Why it matters
Agencies trust us with their data and with systems they rely on to run their business. Many of them compete with each other. The people who work for us must not let personal interests, or their work for someone else, affect how they treat Templace or any customer.
What a conflict of interest is
A conflict of interest arises when your personal interests, relationships or other work could affect, or could reasonably look as if they affect, the decisions you make or the work you do for us. Having a conflict is not wrong in itself. Failing to declare it is. Examples include:
- you, or someone close to you, own, work for, or are a candidate or worker with an agency that uses the Service, or a competitor of ours;
- you do other work, paid or unpaid, for another software company or a recruitment business;
- a supplier we are choosing is run by a friend or relative of yours;
- you have a financial interest in a customer, supplier or competitor;
- you are asked to support an agency's system where you know people whose records you would see.
The Director's duties
As a company director, our Director has legal duties under the Companies Act 2006. They include the duty to avoid situations in which the Director has, or could have, an interest that conflicts with the company's interests (section 175), and the duty to declare an interest in a proposed transaction or arrangement with the company (section 177).
We record the Director's interests in the same register as everyone else's.
How to declare an interest
Declarations go to the Director, in writing:
- when you start working with us;
- within 5 working days of a new interest arising, or before you take part in the work or decision it affects, if that is sooner;
- once a year when we ask you to confirm your declaration, even if nothing has changed;
- whenever you are unsure. If in doubt, declare it.
How we manage conflicts
The Director decides how each declared conflict is managed and records the decision in our register of interests. Depending on the conflict, we may:
- record it and take no further action, where the risk is low;
- make sure someone else does the work or makes the decision;
- not give you access to a particular agency's system;
- tell the customer affected, with your agreement where that is needed;
- ask you to give up the interest or the outside work, where the conflict cannot be managed in any other way.
Keeping customers' information apart
Each agency's data is kept separate and no agency can see another's. Everyone who works for us must keep it that way in what they say and do. Never pass one agency's information, prices, candidates or clients to another, and never use it to compete with a customer.
Breaches and review
Failing to declare a conflict, or using your position for personal gain, is a breach of our code of conduct. It may lead to your contract being ended or, if we employ you, to disciplinary action.
Questions go to terry@hilliernet.co.uk. The Director reviews this policy and the register of interests at least once a year.
Conflicts of interest · version 1.0 · approved 27/10/2026 · next review 27/10/2027. Templace is a trading name of TWH Holdings Limited, company number 10663539, Meadway, Mill Road, Writhlington, Radstock, BA3 5TY.