Conflict of Interest Policy Development Tool
Developed by the City of Toronto
A Conflict of Interest Policy defines conflict of interest and guides the conduct of housing provider employees, directors, and contractors when situations arise of conflict of interest. All Toronto social housing providers are required to comply with Conflict of Interest City Guideline 2015-6, developed under the authority of the Housing Services Act, Regulation 367, Section 100.
Housing provider staff, directors and contractors can face situations where their loyalties may be divided or where personal interests may conflict with their duties or responsibilities to the housing provider. To ensure everyone is aware of what to do when these situations arise and the ramifications of violations, a policy must be developed that is compliant with City Guideline 2015-6.
What to include
- The purpose of the policy.
- A definition of conflict of interest, including real conflict of interest and perceived conflict of interest. The scope of the policy.
- The responsibilities surrounding conflict of interest.
- The repercussions of violating the policy.
- A reference to the City Guideline 2015-6 developed under the authority of Housing Services Act, Regulation 367, Section 100.
- Reference(s) to any related corporate policies.
- Procedures to report conflict of interest instances to the City of Toronto, as required under City Guideline 2015-6.
Ensure the policy is being followed
- Have “Declaration of Conflict of Interest” as a standing agenda item at every meeting of the Board of Directors.
- Have Directors sign a Conflict of Interest Declaration Form each year after elections. Sector organizations have templates of conflict of interest declaration forms.
- Have staff and contractors sign conflict of interest declaration forms.
- Review the policy with Directors and staff on a regular basis.