Conflict of Interest Policy

Bangladesh Nature Foundation (BNF) is committed to integrity, impartiality, transparency, accountability, responsible decision-making, and public trust. As a nonprofit organization working in biodiversity conservation, environmental protection, climate resilience, community development, research, education, and sustainable livelihoods, BNF recognizes the importance of identifying and appropriately managing actual, potential, and perceived conflicts of interest.

A conflict of interest can arise when an individual’s personal, professional, financial, family, business, academic, social, or other interests could improperly influence—or could reasonably appear to influence—their responsibilities or decisions on behalf of BNF. Having a conflict of interest does not necessarily mean that a person has acted improperly. The purpose of this Policy is to ensure that conflicts are disclosed, assessed, managed, documented, and resolved appropriately so that organizational decisions remain objective and consistent with BNF’s mission and responsibilities. This Policy applies to BNF’s governance bodies, management, employees, volunteers, consultants, researchers, advisers, project personnel, and other persons acting on behalf of or representing BNF.

1. Purpose

The purposes of this Policy are to:

  • Protect the integrity and independence of BNF’s decision-making;
  • Promote objective and transparent organizational decisions;
  • Identify conflicts of interest at an early stage;
  • Establish procedures for disclosure and management of conflicts;
  • Prevent personal interests from improperly influencing BNF activities;
  • Protect BNF’s funds, assets, reputation, research integrity, and public trust;
  • Promote fairness in recruitment, procurement, contracting, partnerships, grants, and project decisions;
  • Provide a consistent framework for managing conflicts involving governance members, staff, consultants, partners, and other representatives;
  • Support accountability to communities, donors, government authorities, research institutions, and other stakeholders.

2. Scope

This Policy applies to individuals involved in BNF’s organizational activities, including:

  • General Committee members;
  • Executive Committee members;
  • Advisory or technical advisers;
  • Executive Director;
  • Senior management;
  • Program and project managers;
  • Finance and administrative personnel;
  • Employees;
  • Volunteers;
  • Interns;
  • Consultants;
  • Researchers;
  • Technical experts;
  • Trainers;
  • Contractors;
  • Procurement personnel;
  • Selection and recruitment panel members;
  • Grant or funding reviewers;
  • Project committee members;
  • Representatives acting on behalf of BNF;
  • Other persons whose decisions or actions may materially affect BNF.

The Policy also applies to conflicts involving BNF’s relationships with:

  • Donors;
  • Government agencies;
  • Universities;
  • Research institutions;
  • NGOs;
  • Private-sector organizations;
  • Suppliers;
  • Contractors;
  • Consultants;
  • Community organizations;
  • Project beneficiaries;
  • Research participants;
  • Other partners and stakeholders.

3. What Is a Conflict of Interest?

A conflict of interest exists when an individual’s personal or external interests intersect with their BNF responsibilities in a way that could affect, or reasonably appear to affect, their impartial judgment. Conflicts may arise from:

  • Financial interests;
  • Family relationships;
  • Personal relationships;
  • Business relationships;
  • Employment or consultancy relationships;
  • Academic relationships;
  • Research collaborations;
  • Professional affiliations;
  • Ownership or management of a business;
  • Gifts or benefits;
  • Outside employment;
  • Political or community relationships;
  • Personal disputes or interests;
  • Other circumstances capable of influencing objective decision-making.

The existence of an interest does not automatically constitute misconduct. The relevant question is whether the interest could improperly influence, or reasonably appear capable of influencing, a person’s BNF responsibilities.

4. Types of Conflicts of Interest

BNF recognizes three principal categories.

4.1 Actual Conflict of Interest

An actual conflict exists where a person’s current personal or external interest directly conflicts with their BNF responsibilities.

Example: A person involved in selecting a supplier has a financial interest in one of the companies submitting a quotation.

4.2 Potential Conflict of Interest

A potential conflict exists where circumstances could reasonably develop into an actual conflict.

Example: A BNF employee is involved in a project involving an organization where the employee’s close relative is being considered for employment.

4.3 Perceived Conflict of Interest

A perceived conflict exists where a reasonable person could believe that an individual’s external interests might influence their BNF decision, even if the individual believes that they can remain impartial.

Perceived conflicts should not automatically be treated as evidence of wrongdoing. However, BNF may manage them to protect organizational integrity and stakeholder confidence.

5. Common Sources of Conflict

Conflicts may arise in many organizational situations. These may include:

  • Procurement;
  • Recruitment;
  • Consultancy appointments;
  • Project partner selection;
  • Grant decisions;
  • Funding allocation;
  • Contract negotiations;
  • Financial decisions;
  • Research collaboration;
  • Publication and authorship;
  • Community beneficiary selection;
  • Training opportunities;
  • Travel or participation opportunities;
  • Environmental project decisions;
  • Property or resource transactions;
  • Donations;
  • Fundraising;
  • Supplier relationships;
  • Personal business interests;
  • Family relationships;
  • Outside employment;
  • Academic supervision;
  • Professional relationships.

This list is not exhaustive.

6. Financial Interests

A financial conflict may arise when an individual has a financial interest that could influence a BNF decision. Examples include:

  • Ownership of a company;
  • Shares or investments;
  • Partnership interests;
  • Directorships;
  • Financial benefits;
  • Loans;
  • Commissions;
  • Contractual benefits;
  • Business interests of a close family member;
  • Expected financial gain from a BNF decision.

Individuals must disclose relevant financial interests where those interests could affect or reasonably appear capable of affecting their BNF responsibilities.

7. Family and Close Personal Relationships

A conflict may arise where a BNF decision concerns a:

  • Spouse or partner;
  • Parent;
  • Child;
  • Sibling;
  • Other close family member;
  • Close personal associate.

Examples include:

  • Recruitment;
  • Promotion;
  • Contracting;
  • Procurement;
  • Consultancy;
  • Scholarships or training opportunities;
  • Project beneficiary selection;
  • Research collaboration.

BNF does not prohibit family members from working with or benefiting from legitimate BNF opportunities. However, decisions involving close relatives should be managed to avoid favoritism or improper influence.

8. Personal Relationships

Close friendships, personal relationships, disputes, or other significant relationships may create actual or perceived conflicts. Individuals should disclose relationships that could reasonably affect their impartiality in a particular BNF decision. BNF will consider the circumstances rather than assuming that every friendship or professional relationship constitutes a conflict.

9. Outside Employment and Business Activities

BNF recognizes that staff and other representatives may have legitimate external professional or business interests. However, external activities must not:

  • Improperly interfere with BNF responsibilities;
  • Misuse BNF resources;
  • Misrepresent an individual’s authority;
  • Create an undisclosed conflict;
  • Divert BNF opportunities;
  • Use confidential BNF information for personal benefit;
  • Damage BNF’s reputation or legitimate interests.

Relevant outside employment or business interests should be disclosed where they may conflict with BNF responsibilities.

10. Gifts, Hospitality, and Benefits

Gifts, hospitality, discounts, travel, entertainment, services, or other benefits may create an actual or perceived conflict of interest. Individuals acting on behalf of BNF should not accept benefits that could reasonably:

  • Influence a BNF decision;
  • Create an obligation to another party;
  • Affect impartiality;
  • Create an appearance of preferential treatment;
  • Be connected to a procurement, recruitment, funding, contracting, or other decision.

Nominal or customary hospitality may be acceptable where it is reasonable, transparent, and does not influence decision-making. Where there is uncertainty, the individual should disclose the benefit to the appropriate supervisor or governance authority.

11. Procurement and Supplier Selection

Conflict-of-interest controls are particularly important in procurement. Anyone involved in:

  • Supplier selection;
  • Request for quotations;
  • Tender evaluation;
  • Contract negotiation;
  • Purchase approval;
  • Vendor management;
  • Payment approval

must disclose any relevant personal, family, financial, business, or other relationship with a supplier or prospective supplier. A person with a material conflict should not participate in the relevant decision unless an appropriate authority determines that participation can be managed without compromising integrity.

12. Recruitment and Employment

BNF seeks to ensure that recruitment and employment decisions are based on relevant qualifications, experience, suitability, organizational needs, and applicable selection criteria. A person involved in recruitment must disclose relevant relationships with an applicant. Where appropriate, the conflicted person should:

  • Withdraw from the selection process;
  • Avoid influencing other panel members;
  • Avoid accessing confidential applicant information unnecessarily;
  • Allow an independent or otherwise appropriate person to participate in the decision.

Family or personal relationships must not be used to secure an improper employment advantage.

13. Consultants and Contractors

Consultants and contractors working with BNF may also have external interests. Before undertaking relevant assignments, BNF may require consultants or contractors to disclose interests that could affect their independence. This may be particularly important where they are engaged for:

  • Evaluation;
  • Auditing;
  • Research;
  • Procurement;
  • Technical assessment;
  • Grant review;
  • Policy development;
  • Environmental assessment;
  • Scientific advice;
  • Recruitment;
  • Monitoring and evaluation.

14. Research Conflicts of Interest

BNF recognizes that research activities can involve complex professional and financial relationships. Researchers, advisers, reviewers, and project personnel should disclose relevant conflicts involving:

  • Research funding;
  • Commercial interests;
  • Research collaborators;
  • Academic supervision;
  • Institutional affiliations;
  • Intellectual property;
  • Competing research interests;
  • Consultancy relationships;
  • Personal relationships with researchers or participants;
  • Potential financial benefits from research outcomes.

Disclosures should be managed in accordance with relevant research ethics, research integrity, publication, and data-management requirements.

15. Research Publication and Authorship

Conflicts may arise in:

  • Manuscript preparation;
  • Authorship decisions;
  • Peer review;
  • Editorial activities;
  • Publication decisions;
  • Data interpretation;
  • Research assessment.

A person should not use their position within BNF to obtain inappropriate authorship, publication advantage, editorial influence, or other academic benefit. Relevant financial, institutional, professional, or personal conflicts should be disclosed in accordance with the requirements applicable to the research or publication.

16. Community and Beneficiary Selection

BNF may work with communities and select participants or beneficiaries for particular activities. Persons involved in selection should not improperly favor:

  • Family members;
  • Friends;
  • Business associates;
  • Political or personal associates;
  • Individuals from whom they expect a private benefit.

Where beneficiary selection criteria exist, decisions should follow the approved criteria and be documented where appropriate.

17. Donors and Funding Relationships

BNF may receive grants, donations, gifts, or other forms of support. Individuals involved in fundraising or donor relationships should disclose relevant conflicts where a personal or financial interest could affect:

  • Donor selection;
  • Funding negotiations;
  • Grant allocation;
  • Reporting;
  • Contracting;
  • Use of funds.

BNF will seek to protect its mission and independence when engaging with donors and funding partners.

18. Partnerships and Collaborations

BNF may collaborate with:

  • Government agencies;
  • Universities;
  • Research institutions;
  • NGOs;
  • Private-sector organizations;
  • Community organizations;
  • International organizations;
  • Technical experts;
  • Other stakeholders.

Potential conflicts should be considered when selecting or managing partners. BNF may assess:

  • Shared interests;
  • Financial relationships;
  • Personal relationships;
  • Commercial interests;
  • Institutional affiliations;
  • Previous contractual relationships;
  • Competing organizational interests.

19. Conflict in Governance

Members of BNF’s General Committee, Executive Committee, Advisory bodies, and other governance structures have a particular responsibility to identify and disclose conflicts. A governance member should disclose a conflict before participating in a decision where their external interest could affect, or reasonably appear to affect, their impartiality. Depending on the circumstances, the person may be required to:

  • Leave the meeting during discussion;
  • Refrain from voting;
  • Abstain from influencing other members;
  • Refrain from accessing certain information;
  • Have the conflict recorded in the meeting minutes.

20. Executive Committee and General Committee Decisions

Where a conflict involves an Executive Committee or General Committee member, the relevant body should determine an appropriate management measure. The decision should, where appropriate, be documented in the minutes. The conflicted member should not improperly influence the decision. Where necessary, the matter may be referred to an independent or otherwise appropriate authority for review.

21. Disclosure of Conflicts

Individuals covered by this Policy should disclose relevant conflicts as soon as they become aware of them. Disclosure should generally include:

  • Nature of the interest;
  • Parties involved;
  • Relevant project, transaction, decision, or activity;
  • Nature of the potential benefit or relationship;
  • Any other information necessary to assess the conflict.

Disclosure does not itself constitute wrongdoing.

The purpose of disclosure is to allow BNF to determine an appropriate management response.

22. Conflict of Interest Declaration

BNF may require relevant personnel to complete a conflict-of-interest declaration:

  • Upon appointment;
  • At the beginning of a project;
  • Annually;
  • Before participating in a sensitive decision;
  • When circumstances change;
  • At another time considered appropriate.

Declarations may be maintained by the relevant administrative, governance, human resources, project, or compliance function.

23. How Conflicts Are Managed

After disclosure, BNF may use one or more management measures. These may include:

23.1 Disclosure

The conflict may be documented and openly recognized within the relevant decision-making process.

23.2 Recusal

The individual may withdraw from discussion, evaluation, recommendation, or voting.

23.3 Independent Review

Another qualified person may review or make the decision.

23.4 Separation of Duties

Responsibilities may be divided between different people to reduce the risk of improper influence.

23.5 Restricted Access

The conflicted person may be prevented from accessing particular confidential information.

23.6 Monitoring

Additional oversight may be introduced.

23.7 Change of Responsibility

The individual’s role in the relevant matter may be reassigned.

23.8 Contractual or Organizational Measures

Where necessary, BNF may modify, suspend, or terminate an arrangement in accordance with applicable terms.

24. Assessing the Appropriate Response

Not every disclosed interest requires withdrawal from an activity. BNF may consider:

  • Nature of the conflict;
  • Degree of influence;
  • Financial significance;
  • Relationship involved;
  • Potential benefit;
  • Importance of the decision;
  • Sensitivity of information;
  • Risk to BNF;
  • Risk to stakeholders;
  • Public perception;
  • Donor or contractual requirements;
  • Relevant organizational policies.

The objective is to manage the conflict proportionately while protecting organizational integrity.

25. Recording Conflicts

Where appropriate, BNF may record:

  • Conflict disclosures;
  • Declarations;
  • Decisions concerning management;
  • Recusals;
  • Alternative decision-makers;
  • Meeting minutes;
  • Corrective measures.

Records should be maintained securely and handled according to applicable privacy and confidentiality requirements.

26. Confidentiality of Conflict Disclosures

Conflict declarations may contain personal or commercially sensitive information. BNF will seek to limit access to such information to persons with a legitimate need to know. Information may nevertheless be disclosed where necessary for:

  • Governance;
  • Audit;
  • Investigation;
  • Donor requirements;
  • Legal or regulatory obligations;
  • Safeguarding;
  • Protection of BNF’s interests.

27. Failure to Disclose

Failure to disclose a relevant conflict may constitute a breach of this Policy where the person knew, or reasonably should have known, that disclosure was required. Depending on the circumstances, BNF may:

  • Request clarification;
  • Require a retrospective declaration;
  • Review affected decisions;
  • Introduce additional controls;
  • Reassign responsibilities;
  • Require corrective action;
  • Apply appropriate organizational measures.

The response should be proportionate to the circumstances and the nature of the non-disclosure.

28. Deliberate Concealment

Deliberately concealing a material conflict, providing knowingly false information, or using a conflict for personal gain may constitute serious misconduct. BNF may investigate such circumstances and take appropriate action under applicable organizational policies, employment arrangements, contracts, or other relevant procedures.

29. Conflicts and Organizational Resources

BNF resources must not be used to obtain improper personal benefit. Organizational resources may include:

  • Funds;
  • Vehicles;
  • Equipment;
  • Offices;
  • Computers;
  • Databases;
  • Research materials;
  • Intellectual property;
  • Staff time;
  • Confidential information;
  • Organizational contacts;
  • Donor information;
  • Project information.

Individuals must use BNF resources responsibly and for authorized organizational purposes.

30. Confidential Information and Conflicts

Individuals must not use confidential BNF information obtained through their position to obtain an improper personal, family, academic, commercial, or other benefit. This may include information relating to:

  • Funding;
  • Procurement;
  • Suppliers;
  • Staff;
  • Beneficiaries;
  • Communities;
  • Research;
  • Donors;
  • Partnerships;
  • Contracts;
  • Organizational strategy.

Confidentiality obligations may continue after a person’s relationship with BNF ends.

31. Organizational Opportunities

Individuals should not improperly take for themselves an opportunity that:

  • Was identified through their BNF position;
  • Was developed using BNF resources;
  • Was intended for BNF;
  • Would reasonably be understood as belonging to BNF.

Where an opportunity may create a conflict between an individual’s personal interests and BNF’s legitimate interests, the matter should be disclosed and appropriately assessed.

32. Political and Public Activities

BNF is a non-political organization. Individuals may have lawful personal civic or public interests outside BNF. However, they must not:

  • Represent personal political views as official BNF positions;
  • Use BNF resources for political purposes;
  • Misuse BNF’s name or reputation;
  • Imply BNF endorsement of a political candidate, party, or campaign;
  • Allow political activities to improperly influence BNF decisions.

Where an external public role could create a conflict with BNF responsibilities, the individual should disclose the matter to the appropriate organizational authority.

33. Conflict of Interest and Non-Discrimination

The existence of a conflict should be managed objectively. BNF will not treat a person unfairly merely because they disclose a legitimate external interest. The purpose of this Policy is to manage risks and protect integrity, not to prohibit reasonable personal, professional, family, academic, or community relationships.

34. Conflicts Involving Volunteers and Interns

Volunteers and interns may also encounter conflicts. They should disclose relevant interests when participating in:

  • Procurement;
  • Recruitment;
  • Research;
  • Community selection;
  • Data collection;
  • Project decisions;
  • External representation;
  • Other sensitive activities.

Supervisors should provide appropriate guidance where a conflict arises.

35. Conflicts Involving Donated Goods or Services

BNF may receive donated goods, services, equipment, professional assistance, or other non-cash contributions. Individuals involved in accepting or evaluating such contributions should disclose any personal or external interest that could influence the decision. Donations should not create inappropriate obligations or compromise BNF’s independence.

36. Conflict of Interest and Fundraising

Fundraising personnel and representatives should avoid arrangements where personal financial interests could influence fundraising decisions. Any commissions, incentives, referral arrangements, or other benefits connected with fundraising must be transparent, authorized, and consistent with BNF’s organizational requirements. BNF should not allow personal financial interests to determine whether a particular donor, funding source, or partnership is pursued.

37. Conflict of Interest in Monitoring and Evaluation

Individuals conducting monitoring, evaluation, assessment, or audit activities should disclose relevant interests that could affect their independence. Where appropriate, an independent reviewer may be appointed. Evaluation findings should be based on relevant evidence rather than personal or financial interests.

38. Conflict of Interest in Financial Management

Personnel responsible for:

  • Budget preparation;
  • Payment authorization;
  • Accounting;
  • Financial review;
  • Procurement;
  • Internal controls;
  • Audit coordination

should disclose relevant conflicts.

Where practical, BNF should maintain appropriate separation of duties so that a single person does not control incompatible stages of a sensitive financial transaction.

39. Conflict of Interest in Project Management

Project personnel should disclose conflicts that could affect:

  • Beneficiary selection;
  • Procurement;
  • Partner selection;
  • Community engagement;
  • Recruitment;
  • Project resource allocation;
  • Research;
  • Monitoring;
  • Reporting;
  • Environmental decisions.

Project-specific conflict management procedures may be established where required.

40. Conflict of Interest in Environmental and Conservation Decisions

BNF works to protect biodiversity and natural ecosystems. Conflicts may arise where conservation decisions affect:

  • Private businesses;
  • Natural-resource users;
  • Land interests;
  • Commercial activities;
  • Community resource access;
  • Project partners;
  • Suppliers;
  • Individuals with financial interests.

Relevant interests should be disclosed and considered when making conservation or environmental decisions. BNF seeks to base such decisions on appropriate evidence, project objectives, environmental considerations, stakeholder interests, and applicable requirements.

41. Conflict of Interest in Community Economic Activities

BNF may support sustainable livelihoods, small enterprises, market linkages, training, and community-based economic activities. Personnel involved in these activities should not use their position to obtain preferential access to:

  • Grants;
  • Equipment;
  • Training;
  • Contracts;
  • Market opportunities;
  • Business opportunities;
  • Project resources.

Selection should follow relevant project criteria and be documented where appropriate.

42. Conflict of Interest and Partnerships With Private Organizations

When BNF works with private-sector organizations, relevant commercial relationships should be disclosed where they may influence organizational decisions. Partnerships should be evaluated according to appropriate organizational, project, environmental, ethical, financial, and reputational considerations. A partnership should not be presented as BNF endorsement of all activities or interests of the partner unless such endorsement has been expressly authorized.

43. Conflict of Interest and Communications

BNF’s website, publications, reports, social media, research outputs, and public communications should not be used to provide undisclosed personal or commercial benefits to individuals associated with BNF. Individuals must not use their BNF position to improperly promote their own businesses, services, products, publications, or private interests.

44. Website and Digital Content

Conflicts may arise in relation to:

  • Website content;
  • Advertising or sponsorship;
  • External links;
  • Service providers;
  • Digital platforms;
  • Analytics;
  • Donations;
  • Publication arrangements;
  • Promotional materials.

BNF should disclose or appropriately manage material relationships where they could affect the impartiality or transparency of website content. The use of an external organization’s name, logo, service, or link should not automatically be interpreted as BNF endorsement.

45. Conflict of Interest and Intellectual Property

Individuals should disclose relevant interests involving intellectual property where BNF decisions concern:

  • Research outputs;
  • Publications;
  • Software;
  • Databases;
  • Training materials;
  • Photographs;
  • Maps;
  • Designs;
  • Innovations;
  • Commercialization.

Ownership and use of intellectual property should be determined according to applicable agreements and BNF policies.

46. Conflict of Interest and Data

Individuals must not use BNF data or confidential information for undisclosed personal or commercial purposes where doing so would conflict with their responsibilities. Particular care should be taken with:

  • Personal data;
  • Beneficiary information;
  • Community information;
  • Research data;
  • Sensitive ecological information;
  • Species-location information;
  • Donor information;
  • Confidential project data.

47. Seeking Advice

Individuals should seek guidance when they are uncertain whether a situation constitutes a conflict.

It is preferable to disclose a reasonable concern for assessment rather than conceal an interest because of uncertainty. Guidance may be sought from:

  • Immediate supervisor;
  • Executive Director;
  • Relevant senior management;
  • Finance or administrative authority;
  • Project manager;
  • Governance authority;
  • Other designated BNF personnel.

48. Responsibility for Implementation

General Committee

The General Committee provides overall organizational oversight and may establish or approve relevant governance arrangements.

Executive Committee

The Executive Committee oversees major organizational matters and may review significant conflicts involving governance, management, finances, projects, or organizational interests.

Executive Director

The Executive Director is responsible for implementing this Policy within day-to-day organizational operations and ensuring that material conflicts are appropriately escalated.

Managers and Supervisors

Managers and supervisors are responsible for identifying and appropriately addressing conflicts within their areas of responsibility.

All Personnel

Every person covered by this Policy is responsible for:

  • Recognizing relevant conflicts;
  • Disclosing them promptly;
  • Cooperating with management measures;
  • Avoiding improper influence;
  • Protecting BNF’s interests;
  • Maintaining confidentiality.

49. Governance Records

Where appropriate, significant conflict-of-interest matters may be recorded in:

  • Meeting minutes;
  • Conflict declarations;
  • Procurement records;
  • Recruitment records;
  • Project files;
  • Contract files;
  • Governance records;
  • Financial records.

Records should contain sufficient information to demonstrate that the conflict was appropriately considered without unnecessarily disclosing confidential personal information.

50. Monitoring and Review

BNF may periodically review the implementation of this Policy. Review activities may consider:

  • Conflict declarations;
  • Procurement decisions;
  • Recruitment processes;
  • Governance decisions;
  • Financial controls;
  • Project implementation;
  • Research activities;
  • Complaints and investigations;
  • Audit findings;
  • Lessons learned.

Where recurring risks are identified, BNF may strengthen relevant procedures, training, controls, or reporting requirements.

51. Training and Awareness

BNF may provide appropriate orientation or training concerning conflicts of interest. Training may cover:

  • Identifying conflicts;
  • Disclosure requirements;
  • Procurement conflicts;
  • Recruitment conflicts;
  • Research conflicts;
  • Gifts and hospitality;
  • Confidentiality;
  • Recusal;
  • Documentation;
  • Reporting concerns.

New staff, governance members, consultants, and other relevant personnel may be introduced to this Policy as part of organizational orientation.

52. Relationship With Other BNF Policies

This Policy should be read together with other relevant BNF policies and organizational procedures, including:

  • Code of Conduct;
  • Anti-Fraud and Anti-Corruption Policy;
  • Whistleblower Policy;
  • Complaints & Feedback Policy;
  • Safeguarding Policy;
  • Gender Equality and Non-Discrimination Policy;
  • Environmental and Social Safeguards Policy;
  • Research Ethics Policy;
  • Research Integrity Policy;
  • Publication and Authorship Policy;
  • Privacy Policy;
  • Copyright & Intellectual Property Policy;
  • Financial Management procedures;
  • Procurement procedures;
  • Human Resources procedures.

A particular conflict may be subject to more than one policy or procedure.

53. Policy Does Not Prohibit Legitimate Relationships

This Policy is not intended to prevent reasonable and legitimate:

  • Family relationships;
  • Friendships;
  • Professional relationships;
  • Academic collaborations;
  • Community participation;
  • Outside employment;
  • Business ownership;
  • Research collaborations;
  • Volunteer activities.

The purpose is to ensure that such relationships do not improperly influence BNF decisions or create an unmanaged risk to the organization or its stakeholders.

54. Good-Faith Disclosure

BNF encourages early and good-faith disclosure of potential conflicts. A person who voluntarily discloses a potential conflict should not be treated as having committed misconduct merely because the conflict exists. Early disclosure allows BNF to determine an appropriate and proportionate management response.

55. Review of Decisions Affected by an Undisclosed Conflict

Where BNF identifies a material undisclosed conflict after a decision has been made, it may review the decision. Depending on the circumstances, BNF may:

  • Confirm the original decision;
  • Modify the decision;
  • Re-run a selection process;
  • Conduct an independent review;
  • Cancel or renegotiate an arrangement;
  • Take corrective action;
  • Refer the matter for further investigation.

The response should be proportionate to the nature and impact of the conflict.

56. False or Misleading Declarations

Individuals must provide accurate information when making conflict-of-interest declarations. Knowingly providing false or materially misleading information may be treated as a policy violation and may result in appropriate action. Unintentional omissions should generally be corrected as soon as they are identified.

57. External Disclosure

BNF may disclose relevant conflict-of-interest information to donors, regulators, auditors, research institutions, partners, or other authorized parties where required by:

  • Law or regulation;
  • Funding agreements;
  • Project agreements;
  • Audit requirements;
  • Research requirements;
  • Organizational obligations.

Any disclosure should be limited to information reasonably necessary for the relevant purpose.

58. Protection of BNF’s Independence

BNF seeks to maintain independent decision-making consistent with its mission and organizational objectives. External funding, partnerships, donations, technical assistance, research collaboration, or other relationships should not improperly control BNF’s organizational decisions. Potential conflicts involving external stakeholders should be assessed with appropriate consideration for organizational independence, transparency, and accountability.

59. Complaints Concerning Conflicts of Interest

Concerns about a suspected conflict of interest may be submitted through BNF’s Complaints & Feedback mechanism or, where appropriate, the Whistleblower or Anti-Fraud and Anti-Corruption reporting mechanism. A person reporting a concern in good faith should not be subject to retaliation. Complaints should contain factual information where possible and should avoid unnecessary disclosure of personal information.

60. Protection against Retaliation

BNF does not support retaliation against a person who:

  • Discloses a conflict in good faith;
  • Reports a suspected undisclosed conflict;
  • Participates in a review;
  • Provides relevant information;
  • Cooperates with an investigation.

Concerns about retaliation should be reported through the appropriate BNF complaints or reporting mechanism.

61. Policy Review and Updates

BNF may periodically review and update this Policy to reflect:

  • Organizational experience;
  • Governance decisions;
  • Program changes;
  • Donor requirements;
  • Research requirements;
  • Stakeholder feedback;
  • Identified risks;
  • Changes in organizational procedures;
  • Relevant standards and good practices.

The most recent version should be made available on the BNF website where appropriate.

62. Contact

Questions or concerns concerning this Conflict of Interest Policy may be directed to Bangladesh Nature Foundation through its official communication channels.

Bangladesh Nature Foundation (BNF)

Head Office: Sayman Road, Cox’s Bazar-4700, Bangladesh

Website: https://bdnature.org/

For confidential concerns, individuals should use the appropriate confidential reporting channel where one has been established.

Bangladesh Nature Foundation recognizes that public trust depends not only on the quality of its environmental and community programs but also on the integrity of the decisions through which those programs are designed, funded, implemented, evaluated, and communicated.

BNF therefore expects individuals acting on its behalf to identify relevant conflicts of interest, disclose them in a timely manner, cooperate with appropriate management measures, and avoid using organizational positions or resources for improper personal benefit.

BNF is committed to transparent decision-making, responsible stewardship of resources, impartiality, ethical conduct, and the protection of the interests of the communities, ecosystems, partners, donors, researchers, and stakeholders it serves.