Importance of maintaining a conflict of interests policy

Charity trustees are bound to ensure that their decisions are only made in their charity’s best interests. This is a key governance responsibility of trustees. Any failure by trustees to act properly where there is a conflict of interest is a breach of their legal responsibilities. Accordingly, the Charity Commission expects trustees to effectively identify and manage all actual and potential conflicts of interest and act in the best interests of their charity. 

Adopting and implementing a written conflict of interests policy is the usual means adopted by a charity to help it ensure that its trustees deal correctly with any conflict of interests. Charities should therefore adopt a conflict of interests policy and keep it under regular review.

Updated safeguarding policy templates

We have taken the opportunity of updating and improving our two charity conflict of interests policy templates. 

One template is for a charitable company limited by guarantee and the other is for a charitable incorporated organisation. They are both designed to be used as a basis for producing a suitable conflict of interests policy for a small or medium sized charity.

Changes to the law and practice relating to conflicts of interest

Under Section 250 of the new Crime and Policing Act 2026, a criminal offence committed by a trustee or senior manager acting within the actual or apparent scope of their authority may, as from 29 June 2026, in some circumstances be attributed to the Charity itself. Charities need to maintain arrangements designed to reduce that risk, including a suitable conflict of interests policy. These updated policy templates are designed to assist in reducing that risk.

More generally, there have over the past few years been various changes in relevant legislation, guidance (including the Charity Commission's CC29 guidance which was updated in early 2026), the Charity Commission's expectations, and good practice. 

Conflict of interests policies need to take account of these changes. These updated templates take full account of these changes.

Why should I use one of these templates?

These comprehensive and updated conflict of interests templates reflect changes to relevant law and practice. They provide a good basis for drafting a conflict of interests policy for your charity, and they will save you time when you are planning and drafting such a policy. They can serve as useful checklists for trustees when they need to identify and manage any conflict of interests.