Purpose
The purpose of this policy is to protect the integrity of Sultan Institute of Management
Training (SIMT) by providing guidance on identifying, disclosing, and managing conflicts of
interest.
Scope
This policy applies to all staff, faculty, board members, subcontractors, and any other
relevant individuals associated with SIMT.
Definitions
• Conflict of Interest: Any situation where personal, financial, or other interests could
compromise or appear to compromise an individual’s decisions or actions on behalf
of SIMT.
Duty to Disclose
All individuals must disclose any potential conflicts of interest as soon as they become
aware of them. Disclosures should be made in writing to the designated Conflict of Interest
Officer.
Review Process
The Conflict of Interest Officer will review all disclosures and determine whether a conflict
of interest exists. If a conflict is identified, the officer will recommend steps to manage,
reduce, or eliminate the conflict.
Managing Conflicts of Interest
• Recusal: The individual may be required to abstain from decision-making processes
related to the conflict.
• Divestment: The individual may need to divest financial interests that create a
conflict.
• Restructuring Duties: Adjusting the individual’s responsibilities to mitigate the
conflict.
Confidentiality
All disclosures and related discussions will be handled confidentially and shared only with
those involved in the review process.
Consequences of Non-Compliance
Failure to disclose a conflict of interest or comply with this policy may result in disciplinary
action, up to and including termination of employment or association with SIMT.
Regular Review
This policy will be reviewed annually to ensure its effectiveness and relevance. Amendments
will be made as necessary.