Conflict of Interest Policy Summary

Last updated: 23 June 2026

1. Introduction

Albion Awards is being developed as a specialist awarding organisation focused on professional qualifications in governance, risk, assurance, cyber governance, board practice and organisational resilience.

This summary explains Albion Awards’ approach to identifying, declaring, recording, managing and reviewing conflicts of interest.

Albion Awards is currently preparing for Ofqual recognition. Albion Awards is not yet recognised by Ofqual and does not currently offer Ofqual-regulated qualifications.

2. Policy Commitment

Albion Awards is committed to fair, objective, transparent and independent decision-making.

Conflicts of interest can affect confidence in qualification design, centre approval, assessment, quality assurance, certification, complaints, appeals, governance and regulatory activity. Albion Awards will therefore maintain clear arrangements to identify, record and manage actual, potential and perceived conflicts of interest.

3. What Is a Conflict of Interest?

A conflict of interest may arise where a person’s personal, professional, financial, commercial or organisational interests could affect, or appear to affect, their ability to act objectively in the interests of Albion Awards, learners, centres, qualification standards or regulatory requirements.

A conflict may be:

actual — a conflict currently exists;
potential — a conflict could arise in future;
perceived — others could reasonably believe a conflict exists, even if the person believes they can act objectively.

4. Who This Applies To

This policy summary applies to anyone involved in Albion Awards activity, including:

Governing Body members;
Responsible Officer;
staff;
contractors;
consultants;
qualification developers;
assessment writers;
assessors;
internal quality assurers;
external quality assurers;
centre approval reviewers;
certification personnel;
complaints and appeals reviewers;
malpractice investigators;
committee members;
centres and centre staff;
professional advisers;
any other person acting on behalf of Albion Awards.

5. Examples of Conflicts of Interest

Conflicts of interest may include:

involvement in approving a centre where the person has a financial, employment or personal relationship with that centre;
assessing or quality assuring the work of a learner who is a family member, close friend, colleague or business associate;
taking part in an appeal, complaint or malpractice investigation where the person was involved in the original decision;
developing assessment materials while also delivering teaching or coaching that could give learners an unfair advantage;
using confidential Albion Awards information for personal or commercial benefit;
holding a role with another awarding organisation, training provider, centre or competitor where interests may overlap;
making certification decisions where there is pressure from a centre, employer, client or commercial relationship;
failing to declare personal, financial or organisational interests that could affect impartiality.

6. Declaration Requirements

Relevant individuals must declare conflicts of interest:

when appointed or contracted;
before taking part in governance, assessment, quality assurance, certification, appeals or investigation activity;
when allocated to centre approval, EQA or assessment work;
at the start of relevant meetings;
when circumstances change;
as soon as they become aware of an actual, potential or perceived conflict.

Failure to declare a conflict may be treated as a serious matter and may result in removal from decision-making, investigation, sanctions or other appropriate action.

7. Recording Conflicts

Albion Awards will maintain a Conflict of Interest Register.

The register may record:

name of the person or organisation;
role or relationship to Albion Awards;
nature of the conflict;
whether the conflict is actual, potential or perceived;
date declared;
risk level;
mitigation actions;
decision made;
person responsible for monitoring;
review date;
closure date where applicable.

The register will be reviewed as part of Albion Awards’ governance and risk management arrangements.

8. Managing Conflicts

Albion Awards will manage conflicts proportionately, based on the nature and risk of the conflict.

Possible actions may include:

recording the conflict and allowing activity to continue with monitoring;
restricting access to certain information;
removing the person from a meeting, decision or approval process;
allocating the work to another person;
adding independent review or moderation;
requiring additional quality assurance checks;
changing assessment, EQA or certification responsibilities;
excluding the person from complaints, appeals or malpractice decisions;
terminating a role, contract or appointment where necessary;
escalating the matter to the Responsible Officer or Governing Body.

The chosen action will be documented.

9. High-Risk Areas

Albion Awards will pay particular attention to conflicts involving:

qualification approval;
assessment design and approval;
centre approval;
centre monitoring;
external quality assurance;
learner assessment;
certification claims;
appeals;
complaints;
malpractice and maladministration investigations;
sanctions or withdrawal decisions;
governance decisions;
commercial relationships;
confidential information.

These areas are especially important because they may affect learner fairness, qualification standards, public confidence and regulatory readiness.

10. Separation of Duties

Albion Awards will seek to separate key duties where appropriate.

For example:

a person who develops an assessment should not normally be the sole person approving it;
a person involved in an original assessment or certification decision should not normally decide an appeal about that decision;
a person with a relationship to a centre should not make an independent centre approval decision for that centre;
complaints and investigations should be reviewed by people who can act objectively;
certification decisions should be based on evidence and appropriate checks, not commercial pressure.

11. Responsibilities

Governing Body

The Governing Body oversees Albion Awards’ arrangements for managing conflicts of interest and receives reports on significant conflicts where appropriate.

Responsible Officer

The Responsible Officer is responsible for ensuring that conflicts are identified, recorded, managed, escalated and reviewed.

Staff, Contractors and Representatives

Anyone acting for Albion Awards must declare conflicts promptly and follow any mitigation actions agreed.

Centres

Centres must identify and manage conflicts within their own delivery and assessment arrangements and report relevant conflicts to Albion Awards.

Assessors, IQAs and EQAs

Assessment and quality assurance personnel must declare conflicts before undertaking work and must not take part in activity where their objectivity could reasonably be questioned.

12. Confidentiality

Conflict declarations may contain personal, professional or commercial information. Albion Awards will handle this information confidentially and share it only with those who need to know in order to assess, manage or monitor the conflict.

Records will be retained in accordance with Albion Awards’ data protection and records retention arrangements.

13. Breaches of the Policy

A breach may include:

failing to declare a conflict;
providing incomplete or misleading information;
ignoring an agreed mitigation action;
taking part in a decision despite a conflict;
using confidential information for personal or commercial advantage;
applying inappropriate pressure to assessment, quality assurance or certification decisions.

Where a breach is identified, Albion Awards may take action under the relevant procedure. This may include investigation, removal from activity, centre action, contract review, sanctions, or escalation to the Governing Body.

14. Monitoring and Review

Albion Awards will review conflicts of interest through:

governance reporting;
Responsible Officer oversight;
centre approval and monitoring;
assessment and certification controls;
complaints and appeals review;
malpractice and maladministration investigations;
EQA activity;
risk management;
audit trails;
annual policy review.

Learning from conflict cases will be used to improve controls, training, guidance and decision-making.

15. Related Documents

This summary should be read alongside:

Conflict of Interest Policy and Procedure;
Conflict of Interest Register;
Governance Statement;
Responsible Officer Statement;
Risk Management Policy;
Assessment Policy;
Centre Approval Policy;
Centre Agreement;
External Quality Assurance Procedure;
Certification Procedure;
Complaints Policy;
Appeals Policy;
Malpractice and Maladministration Policy;
Data Protection and Records Retention Statement.

16. Contact

For questions about conflicts of interest, or to declare a conflict, contact:

Albion Awards
United Kingdom
Email: info@AlbionAwards.org.uk