Conflicts of Interest Policy

Introduction

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 both ABMA employees and ABMA agents which include, but are not limited to:

  • consultants,
  • qualification developers,
  • examination question and mark scheme developers,
  • 3rd parties which provide services such as invigilation,
  • markers,
  • moderators,
  • suppliers,
  • external quality assurers (EQAs), and
  • centre staff associated with the delivery and assessment of ABMA qualifications e.g. principals, tutors, invigilators, internal quality assurers (IQAs), etc.

Review arrangements

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.

Overview

In terms of agents, including centres, we expect to receive notification of actual or potential conflicts of interest that could arise, or have arisen, before or as soon as possible after they are identified. 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.

Definition of a conflict of interest

For the purposes of this policy we have adopted the definition used by Ofqual 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.

Examples of a conflicts of interest

Below are some examples of potential conflicts of interest and the reasons why they are deemed conflicts of interest (note: this list is not exhaustive):

Potential conflict of interest Why this is a potential conflict
An ABMA employee is related to/has a personal relationship with an ABMA learner ·  The employee may amend the learner’s record, for example, tamper with the learner’s grades on the system

·  The employee may have access to the examination questions/mark schemes and share these with the learner

·  This could have an adverse effect

 

An ABMA employee is related to/has a personal relationship with a centre’s member of staff ·  The employee may amend the centre’s record as a favour to the staff member, for example, indicate that the centre has processed a payment when they have not

·  The employee may have access to the examination questions/mark schemes and share these with the staff member

·  This could have an adverse effect

 

An ABMA marker is related to/has a personal relationship with an ABMA learner that they are assessing ·  The marker may award the learner a biased grade

·  This could have an adverse effect

 

A centre employee is related to/has a personal relationship with an ABMA learner whom they are teaching ·  The employee may give the learner preferential treatment, thereby disadvantaging other learners

·  The employee may have access to the examination scripts when they are received by the centre and share these with the learner

·  This could have an adverse effect

 

A centre employee is related to/has a personal relationship with an ABMA learner whom they are not teaching ·  The employee may try to influence their colleague(s) who are teaching the learner to give them preferential treatment, thereby disadvantaging other learners

·  This could have an adverse effect

 

The invigilator is related to/has a personal relationship with an ABMA learner that they are invigilating ·  The invigilator may give the learner preferential treatment, thereby disadvantaging other learners

·  The invigilator may contravene our invigilator rules to allow the learner undue advantages

·   This could have an adverse effect

 

When someone declares that they have a conflict of interest, control measures can then be put in place to then manage the conflict. For example, we might state that if a centre employee is related to/has a personal relationship with an ABMA learner at their centre, they are not permitted to teach, assess or invigilate that learner.

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.

Declaring conflicts of interest

In order to meet the principles outlined, it is imperative that any conflicts of interest, both existing and new, are declared as soon as they are identified.

ABMA agents, including centre staff, must declare any existing or new conflicts of interest via ABMA Interactive (AI) or by contacting us directly (contact details below).

Why declaring conflicts of interest is important

It is important that ABMA agents, including centres, declare conflicts of interests as we need to assure ourselves that the integrity of our qualifications is maintained and that any potential adverse effects are mitigated.

For information, the Ofqual definition of an adverse effect is:

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

  • gives rise to prejudice to Learners or potential Learners, or
  • adversely affects –
  • (i) the ability of the Awarding Organisation to undertake the development, delivery or award of qualifications in accordance with its Conditions of Recognition,
  • (ii) the standards of qualifications which the Awarding Organisation makes available or proposes to make available, or
  • (iii) public confidence in qualifications.’

If an ABMA agent is found to not have declared a conflict of interest, this could result in the termination of the agreement with ABMA.

Sanctions

If there is a breach of this policy and an ABMA agent is found to not have declared a conflict of interest, breaches are reported to the QCC and sanctions may be imposed in accordance with our Sanctions Policy. Sanctions range from issuing of actions to the termination of the agreement with ABMA.

Contact us

If you have any queries about the contents of the policy, please contact our Compliance Department at:

ABMA Education

7 Queens Square | Lyndhurst Road | Ascot | Berkshire | SL5 9FE | United Kingdom

Tel: +44 (0) 20 8733 7000

E-mail: quality@abma.uk.com

Web: www.abma.uk.com

 

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