- Status
- Published
- Version
- 1.0
- Effective
- 19 June 2026
- Last reviewed
- 19 June 2026
- Review cycle
- Annually
- Last updated
- 19 June 2026
1. Purpose
This policy protects the Foundation, its beneficiaries and its representatives by ensuring that real, potential or perceived conflicts of interest are identified, declared and managed openly.
2. Scope
This policy applies to every Trustee, staff member, volunteer, consultant and partner representative acting on behalf of the Foundation.
3. What is a conflict of interest?
A conflict of interest arises when a personal interest could improperly influence — or appear to influence — a decision made on behalf of the Foundation. Examples include:
- A Trustee whose family business tenders for a Foundation contract.
- A staff member recommending a service provider in which they hold a financial interest.
- A volunteer directing beneficiaries to a paid service they offer privately.
- Accepting personal gifts of significant value from a supplier, partner or donor.
4. Declaration
- Every Trustee, staff member and volunteer completes an annual declaration of interests.
- New or emerging interests must be declared promptly in writing to the Board Chair (Trustees) or the Executive Lead (staff and volunteers).
- Any party with a declared interest in a matter must recuse themselves from related decisions and may not vote on them.
5. Gifts and hospitality
- Gifts of nominal value (under R500) may be accepted but must be recorded in the gifts register.
- Cash, vouchers or gifts above R500 must be declined or transferred to the Foundation.
- Hospitality must be modest and connected to legitimate Foundation business.
6. Procurement
Where a related party (family, business associate) is being considered as a supplier, the related party must be excluded from the selection process and the decision recorded in detail.
7. Breach
Failure to declare or manage a conflict of interest is a serious breach and may result in removal from the Board, dismissal, or termination of volunteer status.
8. Register
The Foundation maintains a Register of Interests that is reviewed by the Board at least annually. Material entries are disclosed in our annual report.
9. Reporting concerns
Any concern about an undeclared or improperly managed conflict can be reported in confidence to info@eflegacy.org.
Questions about this policy? Email info@eflegacy.org and a member of our team will respond within five working days.