Identifying and managing interests that could affect independent judgement.
Document owner: Max Pocock, Lead Consultant Version: 1.0 Issued: 25 July 2026 Review due: 25 July 2027, or earlier after a material conflict or business-model change Applies to: Managed Services Ltd and every person or organisation acting for it
Actual, potential and perceived conflicts are disclosed early, assessed objectively and managed before they can undermine trust, fairness or decision quality.
1. What is a conflict
A conflict of interest arises where a personal, financial, professional or other interest could influence, or reasonably appear to influence, a company decision or duty. A conflict is not necessarily misconduct, but failing to disclose or manage it may be.
Examples include:
- work for clients with competing interests;
- a personal or family relationship with a client, supplier, participant or evaluator;
- financial interests, gifts, hospitality, commissions or referral arrangements;
- access to confidential information relevant to another engagement;
- involvement in evaluating one's own work or a connected organisation;
- outside roles, political activity or public statements relevant to the work; and
- pressure created by fees, deadlines or dependence on a relationship.
2. Disclosure
Interests must be disclosed to Max Pocock as soon as identified and before related selection, access, advice or approval. Max Pocock will record his own relevant interests and disclose them to an appropriate client decision-maker or independent adviser where needed.
Separately engaged specialists and suppliers must update disclosures when circumstances change. Uncertainty should be resolved in favour of disclosure, while limiting unnecessary personal information.
3. Assessment and controls
The assessment will consider the duties involved, closeness and value of the interest, information access, decision influence, reasonable external perception, contractual rules and whether consent can genuinely address the risk.
Controls may include:
- disclosure and informed written agreement;
- restricting information or separating work;
- independent review or approval;
- removing the person from a decision or activity;
- declining a gift, role, supplier or engagement;
- changing reporting or payment arrangements; or
- ending an affected relationship where the conflict cannot be managed.
Client consent does not make every conflict acceptable. Legal, procurement, confidentiality and professional restrictions continue to apply.
4. Confidentiality and competing work
Information from one client or engagement must never be used for another without authority. The company will not accept work where confidentiality, independence or delivery duties cannot be reconciled through credible controls.
Marketing claims, references and case studies require permission and must not reveal protected information.
5. Breach and review
An undisclosed or unmanaged conflict will be investigated proportionately. Possible action includes removing access, repeating or independently reviewing a decision, notifying an affected client, contractual action, repayment or referral where required.
The company will review material conflicts, gifts, referrals, supplier selection and lessons at least annually and before sensitive tenders or engagements.
6. Contact and document control
Conflicts or concerns can be reported to max.pocock@managed-group.co.uk. If the concern involves Max Pocock, an appropriate client contact, independent adviser or competent authority should be used.
This policy must be read with applicable tender, client, procurement, anti-bribery and confidentiality requirements.