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Conflicts of Interest & Connected Persons Policy



This policy was adopted by the Board of Directors of Armagh Credit Union
Limited.



Signed:-

_______________________________ Position ________________


_______________________________ Position ________________




Date:

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.

The director, supervisor, committee member, employee or volunteer shall not
in any manner, directly or indirectly, participate in the deliberation upon
or the determination of any question affecting his interest (including but
not limited to pecuniary interest) or the interest of anybody (other than
the credit union) in which he/she is directly or indirectly interested.
Such person shall be required to withdraw from any meeting at which the
matter is being discussed or determined.

Where a Director of the credit union has a personal relationship with an
employee of the credit union, he or she will absent themselves from all
meetings or discussions that relate to employee matters. If a Board or
Committee Member or a member of their family expresses an interest in
becoming an employee of the credit union, they shall not be permitted to
take part in either the 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 &
counter-signatory 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 or Volunteer must not
use any information obtained during the course of involvement with the
credit union for any purposes of personal gain or that of family, friends
or other associates. All personnel are required to sign a declaration of
confidentiality on taking up a role in the credit union and annually
thereafter.