1. Reason for Policy:
The Anaphylaxis Campaign (TAC) acknowledges the contribution and impact volunteers have on society through their involvement in organisations. TAC recognises the historic and on-going role that volunteers play in the work it carries out both locally and nationally.
TAC is committed to involving volunteers in all aspects of its activity. We have developed a volunteering policy to provide a framework for the involvement of volunteers in our work and in meeting our aims.
TAC is committed to continuous improvement and working within recognised good practice framework, as far as our capacity reasonably allows.
2. Policy Statement:
TAC values the contribution that volunteers can make to our organisation. They help reflect the diverse interests, needs and resources of the communities we aim to serve and bring a unique perspective to our work. We recognise volunteers as a core part of our team, with a distinctive but complementary role alongside paid staff.
TAC recognises that volunteering is a two-way process that provides us with the benefits of the skills, experience and enthusiasm that volunteers bring and provides volunteers with opportunities to further enhance or develop skills, gain experience of new working environments and gain personal benefits from the volunteering experience. We are committed to managing and supporting volunteers in a way that ensures that the needs of both parties are met, as far as our capacity reasonably allows.
TAC strives to create a diverse and inclusive organisation; we are therefore committed to ensuring equality of access to high quality volunteer opportunities and equality of treatment for our volunteers in all our policies and practices.
3. Principles Statement:
TAC recognises four principles fundamental to volunteering. These are Choice, Diversity, Mutual Benefit and Recognition. These inform every aspect of our volunteer policy and programme:
Choice – volunteering must be a choice freely made by each individual. Freedom to volunteer implies freedom not to become involved.
Diversity – volunteering should be open to all, no matter what their background, race, colour, nationality, religion, ethnic or national origins, age, gender, marital/partnership status, sexual orientation or disability.
Mutual Benefit – volunteers offer their contribution and skills unwaged but should benefit in other ways in return for their contribution. Giving time voluntarily must be recognised as establishing a reciprocal relationship in which the volunteer also benefits and feels that his or her contribution is personally fulfilling.
Recognition – explicit recognition that valuing the contribution of volunteers is fundamental to a fair relationship between volunteers and TAC. This includes recognising the contribution to the organisation, the community, the social economy and wider social objectives.
TAC recognises that the success of its volunteer policy and programme is dependent on the active support of all parts of the organisation.
Board – the Board has overall responsibility for ensuring that the Volunteering Policy and programme meet the needs of TAC, are implemented effectively and reviewed at appropriate intervals.
Management – the Chief Executive has operational responsibility for ensuring that all of the policies and related programmes/ procedures are implemented effectively. The Chief Executive will designate a senior member of staff to have responsibility for the implementation and management of the volunteer policy and programme.
Staff – all staff are responsible for ensuring that this policy, related procedures and other aspects of the volunteering programme are implemented effectively within their projects/services, with any volunteers they supervise and in any other areas of their work.
Volunteers – all volunteers are responsible for ensuring that this policy is implemented effectively within the volunteering roles they are undertaking.
TAC recognises that anyone has the right to apply to become a volunteer
Advertisements for volunteers will be placed where they will be available to the wider community for example on the internet, in the Anaphylaxis Campaign magazine or by direct mail.
Volunteers will need to speak to the relevant member of staff before being taken on and may need to fill in an application form and attend a more formal interview.
Volunteers will be recruited on the basis that they are to complement the work of paid employees not replace them.
Volunteers must only perform those functions that are within their personal range of competence and the volunteer remit as agreed by TAC.
All volunteers must agree with and sign the volunteer agreement.
6. Volunteer Agreement
TAC recognises that volunteers need a clear understanding of their role, tasks and the responsibilities attached before making a commitment. Each potential volunteer will be given sufficient information in order to allow them to make an informed decision.
This information will include a task description, this policy, the volunteer agreement, the grievance procedure and any other information that becomes relevant at a given time as decided by the relevant member of TAC staff.
Volunteers will be required at all times to respond to the directions of the project or staff member. Volunteers remain accountable for their actions to the management team who have oversight of the volunteers work. The manager has the right to require the volunteer to leave the project at any time. Should the volunteer wish to appeal against the manager’s action, this should be submitted to the Volunteer Coordinator.
Should a volunteer wish to raise a complaint against the management team they should do so through the Anaphylaxis Campaign grievance procedure.
7. Supervision and Support
Appointed Volunteer Coordinators will, in conjunction with project and team staff, provide the supervision and support that volunteers will need to maintain motivation and commitment.
A reasonable level of support will be provided for all volunteers.
All matters of concern, including those relating to personal safety, within the working environment should be reported to a member of the project or staff team in the first instance by the volunteer.
TAC will provide adequate insurance cover for individuals engaged as volunteers.
Where necessary, volunteers will agree to a relevant DBS check (Disclosing and Barring Service) and/or sign a child protection agreement.
Any concerns held by the volunteer on the issue of Health and Safety should be referred to the correct member of staff at the AC.
Volunteers will be reimbursed for any actual expenses incurred during the performance of their tasks where authorisation for such expenditure has been agreed in advance.
9. Intellectual Property
Should a volunteer be working on a project which could lead to a copyright being created (e.g. a database or a publication), any copyright created will be assigned to the Anaphylaxis Campaign.
10. Employment Standing
Whilst recognising the role and value of volunteers in the work of TAC, it is clearly stated that there is no intention, either implied or assumed, that TAC is entering into any form of employment contract with volunteers engaged on our behalf.
Arrangements made by the volunteer and TAC are seen as mutually beneficial, fulfilling needs on both sides and providing valuable experience to both parties. No additional payments beyond definite agreed expenses, confirmed by receipts and vouchers supplied by the volunteer will be paid.
It is also recognised by TAC that the volunteer will retain absolute freedom of choice in the giving of their time and skill to its various projects. TAC recognises that on occasion, unforeseen circumstances may occur that will prevent the volunteer from keeping their commitment to a particular project. In these circumstances, it is asked that as much notice as possible be given so that alternative arrangements can be made.
TAC recognises that its Board members are volunteers. However, where a Board member is acting purely within that role description they are covered by separate Board policies in recognition of that unique role and the statutory obligations placed on them by Charity and Company law. When Board members are undertaking other voluntary activity within TAC their involvement is covered by this policy.
This policy will be reviewed by the Board every three years.
Volunteer Grievance Procedure
Volunteers are not covered by employment or equal opportunities legislation, so the Campaign has a problem-solving procedure which helps to ensure that volunteers are treated fairly and are not discriminated against.
This problem-solving procedure sets out how problems will be dealt with by the Campaign when they arise, and help to find the most appropriate solution to a problem.
The Anaphylaxis Campaign will:
- Treat all complaints confidentially
- Allow enough time for meetings to take place and set realistic timeframes
- Keep complainants informed at each step of the procedure
- Reassure any clients involved that a complaint will not affect their right to use the service
- Ensure that volunteers have the right to be accompanied by a colleague, friend or representative in any of the meetings following on from the initial oral complaint.
If a volunteer makes a complaint
This part of the problem-solving procedure gives the volunteer the opportunity to complain if they have been unfairly treated or if they have an issue or a cause for concern within the organisation.
Stage 1: Oral Complaint
The volunteer should discuss their concerns with the Volunteer Co-ordinator, or if this is not appropriate the matter should be referred to that person’s manager. Every effort will be made to resolve the matter at this stage. If the matter cannot be resolved at this stage then the volunteer should proceed to Stage 2.
Stage 2: In Writing
The volunteer should make a formal complaint in writing to the Volunteer Co-ordinator, or if this is not appropriate to that person’s manager. The volunteer should make the formal complaint within a month of the oral complaint, to which the Volunteer Co-ordinator (or manager) will reply in writing within a month, to allow for investigations or absences.
Stage 3: Opportunity to Appeal
If the volunteer is not satisfied with the outcome, then they can appeal to the Chief Executive or their nominee. The appeal to the Chief Executive should be made within one month of the written response. The Chief Executive will arrange to see the volunteer within one month. The volunteer can have a person present with them at this meeting. The Chief Executive will respond in writing within one month and their decision will be final.
If someone complains about a volunteer
This part of the problem solving procedure gives the volunteer the opportunity to be told why a complaint has arisen, the opportunity to state their case and the chance to appeal.
Stage 1: Oral discussion
The first step is for the Volunteer Co-ordinator to discuss the complaint with the volunteer and establish their view of the issue. The Volunteer Co-ordinator should establish whether any external factors are affecting the volunteer’s ability to carry out tasks, their behaviour or their attitude. The Volunteer Co-ordinator should identify goals that will help the volunteer to fulfil their role, and offer extra support, supervision and training where necessary. The Volunteer Co-ordinator should then agree a deadline for reviewing the situation with the volunteer.
If the complaint was raised by someone else, the Volunteer Co-ordinator should keep them informed of the measures being taken to rectify the situation.
Stage 2: Written Documentation of complaint and discussion
If the matter hasn’t been resolved by Stage 1, the Volunteer Co-ordinator will issue the volunteer with a written document outlining the reason for the complaint. The volunteer will be invited to state their case to the Volunteer Co-ordinator. The volunteer can choose to be accompanied by a person of their choice. Depending on the nature of the complaint, this may be used as an opportunity to set further objectives for the volunteer, or to offer training or other support. However, if at this stage the Volunteer Co-ordinator decides that the volunteer should be asked to leave, the volunteer will be given the chance to appeal.
Stage 3: Opportunity to appeal
When a volunteer has been asked to leave, they may appeal in writing to the Chief Executive within a month. The Chief Executive will arrange to see the volunteer within a month. The volunteer can have a person present with them at this meeting. The Chief Executive will respond in writing within a month and their decision will be final.
Temporary or Permanent Cessation of Volunteering
There are some occasions when volunteers will immediately have to cease volunteering, either permanently or on a temporary basis while an investigation is carried out. These include, but are not limited to gross misconduct, e.g. theft, assault, acts of violence, malicious damage, deliberate falsification of documents, harassment or being under the influence of drink or drugs. The decision to temporarily suspend a volunteer will be confirmed to the volunteer in writing and, in some cases, legal proceedings may need to be concluded before the next step in the problem solving procedure may take place.
This document sets out the policy and procedures of the Anaphylaxis Campaign against fraud and other forms of dishonesty, together with the steps that must be taken where any of these practices is suspected or discovered.
It applies to Trustees Directors, staff and volunteers. Anybody associated with the Campaign who commits fraud, theft or any other dishonesty, or who becomes aware of it and does not report it, will be subject to appropriate action.
Statement of intent
The Anaphylaxis Campaign will continually strive to ensure that all its financial and administrative processes are carried out and reported honestly, accurately, transparently and accountably and that all decisions are taken objectively and free of personal interest. We will not condone any behaviour that falls short of these principles.
All members of the organisation have a responsibility for putting these principles into practice and for reporting any breaches they discover.
A deliberate intent to acquire money or goods dishonestly through the falsification of records or documents. The deliberate changing of financial statements or other records by either; a member of the public, someone who works or is a volunteer for the Campaign. The criminal act is the attempt to deceive and attempted fraud is therefore treated as seriously as accomplished fraud.
Dishonestly acquiring, suing or disposing of physical or intellectual property belonging to the Campaign or to individual members, supporters or clients of the Campaign.
Misuse of Equipment:
Deliberately misusing materials or equipment belonging to the Campaign.
Abuse of Position:
Exploiting a position of trust within the organisation.
Anaphylaxis Campaign fosters honesty and integrity in its entire staff. Directors, staff and volunteers are expected to lead by example in adhering to policies, procedures and practices. Equally, members of the public, service users and external organisations (such as suppliers and contractors) are expected to act with integrity and without intent to commit fraud against the Campaign.
As part of the culture, the Campaign will provide clear routes by which concerns can be raised by Trustees Directors, staff and volunteers and by those outside of the Charity. A copy of the Campaign’s whistleblowing policy is available to Trustees, staff and volunteers, and to service users, suppliers and other third parties on request.
Senior management are expected to deal promptly, firmly and fairly with suspicions and allegations of fraud or corrupt practice
In relation to the prevention of fraud, theft, misuse of equipment and abuse of position, specific responsibilities are as follows:
The Trustee Directors are responsible for establishing and maintaining a sound system of internal control that supports the achievement of the Campaign’s policies, aims and objectives.
The system of internal control is designed to respond to and manage the whole range of risks that the Campaign faces.
The system of internal control is based on an on-going process designed to identify the principal risks, to evaluate the nature and extent of those risks and to manage them effectively. Managing fraud risk is seen in the context of the management of this wider range of risks.
The Chief Executive Officer (CEO):
Overall responsibility for managing the risk of fraud has been delegated to the CEO. The responsibilities include:
Undertaking a regular review of the fraud risks associated with each of the key organizational objectives. • Establishing an effective anti-fraud response plan, in proportion to the level of fraud risk identified (see p4).
The design of an effective control environment to prevent fraud.
Establishing appropriate mechanisms for: o reporting fraud risk issues o reporting significant incidents of fraud or attempted fraud to the Board of Trustee Directors;
Liaising with the Treasurer and if appropriate Auditors.
Making sure that all staff are aware of the Charities Anti-Fraud Policy and know what their responsibilities are in relation to combating fraud; Ensuring that appropriate anti-fraud training is made available to Trustee Directors, staff and volunteers as required; and
Ensuring that appropriate action is taken to minimize the risk of previous frauds occurring in future.
Senior Management Team:
The Senior Management Team is responsible for:
Ensuring that an adequate system of internal control exists within their areas of responsibility and that controls operate effectively;
Preventing and detecting fraud as far as possible;
Assessing the types of risk involved in the operations for which they are responsible; • Reviewing the control systems for which they are responsible regularly;
Ensuring that controls are being complied with and their systems continue to operate effectively; and
Implementing new controls to reduce the risk of similar fraud occurring where frauds have taken place.
Staff and Volunteers:
Every member of staff or volunteer is responsible for:
Acting with propriety in the use of Campaign’s resources and the handling and use of funds whether they are involved with cash, receipts, payments or dealing with suppliers;
Conducting themselves in accordance with the values and behavior principles set out above;
Being alert to the possibility that unusual events or transactions could be indicators of fraud;
Alerting their manager when they believe the opportunity for fraud exists e.g. because of poor procedures or lack of effective oversight;
Reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events; and
Cooperating fully with whoever is conducting internal checks or reviews or fraud investigations.
Detection and Investigation
Whilst having regard to the requirements of the Data Protection legislation, the Campaign actively participates in an exchange of information with external agencies on fraud and corruption. It is often the alertness of Directors, staff or volunteers and the general public to the possibility of fraud and corruption that leads to detection of financial irregularity.
The Chair of the Board of Trustee Directors and Treasurer must be notified immediately of all financial or accounting irregularities or suspected irregularities or of any circumstances which may suggest the possibility of irregularities including those affecting cash, stores, property, remuneration or allowances.
Reporting of suspected irregularities is essential as it:
Facilitates a proper investigation by experienced staff, and ensures the consistent treatment of information regarding fraud and corruption.
When so notified, the Chair/Treasurer will instigate an investigation by appointing a designated officer, auditor or other adviser.
The designated officer, auditor or other advisor will:
- deal promptly with the matter
- record evidence received
- ensure the security and confidentiality of evidence
Work closely with senior managers of the Campaign and other agencies, such as the Police and Courts to ensure that all issues are properly investigated and reported upon.
Ensure maximum recoveries are made on behalf of the Campaign, and assist the senior managers to implement the Campaign’s disciplinary procedures where considered appropriate (referral to the Police will not prohibit or restrict action under the Disciplinary Procedure).
In cases of suspected payroll irregularities where a fraud investigation may be possible, discussion will occur between the Chair and the CEO if it is thought a disciplinary investigation is more appropriate . Malicious accusations may be the subject of disciplinary action.
An important contribution to the continuing success of an anti-fraud strategy, and its general credibility, lies in the effectiveness of programmed awareness/training, of Directors staff and volunteers throughout the organization.
This will be achieved through the development of both induction and awareness training for all personnel involved in internal control systems to ensure that their responsibilities and duties in this respect are regularly highlighted and reinforced.
This policy will be reviewed every 3 years.
Some examples of the types of fraud and financial crime to which charities may be susceptible include:
- misuse of the charity’s bank account
- fraudulent credit or debit card transactions or charges
- stealing or ‘skimming-off’ money from cash collections
- fake fundraising events and requests for donations
- fake grant applications
- the creation of false invoices or purchase orders
- falsely claiming for the provision of services to beneficiaries who do not exist
- using the charity’s databases or inventories for personal profit or unauthorised private commercial use
- the creation of false employees or inflated expenses, overtime or other claims
- other forms of identity fraud
All charities must, as a minimum:
Have some form of appropriate internal and financial controls in place to ensure that all their funds are fully accounted for and are spent in a manner that is consistent with the purpose of the charity.
Keep proper and adequate financial records for both the receipt and use of all funds together with audit trails of decisions made. Records of both domestic and international transactions must be sufficiently detailed to verify that funds have been spent properly as intended and in a manner consistent with the purpose and objectives of the organisation.
Deal responsibly with incidents when they occur, including prompt reporting to the relevant authorities and ensuring the charity’s funds are secure
The Campaign has a system of financial controls which should minimise the risk of fraud. In addition to the annual auditing of the Campaign’s accounts, the Business Manager and Hon. Treasurer undertake the Charity Commission’s internal financial controls checklist annually.
There are various forms of financial fraud that staff may need to be aware of:
Using charities to validate stolen or cloned credit cards
Fraudsters may use stolen or cloned credit cards to make small online donations through charity websites. Their purpose in doing this is to check whether a stolen card has been blocked or cancelled. If the ‘test’ donation works the card will be used for more widespread fraud.
To help prevent this, charity staff may be able to identify some of the following patterns:
- fraudsters typically donate a small, token amount, eg £1. (Note, however, that there might be a large number of relatively small donations during appeals for humanitarian disaster relief or in
- the approach to Christmas)
- one card may be used a number of times in succession, to check it is still unblocked
- the name of the donor may not match the cardholder’s name. Some fraudsters will put random characters into mandatory name and address fieldsOn identifying this kind of risk it may be
- possible to take some preventive measures, such as:
- carrying out address checks for large donations
- checking that the CVC number (last 3 digits on the back of the card) tallies with the individual’s details
- checking the internet provider address from where the donation is being attempted. Suspicious or problematic internet provider addresses can be blocked and blacklisted
- using systems such as ‘Capture’ which require the donor to manually input details
- reporting suspected fraudulent activity to the police and bank immediately
- having an anti-fraud email address in place so that donors can report direct to the charity any suspicious activity and possible scam emails
- ensuring that all emails sent to donors direct them to the charity’s website, without using a link if possible
Fraudsters have been known to set up false charity websites, with the appearance of genuine ones, in order to obtain credit card and personal details of unwitting donors. In doing so they frequently infringe trademark, logos and UK copyright laws in addition to financial crime. The Commission advises charities to provide the following advice to donors or customers who are proposing to make donations through websites, and this is also good advice for staff as well, in spotting potential scam emails / websites:
Avoiding e-crime and spoof websites:
always update your information online by using the process you have used before, or open a new browser window and type in the website address of the legitimate organisation’s account maintenance page
be wary of unfamiliar website addresses, as they may not be genuine. Only use the address that you have used before, or start at your normal homepage. Avoid unfamiliar links or popup screens always report fraudulent or suspicious emails to your Internet Service Provider (ISP). This will help to ensure that bogus websites are shut down before they can do further harm
take note of the header address on the website. Spoof sites are more likely to have an excessively long line of characters in the header, with the business name somewhere in the string.
Many secure sites have padlock symbols and other secure technology to look out for
if you have any doubts about an email or website, make a copy of its address and send it to the legitimate business to check whether it is genuine
If you discover, or suspect, that the Campaign may be a victim of this type of scam, the Commission recommends that we contact the ISP which is hosting the spoof website and request that the site be taken down as quickly as possible
‘Phishing’ is a type of e-crime which involves fraudsters sending emails to many, sometimes thousands, of recipients asking them to disclose sensitive or confidential information. The fraudsters are usually based overseas and may be almost impossible for the UK authorities to trace. Typically, the phishing email is made to look like a genuine email from a bank, and it may ask the recipient to confirm information such as account usernames or passwords because, it claims, there has been a security problem with the bank’s computer system. In many cases the phishing email will contain a link to another website into which the recipient is asked to enter the confidential information. Phishing scams cost fraudsters very little to set up, and they can make a profit if only a few people in every thousand actually provide information that then results in their bank accounts being emptied.
Further information is available from: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/571159/Chapter3.pdf
Conflict of Interest Policy
The Anaphylaxis Campaign has issued a conflict of interest policy to all trustees upon appointment. The purpose of this paper is to remind trustees of their obligations regarding this. These issues become particularly pertinent for both trustees and staff of the Campaign as new ventures are taken forward. This policy applies to trustees and also to staff.
2. What is a conflict of interest and what issues does it raise?
A conflict of interest is any situation in which a trustee or member of staff’s personal interests, or interests which they owe to another body and those of the charity arise simultaneously or appear to clash. Even the appearance of a conflict of interest can damage the reputation of the charity, so conflicts need to be managed carefully.
3. Why we have a policy
Trustees have a legal obligation to act in the best interests of the Anaphylaxis Campaign, and in accordance with the Anaphylaxis Campaign’s governing document.
Conflicts of interests may arise where an individual’s personal or family interests and/or loyalties conflict with those of the Anaphylaxis Campaign. Such conflicts may create problems; they can:
Inhibit free discussion;
Result in decisions or actions that are not in the interests of the Anaphylaxis Campaign; and
Risk the impression that The Anaphylaxis Campaign has acted improperly.The aim of this policy is to protect both the organisation and the individuals involved from any appearance of impropriety.
4. The declaration of interests
Accordingly, the Campaign expects all trustees and staff to declare their interests, and any gifts or hospitality received in connection with their role in the Anaphylaxis Campaign. A declaration of interests form is provided for this purpose, listing the types of interest that should be declared (see Appendix 1).
To be effective, the declaration of interests needs to be updated at least annually and also when any changes occur.
If trustees or members of staff are not sure what to declare, or whether/when their declaration needs to be updated, they need to err on the side of caution. Clarification and confidential guidance can be sought from the Chief Executive or Business Manager.
Interests will be recorded on the charity’s register of interests, which will be maintained by the Campaign’s Business Manager. The information provided will be processed in accordance with data protection principles as set out in the Data Protection Act 1998. Data will be processed only to ensure that trustees act in the best interests of the Anaphylaxis Campaign. The information provided will not be used for any other purpose.
5. Identification of a conflict of interest
Conflicts of interest may come in a number of different forms:
Direct financial gain or benefit to a trustee such as payment for services provided to the charity.
The award of a contract to another organisation in which a trustee has an interest and from which a trustee will receive a financial benefit.
The employment of a trustee in a separate post within the charity, even when the trustee has resigned in order to take up the employment.
Indirect financial gain, such as employment by the charity of a spouse or partner of a trustee, where their finances are interdependent.
Non financial gain, such as when a user of a trustee’s services is also a trustee.
Conflict of loyalties, such as where a trustee is appointed by one of the charities funders or where a friend of a trustee is employed by the charity.
6. The management of situations where conflicts of interest occur
Trustees who are users of the Campaign’s services, or the carer of someone who uses the Campaign’s service should not be involved in decisions that directly affect the service that the person, or the person they care for, receives. They should declare their interest at the earliest opportunity and withdraw from subsequent discussion. The same applies to a conflict for any other reason. It is important that all such actions are recorded.
Trustees may, however, participate in discussions from which they indirectly benefit, for example, where the benefits are universal to all users, or where your benefit is minimal.
It is expected that trustees or staff members will declare any private interest which they have in an item to be discussed before any discussion of the item itself. If trustees fail to declare an interest that is known to the Chief Executive, the Business Manager and/or the Chairman of the Board, the Business Manager or Chairman will declare that interest.
7. Decisions taken where a trustee or member of staff has an interest.
In the event of the board having to decide upon a question in which a trustee or member of staff has an interest, all decisions will be made by vote, with a simple majority required. A quorum must be present for the discussion and decision; interested parties will not be counted when deciding whether the meeting is quorate. Interested board members may not vote on matters affecting their own interests.
All decisions under a conflict of interest will be recorded by the Business Manager and reported in the minutes of the meeting. The report will record:
• The nature and extent of the conflict
• An outline of the discussion
• The actions taken to manage the conflict
Where a trustee benefits from the decision, this will be reported in the annual report and accounts in accordance with the Charities SORP FRS 102.
A de minimise exception applies to contracts less than £100 in value. Random checks against the register of interest will be made on the award of contracts below this value. If the cumulative value of a series of small contracts exceeds £500, the trustees will operate the policy used for individual contracts over that sum.
The de minimise exemption does not apply to contracts of employment with the Campaign.
Independent external moderation will be used where conflicts cannot be resolved through the usual procedures.
8. Managing contracts
If trustees have a conflict of interest, they must not be involved in managing or monitoring a contract in which they have an interest. Monitoring arrangements for such contracts will include provision for an independent challenge of bills and invoices and termination of the contract if the relationship is unsatisfactory.