Volunteer Conflict of Interest Policy

These Rules were adopted by the Board on 9 February 2013 under Article 28

WMUK strives to be an open and transparent organisation. Part of this approach requires that we ensure that none of our volunteers or members have any interests that could conflict with our mission and the principles and rules of our community when they are undertaking any role for Wikimedia UK. WMUK staff and trustees are covered by our rather more strict Conflict of Interest Policy.

Scope

This policy applies to all volunteer and members of Wikimedia UK with regards any responsibilities they hold on behalf of the organisation in delivering its programme. As Wikimedia UK grows, more and more community members will continue to play key roles in the delivery of our programme. Some will be taking up positions of delegated authority on committees and working groups. Some will be undertaking activities supported by the charity such as being Wikimedians in Residence or attending conferences on the charity's behalf. Others will be directly delegated to help deliver parts of our programme.

Principles of Volunteer Conflict of Interest

Staff and trustees are expected to adhere to a code of conduct that expects any conflict of interest or potential conflict of interest to be fully declared. Similarly Wikimedia UK expects its community to abide by the highest standards of probity possible when undertaking activities on behalf of the Chapter.

This will apply to conflicts that affect the area of activity in which the community member is engaged, not all possible areas in which they are involved.

This conflict of interest policy should be read in conjunction with the relevant documents as listed below.

Conflicts of Interest

Volunteers in positions of trust

• Where a volunteer who is not a Trustee is appointed to a position of trust or responsibility in our organisation (e.g. membership of a committee to which the Board has formally delegated responsibility) we expect them to abide by high standards of integrity and accountability, including declaring any relevant interests and abiding by the decisions of the Board in managing such interests.
• This only applies to the areas of the organisation where a given individual has some delegated responsibility e.g. if we had a volunteer who was a member of museum staff, that person would need to declare their interest if they served on a Galleries, Libraries, Archives and Museums committee, but probably not if they were on a committee dealing with election rules or technology development.
• It is not Wikimedia UK's role to tell our volunteers what they can or can't do outside of Wikimedia UK, and keeping details of volunteers' outside interests should be exceptional (unless that volunteer is a Trustee or otherwise in a position of responsibility). However there are limited circumstances where it is appropriate for us to ask volunteers to declare their interests and for us to take this into account in decision-making.
• Where we provide individuals with resources of significant value (e.g. on the scale of a scholarship to Wikimania), we need to ask whether that individual has any other commercial, employment or other financial interests that are relevant.
• Where these interests are declared they will be taken into account in making relevant decisions, e.g. where we are awarding grants, scholarships, or places on particularly resource-intensive training courses. The nature and extent of the relevant interest will be taken into account in making these decisions. This does not mean it will be impossible to take part in such activities where interests are declared, though there will be some circumstances where that is the case.
• Where these interests are declared they will have no bearing on any individual's ability to participate in other Wikimedia UK activities which do not represent significant uses of resources, or where the interests declared are of no relevance. Any such declarations will be treated with an appropriate level of confidentiality but will be open to staff, trustees, and any other persons making decisons regarding the role of the community member.
• Accreditation from or participation in training supplied by Wikimedia UK, or other Wikimedia UK activities does not represent, and should not be presented as, a recommendation for, or statement of fitness of, any individual for any employment or commercial activity It should be seen as a way of supporting the charitable aims of WMUK with a view to offering support back to the community and particularly engaging new editors.

Wikimedian in Residence

• Wikimedia UK will apply the same standards to all Wikimedian in Residence posts where we are a recognised stakeholder, regardless of whether we are funding the post in whole, in part, or not at all. This is because paid or not the title represents a statement of association that could affect our reputation as an organisation.
• All such positions must be advertised under either the Wikimedia UK recruitment policy, or under an acceptable policy of a partner institution

Oversight of Volunteer Conflict of Interest

• The Board will annually review this policy and accompanying process and recommend amendments if required
• The Register of Interests will be completed in consultation with the individuals making the declarations, by the Chief Executive, and held on the UK Wiki (Public) and Office Wiki (Confidential)
• All staff members and volunteers are to be mindful of this policy and the declaration procedure in working with volunteers, particularly in the respect of making decisions under delegated responsibilities, offering support in terms of staff time, resources or financial support in the form of grants or expenses.

If the following circumstances apply

Community members applying for or appointed to the following should declare any interests that might be relevant:

• Wikipedians in residence – paid or unpaid
• Members of working groups set up by the board
• Community members who are not board members but who are given repsonsibilty for an area of the WMUK programme e.g. organising a conference.
• Community members applying for grants in excess of £100, including microgrants
• Community members applying for scholarships or travel grants to attend events on behalf of WMUK or to develop their own skills as contributors or editors.
• Community members undertaking training organised by WMUK.
• Community members undertaking training paid for by WMUK.

If you are subsequently found to have knowingly had a conflict of interest and not declared it, it is unlikely that you will be able to declare it at that point and continue with current responsibilities. If individuals with undeclared conflicts of interest are found to have benefited through failing to properly declare interests they may be subject to sanction, including removal of responsibilities, or obligation to refund grants made to them in good faith. In extreme cases, the chapter will consider legal action to recover funds.

This is not an exhaustive list - if in doubt please contact the office via lucy.crompton-reidwikimedia.org.uk, or call 0203 372 0760 to discuss in confidence.

How to make a declaration

If you consider a relationship or prior with a third part to present a conflict of interest, please provide the following information to the Chief Executive before any decision is made.

• Name
• Role in Wikimedia UK against which interest is being declared
• Whether it is:

• A specific incidence of a conflict of interest (say, in relation to a proposed supplier of a single event)
• An ongoing conflict of interest (say, a change of employment that creates a conflict with your responsibilities on a committee)

• With whom you have an association
• How long this lasted
• Whether there were any payments involved
• Whether your declaration needs to be confidential.

The Chief Executive will make a determination about whether the conflict of interest should be:

1. Simply declared - the matter will be noted in the appropriate public or private Register of Interest which will include a notice of action that must be taken (recusing from voting on certain subjects, explicit commitment not to undertake a certain activity or activities)
2. Refer the matter to the Board.

• This will happen when it is unclear that the individual can continue to act in their current capacity or receive significant use of resources without creating an unacceptable conflict of interest.
• If the Board finds this to be the case the individual will be asked to address the conflict of interest, or be disallowed from the relevant responsibility or use of resources within Wikimedia UK.
• The action taken to address the conflict of interest must be approved by the Board, with a requirement that the Chief Executive ensure this is undertaken/continues to be undertaken within a reasonable timescale (to be stipulated by the Board)

When considering whether to authorise a conflict of interest the Chief Executive or Board members, will have due regard to the Charity Commission guidance.

Confidentiality

The Chief Executive and Board must consider the privacy rights of individuals when discussing conflicts of interest. Appropriate use must be made of in camera board discussion, and with reference to our existing Confidentiality policy

What is a conflict of interest?

A conflict of interest is any situation in which a trustee, volunteer or member of staff's personal interests, or interests that they owe to another body, may (or may appear to) influence or affect the trustee's decision making. It is inevitable that conflicts of interest occur. The issue is not the integrity of the individual concerned, but the management of any potential to profit from a person’s position, or to be influenced by conflicting loyalties. Even the appearance of a conflict of interest can damage the charity’s reputation, so conflicts need to be managed carefully.

What to do if you think you have a conflict of interest

Having a conflict of interest isn't necessarily a problem; if declared it can be managed. Declaring a conflict of interest is normally a straightforward process of providing your name, the nature of the relationship that is creating a conflict of interest, and which Wikimedia UK role of project this relates to (See 'how to make a declaration' for more details). This information is recorded on the UK Wiki so that stakeholders can review declared interests and be confident that volunteers are being honest and acting appropriately by revealing where their decision making may be biased,

These declarations make up a register of interest. They do not have to include lots of personal information - such as where you live or details about other people such as employers, family members or business partners. Normally declaring the nature of the relationship, what it affects and what action will be taken to manage it is sufficient.

Where a conflict of interest is sensitive, such as it may disclose personal or financial information the declarer wishes to keep private, it may be possible to make a confidential declaration seen only by Trustees and staff. However, a wish for privacy is not sufficient - it may be that if you are not prepared to declare an interest publicly you may not carry out activities which present a conflict with this.

How to check if you have a conflict of interest

Review the following case studies to see if any feel similar to your position - in all cases it would be prudent to consider make a declaration of interest.

Case Studies

Person A is a member of the Galleries, Libraries, Archives and Museums Committee, which is considering awarding a grant to a Museum at which a member of their family works.

Person B is a volunteer arranging an event in their local area, and would like to host refreshments in a pub in which they work.

Person C has applied for a grant to attend Wikimania, where they intend to network to promote their services as a consultant in relation to Wikipedia.

Person D has received a microgrant to support editing work, that lends itself towards a project the recipient is receiving payment in connection with.

Procedure

A declaration of interest is made to ensure that Wikimedia UK is acting with property in dispersing the funds it receives from supporters of the Wikimedia mission. If managed properly through a declaration, a conflict of interest does not necessarily mean the individual concerned cannot make a case for their preferred outcome or apply for a grant, but may mean they cannot vote on it or must made certain undertakings before receiving a grant.

If you think you have a conflict of interest that needs declaring please refer to the Volunteer Conflict of Interest Declaration procedure.

Failure to declare

If you don't declare a conflict of interest you may run the risk of having your role revoked, or any money granted to you requested returned to the Charity. It is better to err on the side of caution, especially as few people have relationships that present substantive conflicts of interests that require being declared.