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Conflict of Interest

  1. Purpose

1.1. The purpose of this Conflict-of-Interest Policy is to ensure that all directors, trustees, employees, volunteers, contractors, facilitators, consultants, and representatives of Menstruation Foundation act with integrity, transparency, impartiality, and in the best interests of the organisation, schools, beneficiaries, and communities served.

1.2. This policy aims to:

identify and manage actual, potential, or perceived conflicts of interest;

prevent improper personal, financial, or professional benefit;

promote ethical conduct and accountability;

protect the reputation and integrity of Menstruation Foundation;

ensure compliance with applicable South African laws and governance principles.

 

  1. Scope

2.1. This policy applies to:

Board members and trustees;

Employees;

Volunteers;

Contractors and consultants;

Programme coordinators and facilitators;

Any individual or organisation acting on behalf of Menstruation Foundation.

 

  1. Definitions

3.1 Conflict of Interest

A conflict of interest arises when an individual’s personal, financial, family, business, or other interests may improperly influence, or appear to influence, their decisions, actions, or responsibilities within Menstruation Foundation.

 

3.2 Financial Interest

Includes direct or indirect ownership, employment, commission, gifts, sponsorships, compensation, or any financial benefit connected to an organisation, supplier, school, service provider, or partner.

 

3.3 Related Person

Includes a spouse, partner, family member, close associate, or business associate.

 

  1. Guiding Principles

4.1. All representatives of Menstruation Foundation shall:

act honestly, ethically, and transparently;

avoid situations that may create conflicts between personal interests and organisational responsibilities;

disclose conflicts of interest promptly;

act in the best interests of beneficiaries and partner schools;

avoid conduct that could damage the credibility or reputation of the organisation;

comply with all applicable laws, regulations, and organisational policies.

 

  1. Disclosure of Interests

5.1. All individuals covered by this policy must disclose:

any financial or business interest related to suppliers, sponsors, schools, or partner organisations;

any personal relationship that may influence decision-making;

any gifts, benefits, sponsorships, or hospitality that could create undue influence;

any outside employment or activities that may conflict with organisational duties.

5.2. Disclosures must:

be made in writing;

be updated annually or whenever circumstances change;

be submitted to the Board or designated management representative.

 

  1. Prohibited Conduct

6.1. The following conduct is prohibited:

using organisational position for personal gain;

accepting bribes, kickbacks, or improper benefits;

influencing procurement or donation decisions for personal benefit;

favouring family members, friends, or associates unfairly;

using confidential information for personal or external advantage;

engaging in fraudulent, corrupt, or unethical conduct;

exploiting relationships with schools, learners, or beneficiaries.

 

  1. Gifts and Hospitality

7.1. Representatives may not accept gifts, money, favours, hospitality, or benefits that may:

influence decision-making;

create an obligation;

compromise impartiality;

damage the reputation of Menstruation Foundation.

7.2. Any gifts or hospitality received above a reasonable nominal value must be disclosed to management or the Board.

 

  1. Safeguarding and Ethical Conduct

8.1. All representatives must:

conduct themselves professionally and respectfully when interacting with learners and school staff;

comply with safeguarding and child protection requirements;

avoid inappropriate relationships or communication with learners;

immediately report any safeguarding concerns or unethical conduct.

8.2. The following conduct is strictly prohibited:

harassment, intimidation, or discrimination;

exploitation or grooming of children;

inappropriate communication with learners;

misuse of organisational authority or influence;

unlawful or unethical behaviour.

 

  1. Confidentiality and Protection of Information

9.1. All confidential information relating to:

schools;

learners;

donors;

beneficiaries;

operations;

safeguarding matters;

must be protected and handled in accordance with applicable privacy and data protection laws, including POPIA.

9.2. Confidential information may not be disclosed or used for personal gain.

 

  1. Reporting and Management of Conflicts

10.1. Any actual, potential, or perceived conflict of interest must immediately be disclosed to management or the Board.

10.2. The organisation may implement appropriate measures including:

recusal from decision-making;

reassignment of responsibilities;

supervision or monitoring;

termination of involvement where necessary.

10.3. Failure to disclose a conflict of interest may result in disciplinary action or termination of association with the organisation.

 

  1. Compliance with South African Law

11.1. This policy shall be interpreted in accordance with applicable South African legislation, including but not limited to:

the Children’s Act 38 of 2005;

the Protection of Personal Information Act (POPIA);

the Prevention and Combating of Corrupt Activities Act 12 of 2004;

principles contained in the King IV Report on Corporate Governance.

 

  1. Declaration

12.1. I hereby declare that:

I have read and understood this Conflict-of-Interest Policy;

I agree to comply with its provisions;

I will disclose any actual, potential, or perceived conflict of interest;

I will act ethically and in the best interests of Menstruation Foundation and its beneficiaries.