interests carefully managed. Directors must review the disclosed interest, discuss it openly and manage it so that employees do not become involved in or influence situations where actual conflicts of interest occur. 

Other employment

6.5 If you wish to undertake other work while you are employed by MindHug then you must obtain prior written consent from your Director. 

Further advice

6.6 If you are in any doubt as to whether a conflict of interest exists, discuss the situation with your Director.

6.7 If you have any problems recording your conflict of interest please inform the Company Secretary.

7. Consequences

  1. Failure to comply with the above procedures may result in disciplinary action and legal action being taken wherever appropriate.