Legal & governance

Conflicts of Interest

Disclosure, allocation of responsibility, withdrawal and impartial review.

USG governanceReviewed: 3 October 2026

Impartial handling depends on timely disclosure and appropriate allocation of responsibilities. Anyone involved in USG professional appointments, service delivery, assessment, certification, partnership approval or complaint handling should disclose personal, professional or financial relationships that may affect the impartial performance of their duties.

Disclosure covers actual conflicts of interest, potential conflicts of interest and circumstances that may reasonably cause others to question impartiality. The duty to disclose continues throughout the process; new relevant circumstances should be disclosed promptly.

The relevant department is responsible for recording disclosures, with an appropriate person who has no conflict of interest assessing how the matter should be handled. Measures may include withdrawal from the relevant decision, adjustment of responsibilities, replacement of a professional or a separately arranged review. Where participants’ informed consent is required, the relevant circumstances should be fully explained. Their consent cannot replace any requirement for withdrawal or prohibition under the applicable rules.

Matters involving a department head should be referred to company management. Matters involving management or a director should be handled by a person who is not involved and has the necessary authority. Where suitable internal arrangements cannot be made, external professional support should be sought. A person with a conflict of interest should neither decide how their own conflict is to be managed nor participate in a related review.

Commercial partnerships, referrals, payments or donations should not replace qualification standards or influence professional assessments or complaint handling. Where a conflict of interest cannot be adequately resolved, the relevant appointment or decision should not proceed.

Conflict of interest reports and concerns about their handling

compliance@universalsustainablegrowth.org

For a review of handling, see Complaints and Review.