Declaration
Annually and on any material change
Trust Centre
Conflicts of Interest
Upstream BPO staff declare potential conflicts of interest annually and on any material change. HR and the employee's direct line manager review each declaration, and the resolution is documented.
Key information
At-a-glance governance context
These points summarise the public scope of this page and the main contact or review context around it.
Review
HR and the employee's direct line manager
Outside employment
Concurrent employment with competitors is prohibited
External enquiries
dpo@upstreambpo.com
Section 1
Declaration
Upstream BPO staff declare potential conflicts of interest annually. Staff also declare on any material change, without waiting for the annual cycle.
- A change in personal circumstances that creates a conflict.
- Taking on a new external role.
- A family member joining a customer, vendor or competitor.
- Acquiring a financial interest in a customer, vendor or competitor.
Section 2
Review
HR and the employee's direct line manager review each declaration. Two reviewers are involved so that a declaration is assessed both against employment policy and against the specific work the employee performs.
Section 3
Resolution
Every reviewed declaration ends in a documented resolution. The resolution records what was decided and why, so that the position is auditable later rather than resting on an undocumented conversation.
- Recusal from specific matters where the conflict is limited in scope.
- Reassignment away from conflicted work where recusal is insufficient.
- Divestment where a financial interest creates an ongoing conflict.
Section 4
Gifts and hospitality
Upstream BPO maintains a gifts and hospitality register internally. Thresholds for acceptance and declaration are published internally to staff.
We keep the threshold figures internal. Publishing them externally tells a third party exactly what sits below a declaration line, which works against the control.
Section 5
Outside engagements
Employees are prohibited from concurrent employment with competitors during their employment with Upstream BPO. The prohibition applies for the duration of employment.
Section 6
Records and customer audit
Conflict of interest records are available to customer auditors under NDA, in line with the audit rights set out in the executed Data Processing Agreement.
External enquiries about the conflicts of interest process route to dpo@upstreambpo.com. Staff declarations use the internal HR channel rather than this address.
Reviewer questions
Questions we are asked in security review
Answers are stated in full here so they are quotable directly into a security questionnaire.
How often do staff declare conflicts?
Annually, and additionally on any material change. Material changes include a change in personal circumstances, a new external role, a family member joining a customer, vendor or competitor, or acquiring a financial interest in one.
Who reviews a declaration?
HR and the employee's direct line manager review each declaration together.
What resolutions are available?
Recusal from specific matters, reassignment away from conflicted work, or divestment where a financial interest creates an ongoing conflict. Every resolution is documented.
Can employees work for a competitor at the same time?
No. Concurrent employment with competitors is prohibited for the duration of employment with Upstream BPO.
Can our auditors review conflict of interest records?
Yes. Conflict of interest records are available to customer auditors under NDA, in line with the audit rights in the executed Data Processing Agreement.
Related resources
Related governance and service pages
Use the connected pages below for deeper privacy, governance, service or contact context.
Contact & Escalation
External enquiries about the conflicts of interest process route to dpo@upstreambpo.com. Staff declarations use the internal HR channel.
Next Step
Need a deeper governance review?
Send certificate requests, subprocessor list requests, incident reports and vulnerability disclosures to dpo@upstreambpo.com. We acknowledge security and trust enquiries within 3 business days.