Management of Conflicts of Interest

Identification of potential conflicts of interest

All stakeholders are required to record potential or actual conflicts of interest and personal interest, dating back for a minimum of 3 years. This happens upon recruitment and is requested annually at contract renewal (during March each year). New conflicts should also be declared as soon as they are identified during the course of any contract year, by emailing contact@In2assessments.co.uk

If there is any doubt that the situation represents a potential conflict, it is recommended that it should be declared.

 

The register of Conflicts of Interest is managed, monitored and maintained by the Head of In2Assessments. Decisions will be taken by the ‘relevant person’ - this will be a member of In2Assessments staff with the authority to make such a decision, and most usually would be the End Point Assessment Manager.

The ‘relevant person’ will then:

• Assess the nature of the conflict

• Assess the risk or threat to the organisation’s functions

• Decide whether the conflict warrants further action/mitigation to be taken 

• Decide what steps to take to avoid or manage the conflict or adverse effect

 

There may need to be a discussion between the person notifying the potential conflict and the ‘relevant person’. The purpose of the discussion is to establish if an actual conflict exists (and whether there is potential for an ‘adverse effect’) and if so, to reach a decision about how the conflict will be managed. Good practice would be that if no potential current conflicts are identified, these ‘nil returns’ are logged and recorded, and that regular review and update is undertaken. In2Assessments will take all reasonable steps to ensure that all staff and assessors involved in end-point assessment are required to declare any interest of friends or family sitting upcoming assessments and it will be necessary to complete and sign a declaration of interest form.

 

If a member of In2Assessments independent apprenticeship assessment staff is undertaking end-point assessment and identifies a conflict of interest on the day of the end-point assessment that previously has not been identified through the declaration, the independent assessor is required to contact an Internal Quality Assurer immediately before any assessment takes place. In2Assessments will contact the Training Provider / Employer and discuss an alternative provision for the end-point assessment of the apprentice(s) or put mitigating actions in place to ensure the integrity of the end-point assessment activity.

 

Managing the conflicts

Where a conflict of interest or personal interest has been identified, the next step is to analyse whether this could have an ‘Adverse Effect’. An ‘Adverse Effect’ is defined as:

“An act, omission, event, incident, or circumstance has an Adverse Effect if it –

(a) gives rise to prejudice to Apprentices or potential Apprentices, or

(b) adversely affects –

(i) the ability of the end point assessment organisation to undertake the development, delivery or provision of end-point assessment,

(ii) public confidence in qualifications.”

​

Where an ‘Adverse Effect’ could reasonably be expected to occur, all reasonable steps must be taken to mitigate the Effect as far as possible and to correct it.

This may be achieved by:

• Reorganising activities and/or key functions, where reasonable, so that the Adverse Effect is mitigated

OR

• Gaining an undertaking from the individual(s) concerned to conduct their responsibilities so that the integrity of In2action-EPA end-point assessments is maintained, as well as their own professional integrity.

​

If neither of the above steps are possible, another solution must be found. The solution should be in proportion to the nature of the conflict. In extreme circumstances, activities may need to be monitored or even restricted.

 

The first step will be to try to eliminate the ‘Adverse Effect’ e.g. by assigning another member of staff to undertake the end-point assessment activity. By doing so, this reduces the risk of assessments being compromised and ultimately assessments being voided. Where elimination is not possible due to financial or/and resource implications, measures should be put in place which can demonstrate that the conflict is being managed effectively so as not to compromise the outcome of the assessment. Key principles here are transparency and mitigation.

 

All reasonable steps should be taken to avoid any part of the end-point assessment of an Apprentice (including assessing, interviewing, quality assurance) being undertaken by any person who has a personal interest in the result of the assessment. Where, having taken all such reasonable steps, an assessment by such a person cannot be avoided, arrangements should be made for the relevant part of the assessment to be subject to additional scrutiny by another person.

 

Internal conflicts

In2Assessments requires contractors involved in end-point assessments to declare conflict of interest if they are acting in different roles for In2Assessments for the same Training Provider/Employer. Any such declarations will be carefully monitored to ensure that those assessments are not compromised.

​

Internal Communications and operating procedures