1. Purpose

This Conflict of Interest Policy establishes the requirements for identifying, disclosing, and managing conflicts of interest — actual or perceived — that may arise in connection with neutral appointments, certification decisions, governance processes, and any other TheNeutrals.ORG™ activities.

The independence and impartiality of TheNeutrals.ORG™ neutrals and governance processes is the foundation of the Organisation's credibility. Any conflict of interest — actual or perceived — that is not disclosed and managed appropriately undermines that foundation.

2. What constitutes a conflict of interest

A conflict of interest exists where a certified neutral, Neutral Advisor, or Council member has any interest — financial, professional, personal, or reputational — that could affect or be perceived to affect their independence or impartiality in relation to a neutral appointment, certification decision, or governance matter.

Conflicts include but are not limited to:

• Prior professional relationship with any party, their counsel, or related entity
• Current or prior financial relationship with any party or related entity
• Personal relationship with any party, director, or key employee of a party
• Prior involvement in the subject matter of the dispute in any capacity
• Any financial, reputational, or professional interest in the outcome
• Any relationship that could create a reasonable perception of bias

3. Disclosure obligations

Before accepting any appointment or participating in any governance decision, every certified neutral and Council member must:

• Conduct a thorough conflict-of-interest check covering all parties, counsel, and related entities
• Disclose to TheNeutrals.ORG™ any actual or potential conflict identified
• Allow TheNeutrals.ORG™ to assess the disclosed conflict and determine whether the appointment or participation may proceed
• Immediately disclose any conflict that arises during the course of an engagement or governance process

Disclosure is made to the TheNeutrals.ORG™ governance team at [email protected]. All disclosures are treated as confidential.

4. Waiver by consent

A disclosed conflict may be waived by the written consent of all parties to the relevant engagement, following full disclosure of the nature of the conflict. Waiver requires the informed, written consent of all parties and is recorded by TheNeutrals.ORG™.

Not all conflicts are capable of being waived. Where the conflict is such that it would prevent genuine neutrality — regardless of consent — TheNeutrals.ORG™ will not proceed with the appointment.

5. Non-disclosure consequences

Failure to disclose a conflict of interest is a serious breach of this policy and the Code of Ethical Conduct. It may result in disqualification from the appointment, suspension or revocation of certification, and publication of a governance finding.