Conflict of Interest Policy

Last updated: October 2026Applies to: Higher Council for Distance Education (HCDE)

Purpose

The value of an accreditation depends on the independence of the decision. This policy sets out how HCDE identifies, declares and manages interests that could affect, or appear to affect, a review or decision.

What counts as a conflict

A conflict exists where a person who acts for HCDE has an interest that could reasonably be seen to affect their judgement. Examples:

• Being, or having recently been, an employee, owner, governor, student or paid adviser of the institution under review
• A close family or personal relationship with someone at the institution
• A financial interest in the institution, or in a competitor
• Being involved in preparing the institution's self-study or application
• A previous dispute with the institution or its owners

Declaring interests

• Every reviewer, committee member and panel member signs a declaration before taking on a review, and again if circumstances change.
• Staff declare interests when they begin and when anything relevant changes.
• HCDE keeps a register of declared interests.

Managing a conflict

• A person with a conflict does not take part in the review, the discussion or the decision concerned.
• HCDE assigns another reviewer or panel member, and records that it did so and why.
• Where a conflict is minor, the chair may decide, in writing, that the person may take part with safeguards.

Independence of advice and review

HCDE does not sell consultancy to an institution that is under review or is applying for accreditation. Reviewers do not advise the same institution for a period set by HCDE after a review.

Breaches

Failure to declare a conflict is a breach of the Code of Conduct. A decision affected by an undeclared conflict may be reopened.

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