Conflict of Interest Policy#
1.0 PPL Training Ltd (‘the Company’), including its subsidiary companies, PPL Digital Media Ltd and PPL Engineering Services Ltd, expects all employees, unless prevented by ill health or accident, to devote their whole time and attention to the business of the Company during their working time. Employees may not, without prior written approval, devote any time to any business other than the business of the Company which may:
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1.1 Conflict with the Company’s business interests.
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1.2 Adversely affect the Company’s reputation or relations with others; or
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1.3 Prejudicially affect employees’ ability to carry out their job duties and responsibilities effectively.
2.0 The decision as to whether an activity conflicts with the Company’s business interests, adversely affects the Company’s reputation or relations with others or has a prejudicial effect on the ability of employees to carry out job duties and responsibilities shall be at the absolute discretion of the Company. The Company will always be mindful of its obligations under the Working Time Regulations 1998.
3.0 Except with the Company’s prior written approval, employees may not be directly or indirectly interested, engaged, or have any financial interest in any capacity in any other business, trade, profession, or occupation. However, this shall not prevent employees from holding stocks, shares, or debentures so long as not more than 3% of the shares or stock of any class of any one company is held and provided such company does not carry on a business which is in competition with the Company’s business.
4.0 If employees wish to be engaged in any other employment or have any outside business interest, whether financial or otherwise, they must first seek the written permission of the Managing Director, which will not be unreasonably withheld.
5.0 As all conflicts of interest will be reviewed on a case-by-case basis, a review may result in disciplinary action. The company has full discretion to deem what disciplinary action is both fitting and necessary, including suspension and/or termination of employment.
6.0 Employees have a duty to disclose any actual or potential conflicts of interest, and any situations that might give rise to their being perceived as being compromised by a conflict. To disclose this information employees should speak to the Quality & Compliance Manager or the Business & Process Manager and inform them of details of the conflict, any employees involved, and the potential impact on the Company. They will log the conflict in the Conflict of Interest register and pass over to the appropriate person/s to review and seek appropriate advice where necessary.
7.0 This policy does not apply to employees’ involvement in trade union or public activities, such as becoming a magistrate, Justice of the Peace, or a member of a local authority, tribunal, or school governing body.