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Purpose: This policy helps Kickass Online Ltd (‘KO’) identify, manage, and resolve conflicts of interest to protect the integrity of our decision-making, maintain client trust, and comply with applicable law including the Bribery Act 2010.
Scope: This policy applies to all employees, officers, directors, and contractors working for or on behalf of KO.
What is a Conflict of Interest?
A conflict of interest arises when an individual’s personal interests, relationships, or outside activities interfere, or could reasonably appear to interfere, with their duties to KO or its clients. This includes situations where a personal benefit might influence, or be seen to influence, a professional decision.
Conflicts do not need to be actual to require disclosure, a perceived or potential conflict is sufficient.
Examples of Conflicts of Interest
Conflicts of interest include, but are not limited to:
- Having a financial interest in a supplier, competitor, or client of KO
- Being employed by, or providing services to, a competitor, supplier, or client of KO outside of your KO role (see Secondary Employment below)
- Making business decisions that benefit a family member, close friend, or personal associate
- Using KO’s resources, relationships, or confidential information for personal gain
- Receiving gifts, hospitality, or other benefits from clients, suppliers, or third parties that could influence your professional judgement (see Gifts and Hospitality below)
- Participating in the recruitment, performance review, or promotion of someone with whom you have a personal relationship
Disclosure
Employees must disclose any actual, potential, or perceived conflict of interest to their line manager as soon as they become aware of it, and before taking any action in relation to the matter concerned. Disclosures will be handled confidentially and without prejudice.
Where the conflict involves the line manager, disclosure should be made directly to the Director.
Failure to disclose a known conflict of interest is itself a disciplinary matter.
Assessment and Management
On receipt of a disclosure, KO will assess the situation and determine an appropriate course of action, which may include:
- Recusal from the relevant decision or process
- Reassignment of responsibilities
- Additional oversight or sign-off requirements
- In serious cases, requiring the divestment of a conflicting interest
The outcome will be communicated to the employee in writing.
Secondary Employment and Freelance Work
KO recognises that employees may have outside professional interests. Secondary employment or freelance work is permitted provided it does not:
- Compete directly with KO’s services or client relationships
- Use KO’s confidential information, tools, or resources
- interfere with the employee’s ability to perform their KO role
- Create a conflict of interest as defined above
Employees must notify their line manager in writing before taking on any secondary employment or significant freelance engagement. KO reserves the right to raise concerns where a conflict is identified.
Gifts and Hospitality
Employees must not solicit gifts, payments, or hospitality from clients, suppliers, or other third parties. Unsolicited gifts or hospitality must be handled as follows:
- Token gifts (e.g. branded merchandise, small seasonal gifts of under £50 in value): may be accepted and should be declared to the line manager
- Gifts above £50 in value: must be declined or, where refusal would cause offence, declared immediately to the line manager and either returned or donated to a charity
- Hospitality (meals, events, entertainment): modest business hospitality is acceptable where it has a clear professional purpose. Lavish or disproportionate hospitality must be declined and reported
- Cash or cash-equivalent gifts (vouchers, transfers) must always be refused regardless of value
All accepted gifts and hospitality above token value must be recorded. A record will be maintained by the line manager.
Bribery Act 2010
KO operates a zero-tolerance approach to bribery and corruption in accordance with the Bribery Act 2010. It is a criminal offence to offer, promise, give, request, or accept a bribe. Employees must not engage in any form of bribery, whether directly or through a third party, in any jurisdiction. Suspected bribery must be reported immediately to the Director. KO will cooperate fully with any investigation by law enforcement authorities.
Confidentiality
All disclosures made under this policy will be treated with discretion. Information will only be shared with those who need to know in order to assess and manage the conflict.
Compliance
Breaches of this policy, including failure to disclose a conflict, accepting prohibited gifts, or engaging in conduct that amounts to bribery, may result in disciplinary action up to and including dismissal, and may be referred to the relevant authorities where criminal conduct is suspected.
Review
This policy will be reviewed annually.
Last reviewed: May 2026.