Conflict-of-Interest Policy

1. Applicability
   1. 1 DLearners has adopted this Conflict-of-Interest Policy (“Policy”) to avoid and mitigate Conflicts of Interest or the appearance of Conflicts of Interest.
   1. 2 This Policy applies to all DLearners Personnel, including Employees and Consultants.
   1. 3 DLearners Personnel are required to abstain from acting on DLearners’s behalf in matters where a Conflict of Interest, or the appearance of a Conflict of Interest, exists.
   1. 4 DLearners Personnel may not accept travel, gifts, or entertainment from a third party that will unduly influence their responsibilities.
   1. 5 DLearners Personnel are required to disclose before entering into the relationships, or immediately upon becoming aware of any actual or potential Conflicts of Interest.
   1. 6 This Policy applies to all DLearners Personnel, including Employees and Consultants.
2. Definitions
   1. Employee: Refers to an individual employed by DLearners.
   2. Conflict of Interest: Refers to when an individual has a personal interest to the extent that it affects, or might provide an incentive to affect, the individual’s performance of duties at DLearners. The term Conflict of Interest includes activities that create actual or potential conflicts of interest and includes the activities that create the appearance of a conflict of interest.
   3. Consultant: Refers to a person who has been engaged by DLearners for a fee or other consideration.
3. General Policy
   • DLearners Personnel should always perform their responsibilities in the best interests of DLearners.
   • DLearners Personnel should be free from influences that may benefit themselves or third-parties when working for DLearners.
   • DLearners Personnel must abstain from acting on behalf of DLearners in matters where a Conflict of Interest may exist.
   • They should also avoid any situation that might lead their loyalties to become divided in a manner that creates a Conflict of Interest or the appearance of a Conflict of Interest.
   • DLearners Personnel must also ensure that any work they perform outside of their duties in DLearners do not conflict with DLearners’s or their individual obligations, under any funding agreement, contract, or their terms of engagement with DLearners.
   • DLearners Personnel must seek prior permission from the Programme Director before agreeing to begin any of the following activities that relate to their responsibilities at DLearners:
4. Resulting in compensation in excess of Rs. 25,000;
5. Appointments to a fiduciary board; or
6. Formal paid or unpaid advisory roles for any government or government entity.
   • DLearners Personnel should ensure that their activities outside DLearners are their own and not imputed to DLearners.
   • If any DLearners Personnel engage in activities in which they must make decisions that impact DLearners (e.g., being on the board of entity making a grant to DLearners or an organisation entering into a contract with DLearners) must recuse themselves from any deliberations related to DLearners.
   • DLearners Personnel may not, except with advance written approval from the Programme Director, knowingly have a material interest in:
7. Any entity which is a supplier, or service provider to DLearners;
8. Any organizations that directly competes with DLearners; or
9. An organisation that directly funds the work of DLearners

Explanation: “Having a material interest in a third party” may include:

• Serving as a director, officer, or employee of a third party (a person or entity)
• Performing work or services for, or receiving compensation (including consulting fees, substantial gifts, entertainment, services, travel reimbursement, or loans) for a third party;
• Being materially indebted to a third party;
• Having a personal contract or understanding with a third party

• DLearners Personnel are prohibited from accepting gifts valued in excess of Rs. 25,000 (“gifts”) from any individuals or organisations that DLearners is or has been engaged with. Gifts may include travel, meals, lodging, entertainment, cash or cash equivalents, physical objects, or services.

Explanation: This prohibition is not intended to apply to travel, meals, entertainment, or the like for DLearners work, including attendance at conferences, outreach for funding, solicitation and stewardship and research-related travel.

It is intended to apply to travel, meals, entertainment and the like (received other than from family and friends) that have no purpose for DLearners or the DLearners component is not significant, or the social component does not comport with the overall professional standard of avoiding actual or apparent conflicts of interest.