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Conflict of Interest Policy


This Policy and Procedure aims to protect both SOS and its members from any appearance of impropriety.

As members of SOS, we have an obligation to act in the best interest of SOS. Hence, we need to avoid situations where there may be real, potential or perceived conflicts of interest, which may arise where a member’s personal or family interest conflicts with those of SOS.

  • Such conflicts may result in the following:
    • Cause damage to SOS’s reputation which may lead to its inability to sustain operations;
    • Influence the members’ judgement and compromise objectivity when conducting SOS’s affairs;
    • Restrict free discussion, thus resulting in decisions or actions that are not in the interest of SOS; and
    • Risk the impression that SOS has acted improperly.
  • “Member” refer to a staff member, management member, board member, committee member or volunteer of SOS.


  • All members of SOS shall read and understand the Conflict of Interest Policy. They are required to make full disclosure of interests and to sign declaration form every year.
  • SOS does not permit conflict of interest. Accordingly, no member shall knowingly allow himself/herself to become involved in a conflict of interest, or upon the discovery thereof, to allow such a conflict to continue.
  • When a conflict of interest situation arises, the person concerned shall declare his or her interests and abstain from participating in the discussion, decision-making and voting on the matter.
  • Definitions of “Interest”
    “Interest” means any commitment, investment, relationship, obligation, or involvement, financial or otherwise that may influence a person’s judgement. This would include:

    • Direct interest – ownership in the name of the member;
    • Indirect interest – ownership beneficially held through other investment, estate, trust or
      other intermediary;
    • Vested interest – personal stake or involvement, which may or may not include an expectation of financial gain; and
    • Deemed interest – a member is deemed to have an interest which his / her spouse / immediate family member holds an interest.
  • Definition of “Conflict of Interest”
    • Any direct or indirect interest in, connection with, or benefit from outside commercial activities which interest may in any way adversely affect the organisation, involves a possible conflict of interest.
    • Conflict of interest may also arise whenever the personal or professional interests of a member potentially interfering with the performance of his/her official duties in SOS.
    • When actual, potential or perceived conflict of interest arises, the integrity, fairness and accountability of the person may be affected, which could impede the best interest of SOS.
  • Declarations of Interest – Members of SOS
    • Given the stated purpose of this Policy and Procedure, all Board, Committee and Management members shall declare their interests in connection with their roles in the SOS.
    • Declaration of interest forms: For Board/Committee Member and Staff and Volunteer Member, are provided for this purpose. The types of interest to be declared will include, but not limited to the following:
      • Members who have friends or other personal or business relationships must carefully consider whether those relationships create conflicts of interest with their entrusted role in the SOS. Examples include:
        • hiring a relative or friend as an employee or vendor;
        • buying or selling goods or services from/to a family business for which others might compete; and
        • having a personal relationship where there is an immediate reporting
    • In situations where members are not sure what to declare, or whether/when declaration needs to be updated, they are strongly encouraged to err on the side of caution or seek advice from the Board/Management Team.
    • All employees, Board and Committee members shall be asked to disclose any general information about themselves that could lead to actual or potential conflicts via declaration forms, at the start of their term of office / employment, subsequently on annual basis or as at when the need arises.
    • Volunteers involving in project will need to sign declaration form as they may directly or indirectly be involved in tenders and in making decision on procurement/vendor selection.
  • Declarations of Interest – Tender Project
    • Vendors that wish to participate in tender process and any external consultant that help to prepare tender documents re require to make declaration of conflict of interest and sign on the declaration form.
    • It is the responsibility of the Project Team to ensure the following parties have signed and returned the completed conflict of interest (COI) declaration form:-
      • Project Members
      • Advisers/consultants to the project, including those help in prepare tender documents
      • Tender Committee members
      • Vendor that participate in the tender process
    • It is also the responsibility of the Project Team to ensure relevant breach of conflict of interest clauses be included in the tender documents, inform to Chief of Executive and Tender Committee should there is any conflict of interest declare by any of the participated vendors.


  • Member(s) that deemed to have conflict of interest should not be involved neither explicitly nor implicitly in the said project. The member(s) shall not participate in discussion or vote in the project.
  • In the event of ambiguity/exceptional cases, such member is required to obtain pre- clearance/approval for any involvement.
  • All conflicts must be escalated to the Chief Executive for his attention and action. The pre-clearance/approval level shall be as follows:-
    Involved Party(ies) Pre-clearance/Approval by:
    (other than CE)
    Jointly by CE and Chairman of the
    Governance & Nominating Committee
    Jointly by the Chairman of the Board and
    one Board Member
  • Should such potential conflicts of interest result in confirmed transactions – such transactions shall be subject to a post-mortem review by Governance & Nominating Committee (“GNC”). These transactions shall be scrutinised to be conducted within arm’s length (i.e. purchases shall not be procured at a higher price/fee and sales shall not be sold at a lower price/fee compared with similar vendors/suppliers in the market).
  • A “Conflict of Interest” Register shall be maintained for ease of reference and monitoring.
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