Conflict of Interest Policy
Requirements for identifying, disclosing and managing personal or business interests that could affect impartial decision-making.
View all policies↗What this policy is designed to do.
To protect procurement, recruitment, contracting and operational decisions from undisclosed personal, financial or family interests that could undermine fairness or trust.
Who it applies to: Directors, employees, consultants, procurement personnel, evaluators and others involved in decisions made on behalf of Lion & Leo.
The standards we expect in practice.
These principles guide decisions, conduct and day-to-day execution across the relevant parts of our business.
Disclose actual, potential or perceived conflicts as soon as they become known.
Do not use company position, confidential information or procurement access for personal advantage.
Do not participate in a decision where impartiality could reasonably be questioned until the conflict has been reviewed.
Maintain transparent records of declared conflicts and agreed management measures.
Controls that turn policy into evidence.
Controls are scaled to the nature, value and risk of the activity rather than treated as a one-size-fits-all checklist.
Conflict declarations during relevant onboarding, procurement and evaluation activities.
Recusal from decisions where a conflict cannot be eliminated.
Independent review of related-party or sensitive transactions.
Documented mitigation measures and management approval where a conflict can be safely managed.
Clear ownership matters.
Individuals are responsible for making complete and timely disclosures.
Managers and procurement leads must not ignore known conflicts.
Compliance or senior management determines appropriate mitigation for material cases.
Policies that work together.
Governance controls overlap by design. These related policies provide additional context for this topic.