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Armagh Credit Union

Conflicts of Interest & Connected Persons Policy
This policy was adopted by the Board of Directors of Armagh Credit Union Limited.
Signed:_______________________________ _______________________________ Position Position ________________ ________________

Date:

Armagh Credit Union is authorized and regulated by the Financial Conduct Authority and Prudential Regulation Authority: Registration Number 573925: Version Dec2015


Armagh Credit Union

Policy on Conflict of Interests & Connected Persons
To adhere to the requirements of the Statement of Principles for Approved Persons, Armagh Credit Union will seek to avoid the potential for conflicts of interest to arise. Responsibilities of connected persons (for example, relatives and other close relationships) shall be kept entirely separate. They should not hold key posts at the same time as each other nor will they be permitted to take part in the same committee or to work in the same area of the credit union operations. Where this is unavoidable, the credit union will make every effort, including the following measures, to ensure that sufficient segregation of responsibilities exists, to avoid opportunities for collusion and that the grounds for potential allegations to arise are limited. No Director, Supervisor, Committee Member, Employee or Volunteer shall set up an account or make any change in the books or systems of the credit union in respect of their own account or the account of any members of his family. Staff will not have access to family member accounts on the computer system. From the ILCU Standard Rules, family member means (a) a spouse or civil partner (b) any lineal ancestor, lineal descendant, brother, sister, half-brother, half sister, uncle, aunt, nephew, niece, first cousin of his/her spouse or civil partner. (c) the spouse or civil partner of any person within sub-paragraph (d) adoptive father, mother, son or daughter and for the purpose of deducing any such relationship, an illegitmate child or step-child shall be treated as the legitimate child of the relationship in question. Armagh Credit Union will not make a loan to a relative of, or any person otherwise connected with, an officer, approved person or paid employee of the credit union on terms more favourable than those available to other members of the credit union. Each Director, Supervisor, Committee Member, Employee and Volunteer will avoid circumstances in which personal interests conflict, or appear to conflict, with the interests of the credit union or its members. The Board expects officers to self-declare any potential conflicts affecting them. External positions held or involvement by a Director, Supervisor, Committee Member, Employee or Volunteer in outside activities must not: give rise to any real or apparent conflict with the members' interests; adversely reflect on the credit union; or interfere with an individual's job/role performance. In some circumstances a Director, Supervisor, Committee Member, Employee or Volunteer may directly or indirectly hold an interest that conflicts/may conflict with the credit union's interest. In all such circumstances, and in order to protect both the individual and the credit union in exercising objective decisions, such interest must be declared in advance.
Armagh Credit Union is authorized and regulated by the Financial Conduct Authority and Prudential Regulation Authority: Registration Number 573925: Version Dec2015


Armagh Credit Union

The director, supervisor, committee member, employee or directly or indirectly, participate in the deliberation upon or affecting his interest (including but not limited to pecuniary (other than the credit union) in which he/she is directly or shall be required to withdraw from any meeting at which determined.

volunteer shall not in any manner, the determination of any question interest) or the interest of anybody indirectly interested. Such person the matter is being discussed or the credit employee interest in either the

Where a Director of the credit union has a personal relationship with an employee of union, he or she will absent themselves from all meetings or discussions that relate to matters. If a Board or Committee Member or a member of their family expresses an becoming an employee of the credit union, they shall not be permitted to take part in recruitment or selection process.

No Director, Supervisor, Committee Member, Employee or Volunteer may offer, give, solicit or accept gifts, sponsorships, hospitality or service that would compromise, or give the appearance of compromising, their position or any decision taken by or on behalf of the credit union. Members from the same family are not permitted to be a cheque signatory & countersignatory on the same cheque. Where potential conflicts do arise the Board of Directors will take whatever action it deems necessary to mitigate the conflict. A majority decision of the board may request an individual with a conflict of interest to stand down from their post during the period that the conflict exists. Where a volunteer or staff member breaches the credit union's policy the following actions may be taken: Investigation of the breach Disciplinary action (in line with the credit union's disciplinary procedures) Termination of employment (in line with the credit union's disciplinary procedures) Further civil, criminal and or regulatory action may result. A Register of Interests will be maintained by Armagh Credit Union. Each Director, Supervisor, Committee Member, Employee or Volunteer are required to record details of any businesses they may be involved in, or other organisations that they may represent, or any other information that may be regarded as significant in relation to the credit union's business. A Register of Conflicts of Interests is maintained by the credit union. All Officers and Committee Members are required to record the following details: Date, parties involved, a brief description of the potential conflict of interest and details of any action taken as a result. A Director, Supervisor, Committee Member, Employee information obtained during the course of involvement with personal gain or that of family, friends or other associates. declaration of confidentiality on taking up a role in the credit or Volunteer must not use any the credit union for any purposes of All personnel are required to sign a union and annually thereafter.

Armagh Credit Union is authorized and regulated by the Financial Conduct Authority and Prudential Regulation Authority: Registration Number 573925: Version Dec2015