Conflict of Interest
Annual and transactional conflict-of-interest declarations — what counts, what to disclose, and how recusal is handled.
Group Policy & Procedure | Document No. | P-POL-011 |
Group Supply Chain | Ver. No. | Rev Date | 0.4 | 08 APR 2026 |
Title: Conflict of Interest | Effective Date | 08 April 2026 |
BUKHATIR GROUP
Strength through Diversity
Group Policy and Procedure
Group Supply Chain (GSC)
Conflict of Interest
Disclosure, Recusal & Monitoring
Document No: P-POL-011
Copyright © 2026 Bukhatir Group
Revision Control
This document is issued under the authority of Bukhatir Group and applies when carrying out the activities described. Revisions may be issued as necessary under the authority of the Group Head of Procurement. Revision history is recorded below with every revised policy.
Revision History
Ver. No. | Effective Date | Description |
|---|---|---|
02 | September 2016 | Original Procurement Policy |
0.3 | March 2026 | Procurement Policy – Conflict of Interest |
0.4 | 08 April 2026 | Redesign, content modernization & flowcharts – Conflict of Interest |
Revision Sign-Off
Approving Committee | Name | Signature |
|---|---|---|
Endorsed by — Group Head of Supply Chain | Mohamad Koussa | |
Reviewed by — BIIL CEO | Mr. Ayman Ismail | |
Reviewed by — Group Chief Financial Officer | Mohamad Adnaan Sait | |
Approved by — Group Vice Chairman & Group CEO | Mr. Salah Bukhatir |
Distribution List
# | Departments |
|---|---|
1 | Business Unit Procurement Departments |
2 | Group Supply Chain (GSC) |
3 | Finance, Legal, Compliance, Internal Audit |
4 | Business Unit Management |
1. Purpose
This policy defines how actual, potential and perceived conflicts of interest are identified, declared, managed and monitored in the procurement lifecycle.
2. Scope
Applies to all employees, approvers, evaluators and committee members involved in any procurement decision, supplier selection or contract administration activity.
3. Definition
A conflict of interest arises when personal, financial, family or other external interests of an individual could improperly influence — or appear to influence — the impartial performance of their procurement duties.
4. Categories
Category | Examples |
|---|---|
Financial | Shareholding, directorship, commissions, loans or consultancy fees with a supplier |
Personal / Family | Relative, spouse, close friend employed by or owning a supplier |
Professional | Prior employment with supplier within 2 years, board positions, side-businesses |
Gifts & Hospitality | Receipt of gifts above de minimis threshold (see P-POL-012) |
5. Declaration Requirements
- Annual Conflict of Interest Declaration signed by all procurement staff, approvers and committee members.
- Transaction-level declaration on every Purchase Requisition raised in Oracle.
- Immediate written declaration upon becoming aware of any new conflict.
6. Management Measures
- Declared conflict logged with Compliance.
- Affected individual recused from the transaction.
- Alternate approver/evaluator assigned.
- Decision documented with full audit trail.
7. Monitoring & Audit
Compliance performs quarterly sampling of declarations against Oracle transaction records. Internal Audit tests the process annually.
8. Reference Forms
- Form F-COI-01 — Annual Conflict of Interest Declaration
- Form F-COI-02 — Transactional Conflict of Interest Declaration
9. Definitions & Acronyms
Acronym / Term | Definition |
|---|---|
AED | United Arab Emirates Dirham |
BU | Business Unit |
COI | Conflict of Interest |
DOA | Delegation of Authority |
GSC | Group Supply Chain |