Conflict of interest policy

In this policy:

• Scope
• Introduction
• Definition
• Disclosure and review
• In-house providers/employers Approved Training Organisations
• Appendix 1: Exemplar recording document

1. Scope

All activity carried out by CITB’s Approved Training Organisations (ATO) and approved centre network including Site Safety Plus (SSP), Construction Plant Competence Scheme (CPCS) and Internet Test Centres (ITC).  Including but not limited to the following relationships:

• Senior quality consultant or CITB representative that has an interest or history with a centre or Approved Training Organisation;
• Senior quality advisor or CITB representative that has a relationship with an individual at a centre or Approved Training Organisation (ATO);
• Centre staff who have a relationship with a candidate, delegate or operative;
• Centre staff who have a relationship with each other;
• Centre staff that have a commercial interest in the assessment outcome.

2. Introduction

CITB works with a number of Approved Training Organisations (ATOs) and centres and has links with other bodies, whether CITB departments, commerce, industry, and others.

It is possible that these links may give rise to potential conflicts of interest. CITB is therefore prepared through this policy to detail how conflicts of interest will be managed and reported by CITB and what Approved Training Organisations and centres must do to be compliant.

This policy has been developed to ensure the integrity of courses, cards, tests and assessments assured by CITB are upheld. 

3. Definition

It is not possible to provide a comprehensive definition of the kind of circumstances which will give rise to a conflict of interest, but the following are examples of the most likely situations that will lead to perceived conflicts of interest.

In any situation where an employee is uncertain as to the propriety of a given arrangement, advice should be sought from the Quality and Verification Manager at CITB.

A conflict of interest may be defined generally in two areas: CITB staff, and Approved Training Organisations and centres.

CITB staff

A conflict between an official CITB representative and any other interests the particular individual may have: for example, where the individual may be in a position to influence CITB  business for actual or potential personal benefit, or for that of a close family member, to seek such benefits at the expense of CITB.

Conflicts of interest are not restricted to cases in which an individual actually derives some advantage. They also arise and can be equally damaging where a conflict exists or appears to exist without any consequential behavioural impact.

CITB policy on conflicts of interest does not imply any lack of trust in its staff.  Moreover, it is designed to protect them against criticism by ensuring that they recognise and disclose such conflict situations, and take steps to avoid and/or manage the situations as they arise.

Approved Training Organisations (ATO) and centres

A conflict between the ATO/centre and their delegates/candidates where the centre staff and candidate have a personal relationship which could weaken the assessment/testing/training and quality assurance process, and the integrity of certificates/cards and outcomes subsequently issued.

Additionally, the conflict could arise if the centre staff involved in the assessment/testing/training and quality assurance  process are related, and in a position to influence CITB business for actual or potential professional or personal benefit through its activity.

Conflicts of interest are not restricted to cases in which an individual actually derives some advantage. They also arise and can be equally damaging where a conflict exists or appears to exist without any consequential behavioural impact.

CITB policy on conflicts of interest does not imply any lack of trust in its approved training organisations/centres. Moreover, it is designed to protect them against criticism by ensuring that they recognise and disclose such conflict situations and take steps to avoid and/or manage them as they arise.

4. Disclosure and review

The following outlines the responsibilities of the parties involved in resolving the conflict(s).

CITB staff

It is the duty of all employees of CITB to disclose any actual or potential conflict of interest. Any employee who believes they have a conflict or potential conflict of interest should consult their line manager or the quality assurance manager.

Conflicts of interest should be reported to the line manager and the quality and verification manager immediately. The record of disclosure shall cover:

• the type of potential conflict;
• the nature of the activity;
• a description of all parties involved;
• the potential financial interests and rewards; and
• any other information which the employee feels necessary to evaluate the disclosure.

In the light of any disclosure, the Quality and Verification Manager may need to consult the Head of Products as appropriate.

After appropriate evaluation, it may be determined that a proposed or ongoing agreement and the employee’s personal interests show no conflict or apparent conflict and are acceptable without further review.

Conversely, it may be determined that some questions of propriety requiring a higher level of review have been identified. For each situation, the conflict register must be completed to demonstrate due diligence has been exercised and the conflict managed.

Approved Training Organisations (ATOs)/centres

If the conflict directly impacts on

• assessment;
• testing;
• training;
• quality assurance activity; or
• administration requirements (certification, claiming of funding, claiming of learning outcomes),

Approved training organisations/centres must demonstrate that they have identified potential conflicts of interest and have a policy of managing the risk.

If reasonable steps cannot be taken to mitigate the identified risk, the CITB quality representative must be notified prior to the activity taking place. This is to allow guidance to be provided and steps taken to mitigate.

The approved training organisation/centre must have systems in place to manage the conflict of interest and mitigate the risk. This must be available to CITB on request.

5. In-house providers/employer Approved Training Organisations

CITB recognises that unavoidable potential conflicts of interest exist within ATOs, particularly for in-house providers,* i.e. employers. Therefore at the initial application stage, the ATO can identify the potential conflicts and document the systems that will be in place to overcome this. For example:

• clear role separation of updating the Construction Training Register with achievement date and training delivery;
• clear role separation of quality assurance and training delivery;
• avoidance of training delivery to employees by direct line managers/supervisors or family members.

Any agreed actions can then be monitored as needed by routine CITB quality interventions. Only situations not included in these procedures then need to be identified to a CITB quality representative and be recorded for audit purposes.

* Clarification: The above process is not applicable for ATOs/centres where the routine business delivery is external training on a commercial basis. In these situations, the review process for approved training organisations/centres outlined in section 4 applies, along with any specific scheme rule guidance, i.e. self-proctoring for the CITB Health, Safety and Environment (HS&E) test.

6. Appendix 1: Exemplar recording document

This exemplar document is also available to download (PDF, 9KB).