Purpose and scope
This Conflict of Interest (COI) policy template helps theological institutions identify, disclose and manage situations where private interests could improperly influence institutional decisions. It is intended for boards, senior leaders, faculty, examiners, trustees, staff, volunteers and others involved in governance or academic determinations.
Key principles
- Transparency: Require timely disclosure of interests that could reasonably be seen to affect impartiality.
- Proportionality: Manage conflicts according to risk and institutional role.
- Student-first: Ensure decisions protect students and academic standards.
- Compliance: Maintain legal and regulatory compliance; institutional responsibilities under applicable law remain the institution's duty.
Core policy elements (template text)
The following elements form a usable COI policy. Institutions should adapt wording to local law and institutional structure.
- Definitions: Define 'conflict of interest', 'related party', 'material interest' and 'immediate family'.
- Who must disclose: Board members, senior staff, academic leaders, examiners, programme reviewers and any person making procurement, hiring, assessment or certification decisions.
- When to disclose: On appointment; annually; and immediately upon any change in circumstances.
- Disclosure process: Use a written declaration form held by the Secretary/Registrar and recorded in meeting minutes.
- Management options: Recusal from discussion/vote, independent review, written conditions, repayment/voiding of decision where appropriate, or prohibition from participation.
- Documentation: Record disclosures, management plans and actions taken.
- Enforcement: Breaches may result in disciplinary action up to removal or termination, in line with institutional procedures.
Practical examples
- A board member’s employer is a major supplier: disclose and recuse from procurement decisions.
- A faculty member assessing a relative’s work: delegate assessment to an independent assessor.
- A donor requests preferential admission for their child: document the request and apply standard admissions procedures without special treatment.
Implementation checklist
- Adopt a written COI policy approved by the governing body.
- Create a standard disclosure form and annual declaration cycle.
- Assign a named officer (Secretary/Registrar) to maintain registers.
- Train governance, academic and administrative staff on identifying and managing conflicts.
- Report aggregate COI disclosures and management outcomes in governance reports.
Legal and regulatory note
Institutions must ensure the final policy complies with applicable national and local law and with any statutory obligations on charities, employers or educational providers. ITAA accreditation does not replace governmental recognition or legal requirements; institutions remain responsible for compliance.
Template file and usage
Use this text as a foundation; adapt language to local legal requirements, governance structures and collective agreements. Retain records of disclosures and management plans for audit and quality-assurance purposes.
Frequently asked questions
Who decides on a management plan?
The governing body or a delegated committee, documented in minutes.
Are family relationships always a conflict?
Not always; they require disclosure and risk-based management.
ITAA accreditation replaces government approval.
ITAA accreditation is non-governmental accreditation and does not replace governmental recognition or statutory degree-awarding powers. Institutions remain responsible for all legal registrations and approvals.
Conflict of interest policies only apply to senior leaders.
COI policies should cover any person whose role can influence procurement, assessment, admissions, awards or governance, including volunteers and external examiners.
ITAA’s role
ITAA supports institutions to adopt robust governance and quality-assurance policies. ITAA provides guidance and evaluates whether an institution has appropriate policies and practices in place as part of accreditation. Accreditation is a form of independent theological accreditation aligned with ITAA standards; it does not confer governmental recognition or statutory powers.
Important Accreditation Information
