1 Purpose and scope
This policy protects the integrity of the Association’s decisions and funds and the trust of beneficiaries and donors. It applies to members, the Board, committees, employees, volunteers and advisers participating in its work or decisions. It is applied under current legislation, particularly Federal Decree-Law No. 50 of 2023 regulating public-benefit institutions and its Executive Regulation under Cabinet Resolution No. 5 of 2025, and the Articles of Association. Higher-ranking provisions prevail in a conflict. (1)
2 Conflicts and prohibitions
A conflict arises when a private interest affects, could affect or appears to others to affect impartiality. It includes financial or professional interests, ownership, partnerships and relationships by blood or marriage up to the fourth degree. Any other relationship that could affect a decision must also be disclosed.
Using position or information for private benefit, accepting a gift, commission or service to influence a decision, or participating in assessment, approval or payment involving an interest of the person, relatives or an affiliated entity is prohibited. Disclosure does not authorise a prohibited act. The gift prohibition excepts customary symbolic gifts or ordinary courtesies not intended to influence decisions and not exceeding a modest value set by the Association, provided they are entered in the gifts register.
3 Disclosure and suspension of participation
Persons covered submit a declaration at the start of their role, renew it annually and update it immediately when a new interest arises. For a specific matter, they notify the Secretary and the chair of the body considering it in writing before participating, identifying the relationship, benefit, matter and parties. Disclosure through official email is accepted and retained in the register.
The interested person immediately stops unnecessary access, discussion, assessment, voting, signing or influencing others on the matter until the competent authority decides. Disclosure is recorded when discussion of the item begins even if previously submitted in writing. (2)
4 Assessment and decision
The chair of the competent body examines the disclosure with disinterested members. Board-related or disputed cases are referred to the Board without the interested person’s participation. If the Chair has the conflict, the disinterested Vice-Chair manages the item without acquiring approval powers they do not otherwise hold.
The competent body records the action in writing: no conflict, with reasons; recusal and appointment of an independent replacement; or suspension where the conflict cannot be controlled. A related-party transaction is approved only if it is permissible in the first place, benefits the Association, has fair terms and meets required authority and approvals.
The interested person leaves the discussion and vote. The Secretary records disclosure, departure, return, participants, the response decision and reasons. Quorum and voting validity are checked against the Articles. If recusal creates a validity issue, the item is suspended for legal review rather than resolved by attendees’ discretion.
5 Register and confidentiality
The Secretary maintains a conflicts register, with a case number, disclosure date, discloser’s capacity, parties, relationship, benefit, transaction, recusal, decision-maker, decision date and reasons, appointed replacement and follow-up outcome. It is linked to the declaration, correspondence and meeting minutes. Annually, the Association prepares a statement of work and contracts in which Board members, senior employees or related persons have an interest, identifying names, nature, terms, duration and value. If there are none, that fact must be disclosed.
Disclosures are available only to those assigned to manage and oversee them and to competent authorities. They are retained with decision records for required periods, with destruction suspended for complaints, investigations or disputes. Unnecessary health or personal information must not be included. Personal data is processed under Federal Decree-Law No. 45 of 2021 on Personal Data Protection.
6 Reporting, accountability and review
Breaches are reported to the Secretary and Board Chair, or to the Vice-Chair when either is the subject. Retaliation against good-faith reporters is prohibited. Facts are examined confidentially and the person heard. The competent authority acts under the Articles and applicable rules; this policy neither imposes automatic penalties nor itself removes a member. The Association provides the competent authority with requested information and documents concerning material conflicts as required by current legislation.
The Secretary reviews implementation annually and presents findings and amendments to the Board. The policy complements Board, committee, procurement, assistance, HR and data-protection regulations. No subordinate procedure may weaken a prohibition imposed by a higher-ranking source.
References in the approved document
- The Association’s approved 2026 Articles of Association, Articles 10, 20, 73 and 74. This document sets internal implementation controls without changing a higher-level legal requirement or competence.
- The Association’s approved 2026 Articles of Association, Articles 20 and 73. Disclosure, recusal and registers are implementation controls and do not change quorum or competence. This document sets internal implementation controls without changing a higher-level legal requirement or competence.