Conflict of Interest Policy
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What a conflict of interest is
A conflict of interest exists when a personal interest, relationship or outside activity could influence, or could reasonably appear to influence, a decision someone makes for SENZAIT. The conflict itself is not misconduct. Hiding it is.
This policy applies to every director, employee, trainee, contractor and agent of SENZAIT. We also ask our suppliers to declare any conflict that touches their dealings with us, using the declaration at the end of this policy.
Examples of what must be declared
- A financial interest, directly or through a family member, in a supplier, customer, competitor or agent of SENZAIT.
- A family member or close friend working for, or owning part of, a company we buy from, sell to or compete with.
- An outside job, directorship, consultancy or business that overlaps with SENZAIT’s work or uses SENZAIT’s time, equipment or information.
- Being in a position to award work, approve an invoice or select a supplier where the other party is a relative or a personal connection.
- Receiving any gift, hospitality or benefit from a supplier or customer above the limits in our Anti-Bribery and Anti-Corruption Policy.
- Using SENZAIT’s confidential information, client contacts or intellectual property for personal gain or for another business.
Family members and closely connected persons, for this policy, means spouse, parents, children, siblings, their spouses, anyone living in the same household, and any business in which those people hold an interest.
What to do
Declare it in writing to the Director as soon as you become aware of it, before the decision it could affect is taken. Where the conflict is your own, do not take part in the decision. The Director records the declaration, decides how the conflict is managed, and records that decision too. Managing a conflict usually means one of three things: the person steps out of the decision, a second person checks it, or the relationship is ended.
Where the conflict concerns the Director personally, it is declared to the Board of SENZAIT as required by section 184 of the Companies Act 2013, recorded in the minutes, and the Director does not vote on the matter.
Every director and employee makes a declaration when they join, and again each year, even if there is nothing to declare.
Suppliers and agents
We ask every supplier, agent and consultant to declare, before we appoint them and whenever things change, any personal, family or financial connection between their business and anyone at SENZAIT. A supplier who conceals a connection may be removed from our supplier list without further explanation.
Breach
Failing to declare a known conflict, or acting on a conflict that has been declared and not cleared, is a breach of our Code of Business Conduct and Ethics and is treated as serious misconduct.
Responsibility
The Director keeps the register of declarations and reviews it at least once a year. Questions go to [email protected] with the subject line “CONFLICT OF INTEREST”.
Mr. Vishalkumar Suthar, Director · SENZAIT PRIVATE LIMITED · Gandhinagar, 1 October 2026
Conflict of Interest Declaration
To: SENZAIT PRIVATE LIMITED, E002, Pramukh Pride, Behind Pratik Mall, Randesan, Gandhinagar 382007, Gujarat, India
I confirm that I have read SENZAIT’s Conflict of Interest Policy and that, to the best of my knowledge:
☐ I have no conflict of interest to declare.
☐ I declare the following interest, relationship or activity:
_____________________________________________________________________________
_____________________________________________________________________________
I undertake to inform SENZAIT in writing promptly if this declaration ceases to be accurate, and I understand that a conflict which is not declared may lead to the end of my employment, engagement or supplier relationship.
Name: ______________________________ Position or company: ______________________________
Signature: ______________________________ Date: ____________
For SENZAIT: received by ______________________________ on ____________ · Decision: ______________________________