1. Purpose
This policy sets out Murzo Group’s framework for identifying, disclosing, managing, and resolving conflicts of interest in order to protect the integrity, independence, and lawful operation of the business.
The objectives of this policy are to prevent personal, financial, or external interests from improperly influencing decisions, protect Murzo Group from legal, ethical, and reputational risk, promote transparency and accountability in decision-making, and provide a clear and defensible process for managing conflicts.
This policy forms part of Murzo Group’s wider governance, compliance, and risk-management framework.
2. Scope
This policy applies to directors and senior management, employees and officers, contractors, consultants, and temporary workers, advisors and representatives acting on Murzo Group’s behalf, and any individual involved in decision-making, procurement, research, design, or partnership activity.
It applies globally and irrespective of jurisdiction.
3. Definition of a Conflict of Interest
A conflict of interest arises where an individual’s personal, financial, professional, or external interests could reasonably be perceived to interfere with their ability to act in Murzo Group’s best interests.
Conflicts may be actual (a conflict currently exists), potential (a conflict may arise in the future), or perceived (a reasonable third party could believe a conflict exists).
Perception alone may be sufficient to require disclosure and management.
4. Types of Conflicts
Conflicts of interest may include, but are not limited to:
4.1 Financial Interests
- Ownership, investment, or financial interest in a supplier, client, competitor, or partner
- Personal financial benefit arising from Murzo Group decisions
- Undisclosed commissions, fees, or incentives
4.2 Personal Relationships
- Family, romantic, or close personal relationships with suppliers, clients, competitors, or colleagues
- Supervisory or decision-making authority involving related individuals
4.3 External Employment or Activities
- Secondary employment or consultancy
- Advisory or board roles in external organisations
- Research, teaching, or speaking engagements related to Murzo Group’s activities
4.4 Intellectual Property & Research Conflicts
- Competing claims to IP ownership
- Parallel research or development activities
- Use of Murzo Group knowledge or resources for external benefit
4.5 Procurement & Supplier Relationships
- Influence over supplier selection where a personal interest exists
- Acceptance of gifts, hospitality, or benefits beyond reasonable business practice
4.6 Political, Academic, or Institutional Affiliations
- Affiliations that may influence neutrality, independence, or objectivity
- Activities that could be perceived as endorsement or alignment
5. Duty to Disclose
All individuals covered by this policy have a continuing duty to disclose actual, potential, or perceived conflicts promptly, update disclosures if circumstances change, and cooperate with any review or mitigation measures.
Failure to disclose a conflict may itself constitute a breach of this policy.
6. Disclosure Process
Conflicts should be disclosed as soon as reasonably practicable, in writing where possible, and through appropriate internal channels.
Murzo Group may request additional information to assess the nature and risk of a disclosed conflict.
7. Assessment & Management of Conflicts
Upon disclosure, Murzo Group may assess the materiality and risk of the conflict, determine appropriate mitigation measures, require recusal from specific decisions or activities, reassign responsibilities or impose conditions, and restrict access to information or projects.
Murzo Group retains discretion in determining how conflicts are managed.
8. Gifts, Hospitality & Benefits
Individuals must not offer or accept gifts, hospitality, or benefits that could influence decision-making or accept benefits that exceed reasonable and proportionate business practice.
Murzo Group may require disclosure or refusal of gifts or hospitality at its discretion.
9. Confidentiality & Use of Information
Individuals must not use Murzo Group confidential information for personal gain, disclose information to benefit external interests, or exploit Murzo Group resources, data, or IP outside authorised use.
These obligations apply during and after engagement with Murzo Group.
10. International & Cross-Border Context
In international operations or collaborations, conflicts may arise due to differing legal, cultural, or institutional norms. Murzo Group’s internal standards continue to apply regardless of location.
Murzo Group reserves the right to restrict or terminate engagements where conflicts cannot be adequately managed.
11. Failure to Comply
Failure to comply with this policy may result in removal from decision-making roles, suspension or termination of engagement, contractual remedies, and legal action where appropriate.
Murzo Group may act even where no actual harm has occurred.
12. No Waiver
Failure by Murzo Group to identify or act on a conflict does not constitute acceptance or waiver of rights.
13. Legal Position & Limitations
This policy does not create contractual or fiduciary obligations beyond applicable law, does not replace statutory duties, and does not limit Murzo Group’s right to act in its own interests.
Nothing in this policy excludes liability that cannot be lawfully excluded.
14. Review & Updates
This policy is reviewed periodically and may be updated to reflect legal or regulatory developments, changes in business operations, and emerging conflict-of-interest risks.
Commitment Statement
Murzo Group is committed to conducting its activities with integrity, independence, and transparency. By identifying and managing conflicts of interest responsibly, we seek to protect trust, objectivity, and long-term business integrity.
