Conflict of Interest Policy

Adopted: 1st July 2026
Next Review Due: 30th June 2028 (or earlier if required)
Responsible Officer: Director (Governance Lead) – Jay Acharya

1. Purpose
Preston City Mela CIC is committed to promoting community cohesion, cultural celebration,
inclusion, and public benefit through the delivery of the Preston City Mela and related
community activities, events, projects, and partnerships.

As a community-based organisation that works with volunteers, artists, performers,
community groups, sponsors, funders, suppliers, local authorities, and partner organisations,
it is essential that all decisions are made fairly, transparently, and in the best interests of the
organisation and the communities it serves.

This policy sets out how actual, potential, and perceived conflicts of interest will be
identified, declared, recorded, and managed to protect the integrity, reputation, decision-
making, and community benefit objectives of Preston City Mela CIC.

2. Scope
This policy applies to all Directors, employees, contractors, consultants, project workers,
artists, event staff, volunteers, and any other individuals acting on behalf of Preston City Mela CIC.

The policy applies to all organisational activities, including:
• Planning and delivery of the Preston City Mela and associated events.
• Procurement of goods, services, artists, performers, contractors, and suppliers.
• Recruitment and appointment processes.
• Funding applications and grant management.
• Sponsorship arrangements and commercial partnerships.
• Community engagement activities and outreach projects.
• Awarding of contracts, commissions, opportunities, or funding.
• Any decision made on behalf of Preston City Mela CIC.

The Board of Directors is responsible for interpreting and applying this policy, including determining whether a conflict exists, whether it is material, and how it should be managed.

3. Definition of Conflict of Interest
A conflict of interest arises where an individual’s personal, financial, professional, or other interests could influence, or reasonably be perceived to influence, their judgement,
decisions, or actions on behalf of Preston City Mela CIC.

Conflicts may be:
• Actual – where an interest directly affects a decision.
• Potential – where circumstances could develop into a conflict.
• Perceived – where there may appear to be bias or influence, even if none exists.

PCM CIC also recognises conflicts of loyalty, were competing duties, relationships, or
commitments could affect an individual’s ability to act solely in the organisation’s best
interests.

4. Directors’ Legal Duties
Directors must act in the best interests of Preston City Mela CIC and comply with their duties
under the Companies Act 2006.

Directors must avoid situations where their interest’s conflict, or may conflict, with those of the organisation and must declare any relevant interest in a proposed transaction, arrangement, or decision.

5. Declaration of Interests
All individuals covered by this policy must declare any actual, potential, or perceived conflict
of interest as soon as they become aware of it.

Declarations must be made to the Board or the Governance Lead and recorded in the
Register of Interests.

A Declaration of Interest Form must be completed and submitted to the Governance Lead.
The form outlines the types of interests that must be declared and is included at Appendix
1.

Examples of interests that should be declared include:
• Financial interests, including employment, consultancy work, business ownership,
shareholding, or ownership of property, land, equipment, or other assets that could
benefit from Preston City Mela CIC activities or decisions.
• Relationships with artists, performers, entertainers, exhibitors, stallholders, suppliers,
sponsors, contractors, grant applicants, employees, volunteers, or partner
organisations involved in Preston City Mela CIC activities.
• Involvement in selecting performers, vendors, contractors, suppliers, community
groups, or organisations participating in the Preston City Mela or associated projects.
• Roles held within other charities, CICs, community groups, cultural organisations,
public bodies, businesses, or funding organisations that may partner with, fund,
compete with, or otherwise interact with Preston City Mela CIC.
• Involvement in funding applications, sponsorship arrangements, grant programmes,
commissioning exercises, or procurement processes where a personal connection
exists.
• Gifts, hospitality, sponsorship, donations in kind, discounts, tickets, or benefits
received from suppliers, sponsors, performers, partners, contractors, exhibitors, or
organisations connected with Preston City Mela CIC activities.
• Any other personal, professional, community, political, religious, cultural, or financial
interest that could reasonably be perceived as influencing impartial judgement or
decision-making.

This is not an exhaustive list and should be used as illustrative examples, with other relevant
interests also declared.”

6. Register of Interests
PCM CIC will maintain a Register of Interests containing declared interests relevant to its activities, see Appendix 2

The Governance Lead is responsible for maintaining the register.

Directors must review and confirm their declared interests at least annually, regardless of whether any changes have occurred.

The register is an internal governance document and will only be shared where necessary for governance, regulatory, audit, funding, or legal purposes.

7. Managing Conflicts of Interest
Where a conflict of interest exists, the individual must:
• Declare the conflict immediately.
• Withdraw from any related discussion or decision-making.
• Refrain from influencing the decision directly or indirectly.

The Chair/s may require the individual to leave the meeting while the matter is considered.

Where the conflict relates to procurement, recruitment, funding decisions, commissioning, supplier selection, or contract management, the conflicted individual must not participate in
evaluation, scoring, recommendation, approval, or oversight activities relating to that matter.

All declarations and actions taken must be recorded in meeting minutes.

Where necessary, the Board may seek independent advice to ensure conflicts are managed appropriately and in the best interests of PCM CIC.

8. Quorum and Multiple Conflicts
Where a conflict affects more than one Director, each Director must declare their interest and comply with this policy.

If the number of conflicted Directors prevents the Board from achieving a valid quorum, the matter must be deferred until a quorum can be achieved or alternative governance arrangements can be made in accordance with the Articles of Association.

9. Undeclared Conflicts
Any undeclared conflict identified after a decision has been made must be reported to the Board immediately.

The Board may review affected decisions and determine any corrective action required.

Failure to declare a conflict may result in disciplinary or governance action and may lead to removal from decision-making responsibilities where appropriate.

10. Gifts and Hospitality
As Preston City Mela CIC works closely with community organisations, artists, performers, sponsors, funders, local authorities, businesses, and cultural partners, transparency regarding gifts and hospitality is essential.

All gifts, hospitality, sponsorship, discounts, donations in kind, complimentary tickets, services, or other benefits offered or received in connection with Preston City Mela CIC activities must be declared to the Governance Lead and recorded in the Register of Interests.

Individuals acting on behalf of Preston City Mela CIC must not accept any gift, hospitality, or benefit that could reasonably be perceived as influencing a procurement decision, funding
decision, sponsorship arrangement, performer selection, supplier appointment, contract award, or any other organisational decision.

Where refusal of a gift or hospitality is impractical or could cause offence within a legitimate cultural, ceremonial, or community context, the gift or hospitality must still be declared and recorded, and the Board or Governance Lead will determine any appropriate action.

Gifts, hospitality, sponsorship, discounts, donations in kind, complimentary tickets, services, or other benefits must never influence, or appear to influence, any decision made on behalf
of Preston City Mela CIC.

11. Confidentiality
Individuals acting on behalf of PCM CIC must not use confidential information obtained through their role for personal benefit or for the benefit of another person or organisation.

Confidential information must be handled responsibly and in accordance with applicable data protection requirements.

12. Data Protection
Personal information collected under this policy will be processed in accordance with the Data Protection Act 2018 and UK GDPR.

Information will be used only for governance and compliance purposes, stored securely, and retained only for as long as necessary.

13. Board Adoption
This policy is approved and adopted by the Board of Directors of Preston City Mela
Community Interest Company (PCM CIC).

The Board will review this policy annually and update it where necessary.