Section 1 - Purpose

The management of conflicts of interest in the work of Core Groups is addressed in the existing Practice Guidance: Responding to, assessing and managing safeguarding concerns or allegations against church officers ("Core Groups" will be renamed “Safeguarding Case Management Groups” (SCMG) when this is revised) .

This policy builds on the above-named guidance and seeks to develop a culture of self-declaration by members of Core Groups / SCMGs in the wider safeguarding work in the Church of England. It provides further advice for Chairs of Core Groups / SCMGs to identify and manage conflicts of interest. It applies to safeguarding work in general, and specifically to Church Officers with safeguarding responsibilities, as outlined in the Church of England Key Roles and Responsibilities of Church Office Holders and Bodies Practice Guidance.

What are conflicts of interest?

Within this policy, conflicts of interest include situations of potential or actual risk that the judgement, decision-making and commitment of a member of a Core Group / SCMG has been (or may be) affected by secondary issues. These can include:

• Familial relationships, for example, with a respondent or someone who has reported abuse.

• Social ties – for instance friendships or godparentships - to a respondent or to someone reporting abuse.

• Professional connections to a respondent or a victim or survivor, which may affect the ability or desire of the core group / SCMG member to prioritise the safety and wellbeing of a victim or survivor or reach an impartial judgement about the issues.

• Financial relationships with a respondent, or a victim or survivor.

• A Core Group / SCMG member having personal or material interests in the outcome of the process.

• A Core Group / SCMG member having knowledge of the case to be managed by the Core Group or SCMG where they are also a potential witness for any criminal prosecution or other legal investigation(s).

 

People in these situations may become conflicted or feel that they have a conflict of interest because:

• Their relationship to a respondent or a victim or survivor may lead to a perception of conflict of interest or an actual conflict may arise from their loyalty to the person(s).

• They may be providing pastoral or spiritual support to a respondent or a victim or survivor; making it difficult for them to exercise impartial judgement or that there may be the perception that this is the case.

• Professionally, they are the line manager of the respondent or the victim or survivor and they are concerned that they do not have the requisite distance and impartiality from the matter being considered by the core group or SCMG.

• They may be competitors with the respondent or the victim or survivor for role(s) within the Church or Church Body – this can lead to concerns that they will not exercise impartiality.

• In the past they have initiated disciplinary action or other performance-management related processes in respect of the respondent or the victim or survivor and so they may be concerned that they do not have the necessary distance from the matter.

 

A member of a Core Group / SCMG should be regarded as having a perceived conflict of interest if a fair-minded person in possession of the material facts would consider that there was a real possibility that the member’s personal interests or loyalties could prevent the member from acting objectively, fairly, and impartially.

A suggestion that a member of a Core Group / SCMG has a perceived conflict does not necessarily mean that they should be treated as actually having a conflict of interest.  This is because the person alleging the existence of a conflict of interest might have an incorrect understanding of the relevant facts or might have an unreasonable view of what properly amounts to a conflict of interest. 

Notwithstanding the above, any actual or perceived conflicts can undermine confidence in the fairness and transparency of the work of the Core Group / SCMG and must therefore be addressed immediately.