Scope

• The aim of this policy is to give guidance to directors, employees and anybody acting on its behalf on how Wisdom House handles conflicts of interest, and the action it takes to prevent and manage such conflicts of interest from occurring. This policy is in place to ensure we address all conflicts of interest irrespective of where they arise. I.e. with our assessor specialists, our customers, our own staff as well as contractors, and our third-party suppliers.

Introduction

When to use this policy?

• It is Wisdom House’s aim that employees and others acting on Wisdom House’s behalf should be free from conflicts of interest or potential conflicts of interest which could adversely influence their judgment, objectivity or loyalty to Wisdom House or its stakeholders when conducting Wisdom House activities.
• The company recognises that employees and others acting on Wisdom House’s behalf may take part in legitimate financial, business, charitable and other activities outside Wisdom House. However, employees and others acting on Wisdom House’s behalf should avoid actions, situations or relationships which might conflict, or appear to conflict, with their responsibilities on behalf of Wisdom House, or that might conflict, or appear to conflict, with the interests of Wisdom House.

The Policy

• The areas where potential conflicts of interest might arise have been grouped into four broad categories:
• 1. Wisdom House Staff (including contractors, fixed term contract employees and temporary members of staff) can have conflicts of interest where they have close relatives or associates sitting Wisdom House qualifications or undergoing EPA for apprenticeship standards and at the same time have access to live assessment materials or are able to access processing systems and manipulate marks.
• 2. Centres – members of staff of Wisdom House have conflicts where they are either teaching or administrating qualifications or EPA’s for apprenticeship standards which close relatives or associates are sitting.
• 3. Assessment specialists – this is a particular issue for assessment specialists who author live assessment materials, provide examining services and teach across the same qualification or EPA for apprenticeship standards. There is an additional conflict when close relatives or associates are sitting the qualification/assessment where they are authoring live assessment material.
• 4. Other third parties – Wisdom House uses a range of third parties delivering, marking and awarding its qualifications and EPA for apprenticeship standards in addition to the three above.
  • Potential conflicts of interest – Wisdom House employees and others acting on its behalf
  • The following are some (but not exclusive) examples of potential conflicts of interest that could apply to Wisdom House employees and others acting on its behalf:
  • having a direct or indirect financial interest in a Wisdom House competitor, supplier or customer
  • using a position in Wisdom House to influence the results of an assessment, for example of a relative or acquaintance
  • using company confidential information for personal gain or advantage
  • having a second job or consulting relationship:
  • ➢ which could affect that person’s ability to satisfactorily perform Wisdom House duties and obligations, or
  • ➢ with an employer who is a direct or indirect competitor, customer, supplier or distributor of Wisdom House.

• Disclosure of conflicts and potential conflicts of interest
• It is the responsibility of all employees, and others acting on Wisdom House’s behalf, to disclose any conflict of interest, or potential conflict of interest, promptly to Wisdom House’s Head of Compliance. All employees, and others acting on behalf of Wisdom House, are encouraged to seek the approval of Wisdom House’s Head of Compliance, prior to taking part in financial, business, charitable or other activities which may pose any conflict of interest, or potential conflict of interest. All employees, and others acting on behalf of Wisdom House, are required to complete a Conflict of Interest Disclosure Form, and they are responsible for disclosing any conflict of interest, or potential conflict of interest, that may occur thereafter, promptly to Wisdom House’s Head of Compliance.
• Disciplinary action may be taken in cases of failure to disclose any conflict of interest, or potential conflict of interest. The Conflict of Interest Disclosure Declaration will be held on file in accordance with the General Data Protection Regulation (GDPR) 2016.
• Potential conflicts of interest – centres
• Wisdom House has rigorous monitoring and quality assurance processes in place with centres which are administered through its team of External Quality Advisors (EQA).
• Wisdom House has an allocated EQA who is responsible for ensuring that the centre maintains its quality assurance systems to comply with the required standards – through visiting the centre, talking to the centre’s assessment/quality assurance teams, talking to learners, viewing samples of learners’ work and looking at the centre’s records and documentation.
• EQAs will escalate any concerns regarding a potential Conflict of Interest to Wisdom House’s Head of Compliance who is the Responsible Officer.
• Potential conflicts of interest – Assessment Services
• Wisdom House has rigorous monitoring and quality assurance processes in place regarding the end-point assessment of apprentices which are administered through its team of End-point Assessors.
• Each apprentice has an allocated End-point Assessor who is responsible for ensuring that quality assurance systems and processes comply with the required standards.
• End-point Assessors will escalate any concerns regarding a potential Conflict of Interest to Wisdom House’s Awarding’s Head of Compliance who is the Responsible Officer.
• Potential Conflicts of Interest – Third Parties
• All other third parties’ contract’s owned by the Operations team and are managed in accordance with Procurement policies which include requirements on confidentiality and declaration of interest. Any such declarations are passed to the contract owner for review.