The document outlines both our broad approach to identifying and monitoring all potential/new/actual conflicts of interest that may affect us both now and in the foreseeable future.
This policy aims to negate any conflicts of interest associated with the activities undertaken by ABMA and/or the activities undertaken on ABMA’s behalf. It applies to ABMA employees and ABMA agents which include, but are not limited to:
- qualification developers,
- examination question and mark scheme developers,
- 3rd parties which provide services such as invigilation,
- external verifiers, and
- centre staff associated with the delivery and assessment of ABMA qualifications e.g. principals, tutors, invigilators, internal verifiers, etc.
We will review this document annually as part of our self-evaluation arrangements. However, a review will be commissioned earlier should an issue arise in relation to an actual or potential conflict of interest and/or in response to customer, learner or regulatory feedback.
Definition of a conflict of interest
For the purposes of this policy we have adopted the definition used by the Regulatory Body in relation to conflicts of interest. In essence, a conflict of interest exists in relation to ABMA where:
- our interests in any activity undertaken by us or by agents on our behalf has the potential to lead us to act contrary to our interests in the development, delivery and award of qualifications in accordance with the requirements of Ofqual’s ‘General Conditions of Recognition’,
- a person, including agents, who is connected to the development, delivery or award of qualifications at ABMA has interests in any other activity which have the potential to lead that person to act contrary to his or her interests in the development, delivery or award process and impact on our compliance with the requirements of Ofqual’s ‘General Conditions of Recognition’, and/or
- an informed and reasonable observer would conclude that either of these situations was the case.
In terms of agents, we expect to receive notification of actual or potential conflicts of interest that could arise or have arisen before, as soon as they are identified. This identification will come via our CRM system, ABMA Interactive (AI), or via the Declaration of Interest Form found in Appendix 2. We expect agents to mitigate where possible and manage, where necessary, any identified actual/potential conflicts of interest.
In addition, all centres are expected to have a conflicts of interest policy. This is verified by the Centre Recognition Committee at approval stage.
Conflict of interest principles
In implementing our approach to identifying and managing potential/new/actual conflicts of interest, agents are required to abide by the following principles:
- must be proactive in the identification and management of conflicts of interest that may affect our effectiveness, level of regulatory compliance and/or reputation,
- must be open about the nature of any potential/new/actual conflicts of interest because managing conflicts of interest is about preventing issues from occurring or recurring that may impact on our operational effectiveness and/or regulatory compliance, and
- must strive to identify and deal with conflicts of interest at the earliest opportunity.
Dealing with conflicts of interest and/or breaches to the procedures outlined in this policy
Should there be a breach of this policy and/or unforeseen conflicts of interest emerge, agents must inform ABMA at the earliest opportunity and we will carry out an investigation immediately, along with a review of the associated procedures. The outcomes of the investigation will be reported to ABMA’s Quality Control Committee (QCC). Any necessary actions will be determined by the QCC and communicated to the individual/agent concerned.
If you have any queries about the contents of the policy, please contact our Regulatory Department at:
7 Queens Square
Tel: +44 (0) 20 8733 7000