Conflict of Interest Policy

1. Purpose

To prevent personal, family, financial or organisational interests from influencing decisions taken on behalf of hangel, and to explain how conflicts of interest are declared and managed.

2. Scope

Board and Supervisory Board members, employees, the Association's own volunteers, super-admins, people giving expert opinions in Write Your Project, and consultants working on behalf of the International Social Benefit Association.

3. Principles

A conflict of interest exists when a decision a person takes on behalf of hangel could benefit or harm that person, a relative or an organisation they are connected with. Examples:

• assessing the application, transparency documents, complaint or payout of an NGO, brand or club with which the person has a management or membership relationship,
• buying goods or services for the Association from a company owned by a relative or in which the person is a partner,
• taking a decision about a sponsor or brand while having a personal interest relationship with it,
• as an expert, assessing a project they prepared or advised on.

Rules:

1. When a conflict or the appearance of a conflict is noticed, it is declared in writing (e-mail is enough) before the decision is taken.
2. The person declaring does not take part in discussing or voting on that decision; another authorised person handles it.
3. Conflicts are not hidden; if a conflict is discovered later, the decision is reassessed.
4. Platform permissions are never used for personal benefit or for the benefit of a connected organisation.

4. Roles and responsibilities

• Everyone: declares their own conflicts and steps back from the decision.
• Board of Directors: assesses declarations and reassigns the task where needed; for conflicts of its own members, the member concerned does not vote.
• Supervisory Board: assesses allegations concerning Board members.

5. How it works at hangel today

• Super-admin permissions are granted section by section; actions such as payouts, approvals and rate changes are written to the audit log. This log makes it possible to see later who took a decision.
• Decisions on sponsorship and event support are taken by the organisation running the event, not by hangel; hangel's sponsorship service-fee rate is recorded at the moment of acceptance.
• Organisations' transparency documents are reviewed by a super-admin or a lawyer; the decision is tied to the reviewed file and is reset if the file changes.

6. Not yet in place and our goals

• There is no written declaration-of-interest form or annual declaration yet; our goal is to collect an annual declaration from Board members and super-admins.
• The software does not technically prevent a super-admin from deciding on a record related to an organisation they are connected with; for now the rule relies on declaration.
• There is no central register of declarations.

7. How to raise a concern

• Declarations: in writing to the Board of Directors or to ismailhilmi@hangel.org.
• Allegations of a hidden conflict: kvkk@hangel.org (subject "Whistleblowing — Confidential").

8. Review

At least once a year.

9. Related documents

Code of Ethics · Gifts and Hospitality Policy · Anti-Bribery and Corruption Policy · Existing "Conflict of Interest Policy" (contracts: cikar-catismasi-politikasi)