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Conflicts of Interest Policy

Centre: ACLAS Global International Education Group

Effective: 2025-07-05 | Review Date: 2026-07-05

Policy Owner: Centre Director

1. Purpose

This policy ensures that all assessment and quality assurance decisions made by ACLAS Global International Education Group are free from bias, and that any actual, potential, or perceived conflicts of interest are identified, declared, and managed appropriately.

2. Scope

This policy applies to all individuals involved in the delivery, assessment, or internal quality assurance of OTHM qualifications, including employees, contractors, and volunteers.

3. What Is a Conflict of Interest?

A conflict of interest exists when an individual's personal interests, relationships, or loyalties could influence—or reasonably be perceived to influence—their professional judgment. Examples:

  • Personal relationships: Assessing the work of a family member, partner, close friend, or business associate
  • Financial interest: Holding a financial stake in a learner's business, or receiving payment from a learner outside the Centre's fee structure
  • Dual roles: An IQA reviewing their own assessment work, or reviewing the work of a unit they taught
  • Employment: Assessing a current or former colleague or employee
  • Gifts: Accepting gifts, hospitality, or favours from a learner that could be perceived as influencing an assessment decision

4. The IQA–Assessor Separation

OTHM requires that an IQA must not be involved in the delivery or assessment of any unit they quality-assure. At ACLAS, this means:

  • The Lead IQA does not teach or assess any unit they will later sample.
  • Where the Centre's small size makes complete separation difficult, the Centre:

- Ensures affected assessments undergo heightened IQA scrutiny

- Declares the arrangement to OTHM

- Ensures OTHM's EQA activity covers those assessments

5. Declaration

  • All staff complete a Conflicts of Interest Declaration Form upon appointment.
  • Staff update their declaration immediately if a new conflict arises.
  • All staff reconfirm their declaration annually.

Declarations are submitted to the Centre Director and kept on the staff member's personnel file.

6. Managing Declared Conflicts

When a conflict is declared, the Centre decides on the appropriate management strategy. Options include:

  • Reassigning the learner to a different Assessor
  • Arranging for the assessment to be second-marked by another qualified Assessor
  • Increasing the IQA sampling rate for the affected assessments
  • Removing the staff member from decision-making on the matter

The decision is recorded in writing and communicated to the individuals affected.

7. Unavoidable Conflicts

In the rare case where a conflict cannot be avoided despite all reasonable steps:

  • The affected assessment is subjected to additional IQA review
  • The conflict is declared to OTHM
  • The assessment is included in the sample submitted for EQA

8. Consequences of Non-Disclosure

Failure to declare a conflict of interest is a serious matter. Consequences may include:

  • Investigation under the Malpractice and Plagiarism Policy
  • Disciplinary action up to and including termination of contract
  • Notification to OTHM

9. Record Keeping

All declarations and management decisions are retained for a minimum of 3 years.

10. Policy Review

This policy is reviewed annually.

Approved by: ______________________ (Centre Director)

Date: ______________________