Conflicts of Interest

1. Purpose

Care Cove Alternative Provision is funded with public money to support vulnerable children. Every decision we make, about learners, staff, suppliers or spending, must be made in the interests of learners and the commissioner, not for anyone's personal benefit. A conflict of interest is not wrong in itself. Hiding it or failing to manage it is.

This policy explains how conflicts are declared, recorded and managed, and sets out the safeguards around the Director's known interests.

2. Scope

This policy applies to directors, the Head of AP, the DSL, the Clinical Advisor, the Administrator, all staff and volunteers, members of the Social Work Management Committee (SWMC), and partner staff where they make decisions about our learners or spending.

3. Law and our contracts

• Companies Act 2006. A director must avoid situations where their interests conflict, or may conflict, with the company's interests (section 175) and must declare any interest in a proposed transaction with the company (section 177).

• Bribery Act 2010. An undeclared interest can lead to, or look like, bribery or fraud (see the Anti-Bribery and Anti-Corruption policy).

• Subcontracting. We may subcontract only with the commissioning local authority's express prior written consent, and remain responsible for subcontractors.

• Confidentiality. Confidential information must not be used for any purpose other than the contract it was given for, or to gain an unfair advantage.

• Publicity. No publicity about a contract, or use of a commissioning local authority's name or logo, without its written consent.

4. Roles and responsibilities

5. What a conflict of interest is

A conflict of interest arises when a person's other interests could affect, or could reasonably be seen to affect, their judgement or actions at Care Cove. It can be actual, potential or perceived. Interests include:

• financial: paid work, directorships, business interests, shareholdings, or payments from suppliers or partners;

• other roles: trusteeships, governorships, or roles with a commissioning local authority, a referring school, a supplier or a partner;

• family and personal: relationships with colleagues, learners' families, suppliers or partners, including through close family and friends.

Examples here include a supplier owned by a staff member's relative; a mentor who knows a referred learner's family; a staff member who is a governor of a referring school; an SWMC member asked to review a decision about someone they are related to; and using the AP relationship to promote Care Cove's other paid services, such as Short Breaks, to a learner's family.

6. Why it matters

Commissioning local authorities, schools and families trust us to make decisions honestly. Because Care Cove sits outside Ofsted inspection, the independence of the SWMC is a central part of the assurance we offer commissioning local authorities. An undeclared conflict can damage that trust, breach our contracts and, in the worst cases, amount to a criminal offence.

7. The register of interests

• Who declares: all directors and managers (Director, Head of AP, DSL, Clinical Advisor), all SWMC members, the Administrator, and any member of staff with influence over purchasing, recruitment or referrals. All other staff declare relationships with learners and families, and other paid work, under the Staff Code of Conduct.

• When: on joining, every September, and within 5 working days of a new interest arising. Anyone attending a meeting declares any interest in an item at the start of the meeting, and it is minuted.

• What: directorships and trusteeships; employment and business interests; roles with commissioning local authorities, schools, suppliers or partners; and close family or personal relationships with staff, learners' families, suppliers or partners. Nil returns are recorded too.

• Where: the Administrator keeps the register securely. The SWMC Chair reviews the Director's entries. Commissioning local authorities can see the register on request.

8. The Director's declared interests

The Director is a director of Dreams Are Real CIC, a Sheffield community interest company running street-based outreach and Holiday Activities and Food camps. Dream Chasers Basketball Club operates within the CIC and is not a separate directorship. The CIC is asset-locked and no private benefit accrues to any Care Cove director. The Director also declares any other directorships and business interests in the register, including any companies connected with Care Cove.

8.1 Where the interest touches the AP

• Social value: cash, materials and equipment invested in community health and wellbeing work with the CIC and Dream Chasers (food for Holiday Activities and Food camps, sports and outdoor equipment, venue hire and transport, and first aid and safeguarding costs for outreach).

• Staff volunteering: coaching, camp delivery and evening street outreach given by the Director, the Head of AP and mentors outside delivery hours.

• Other social value measures: unpaid placements for young people not in education, employment or training, recruited through CIC outreach, and the CIC's coaching and volunteer network as our first recruitment pool.

• Sport partner: basketball coaching and sports leadership with Dreams Are Real CIC and Dream Chasers form part of the curriculum.

• Shared building: the CIC also uses 37 Townhead Street.

8.2 Safeguards

1. Declared and approved. Every transaction, donation, payment, volunteering arrangement, use of premises or service arrangement between Care Cove and the CIC is approved by the SWMC in advance and minuted. The Director does not take part in the decision. The commissioning local authority's contract manager is told before any new type of arrangement begins.

2. Evidenced. Social value support is backed by purchase invoices and a delivery statement, and staff volunteering by a volunteering log, each countersigned for the CIC by someone other than the Director. The SWMC reviews them termly alongside its safeguarding and quality audit.

3. Fair value. Any payment by Care Cove to the CIC, for example for coaching, is a related-party transaction (section 9), agreed at a fair price and recorded. Spending with the CIC is never counted as social value.

4. Separate from our contracts. Social value support is additional and is never presented as delivery of our contracts. CIC coaches who work with AP learners are vetted to the same standard as our staff and recorded on the Single Central Record. The Director checks with the commissioning local authority's contract manager whether any CIC delivery to AP learners needs its consent.

5. Separate from AP learners. Social value beneficiaries are young people in the wider community, and AP learners are never counted as social value beneficiaries. Where AP learners take part in basketball coaching or sports leadership with the CIC, it is part of their AP curriculum and recorded as AP delivery. Learners are never pressed to join CIC activities outside their placement, and each learner's Move Plan offers a choice of community clubs. AP learner information is not shared with the CIC except to keep a child safe, and AP learners do not appear in CIC publicity through their placement. The zoning plan keeps AP activity separate from the CIC's use of the building.

6. Truly voluntary. Staff volunteering happens outside delivery hours and is genuinely optional. Saying no has no effect on anyone's pay, appraisal or prospects, and nobody needs to give a reason.

9. Related-party transactions

A related-party transaction is any arrangement between Care Cove and a person or organisation connected to a director, manager, SWMC member or their close family. Before any commitment is made, it must be approved by someone without the conflict, normally the SWMC Chair, or the SWMC for any arrangement with Dreams Are Real CIC. It must be at a fair price, in writing and entered in the related-party transactions record, which the SWMC reviews every year.

10. Gifts and hospitality

Gifts and hospitality are covered by the Anti-Bribery and Anti-Corruption policy and its register.

11. Recruiting relatives and friends

Anyone who knows a candidate personally declares it before shortlisting. A relative or close friend of a candidate takes no part in shortlisting, interviewing, the decision or any reference. Where someone knows a candidate less closely, for example through the Dreams Are Real CIC coaching and volunteer network that is our first recruitment pool, the declaration is recorded and the panel includes at least one member with no connection to the candidate. Posts are always advertised openly and filled on merit.

Where a relative of a director, manager or SWMC member works for Care Cove, this is entered in the register. Their supervision, pay and performance decisions, and any allegation, complaint or disciplinary matter about them, are handled by someone other than that relative; where the relative is the Director, the SWMC Chair decides who handles it.

12. Relationships with learners and families

Some families will already know our staff, including through community work. Staff who know a learner or family personally, or who meet them in another setting such as a Dream Chasers session, tell the Head of AP before the placement starts or as soon as they realise. The Head of AP and DSL decide whether that member of staff can be the key mentor or work closely with the learner, and record the decision.

Staff must not enter private arrangements with learners' families, such as paid tutoring, babysitting, lifts or social media contact (see the Staff Code of Conduct). Families are never pressed to use Care Cove's other services, and information gained through the AP is not used to market them. A member of staff connected to a referring school or a commissioning local authority steps back from any decision there about Care Cove. If a learner referred to the panel is connected to a member of staff, the Head of AP tells the panel.

13. The SWMC's independence

SWMC members declare any relationship with Care Cove staff, learners' families or Care Cove's other services. A member with a conflict on an item, such as an audit, complaint review or allegation, steps back from it. Where the SWMC Chair is conflicted, another SWMC member leads.

14. Dealing with a conflict

1. Declare it in writing, or at the start of the meeting.

2. Record it in the register and, where relevant, the minutes.

3. Step back from discussion and decisions it affects.

4. Independent decision. Someone without the conflict decides how to manage it: the Director for staff, the SWMC Chair for the Director and managers, and the SWMC for its own members.

5. Manage and monitor. Options include no further action, safeguards such as a second sign-off, removing the person from the activity, or ending the interest.

15. Breaches

Failing to declare an interest, or taking part in a decision despite a conflict, is a disciplinary matter for staff and may lead to an SWMC member being removed. Any decision affected is reviewed. Where a contract is affected, the Director (or SWMC Chair) tells the commissioning local authority's contract manager, and any suspected bribery or fraud is handled under the Anti-Bribery and Anti-Corruption policy.

16. Monitoring and review

The SWMC reviews the full register of interests and the related-party transactions record every year, and arrangements with Dreams Are Real CIC termly. This policy is reviewed every year, or sooner after a breach, a change in law or a contract change.

17. Related policies

• 22 Anti-Bribery and Anti-Corruption
• 23 Modern Slavery and Ethical Sourcing
• 04 Whistleblowing
• 21 Staff Code of Conduct
• 02 Safer Recruitment
• 03 Managing Allegations Against Staff and Low-Level Concerns
• 17 Data Protection, Retention and Information Sharing
• 30 Referrals, Admissions and Ending Placements

Document control and ratification

This policy is signed off by the Designated Safeguarding Lead and the Head of Alternative Provision, and ratified by the Social Work Management Committee. It is reviewed every year, or sooner after an incident or a change in law, statutory guidance or contract requirements, and it is available to any commissioning local authority on request.