Conflict of Interest Management Policy 

Goals of the TYPO3 Conflict of Interest Management Policy 

TYPO3's Conflict of Interest Policy aims to ensure that the collective interests of the TYPO3 community prevail over personal interests by exercising our responsibilities and making our decisions impartially, objectively and independently.

Definition of a Conflict of Interest 

The occurrence of a personal interest whose interference with the position held is such as to influence or appear to influence the loyal exercise of the position.

Sensitive Processes, Critical Positions and At-Risk Operations 

Only conflicts of interest within the perimeter of the sensitive processes, critical positions and at-risk operations are covered by this conflict of interest management policy.

Different Types of Conflict of Interest 

There are several types of conflict of interest:

• A real conflict of interest is one in which an individual's current official duties and responsibilities directly conflict with his or her existing personal interests.
• A potential conflict of interest exists when an individual has personal interests that could potentially conflict with his or her official responsibilities.
• A perceived conflict of interest exists when the public may believe that an individual's personal interests could influence the performance of his or her official duties - whether or not this is actually the case.

Code of Conduct 

Any individual falling within the scope of the sensitive processes, critical positions and at-risk operations defined above must :

• Disclose any conflicts of interest by filling in a declaration of interests before taking up their position;
• Declare any conflicts of interest of which they are aware. The nature of the conflict of interest must be recorded in the conflict of interest register.
• Remove themselves from any Board discussion on topics involving a conflict of interest. They should do so either in the meeting or with other Board members before or after the Board meetings.
• Refrain from attending the meeting during discussion, voting or deliberating on decisions related to the conflict of interest, unless expressly invited to do so by unanimous agreement by all other members present. The Board Member’s abstinence should be recorded in the meeting minutes.
• Respect the confidentiality of all person(s) who declare an existing or potential conflict of interest.

Priority Matrix 

The priority matrix is used to weight the severity of a conflict of interest by its probability, and to determine whether action needs to be taken to reduce this priority.

Only conflicts of interest with a value greater than or equal to 4 should be dealt with using one of the strategies described below.

Resolution Strategies 

• Record/register: Recording the disclosure of a conflict of interest in a register is an important first step; however, this does not necessarily resolve the conflict. It may be necessary to assess the situation and determine whether one or more of the following strategies is also required.
• Restrict: It may be appropriate to restrict involvement in the matter, for example, refrain from taking part in debate about a specific issue, abstain from voting on decisions, and/ or restrict access to information relating to the conflict of interest. If this situation occurs frequently, and an ongoing conflict of interest is likely, other options may need to be considered.
• Recruit: If it is not practical to restrict your involvement, an independent third party may need to be engaged to participate in, oversee, or review the integrity of the decision-making process.
• Remove: Removal from involvement in the matter altogether is the best option when ad hoc or recruitment strategies are not feasible, or appropriate.
• Relinquish: Relinquishing the personal or private interests may be a valid strategy for ensuring there is no conflict with your public duty. This may be the relinquishment of shares, or membership of a club or association.
• Resign: It may be an option if the conflict of interest cannot be resolved in any other way, particularly where conflicting private interests cannot be relinquished.

Possible Conflict of Interest Mapping