POL-02 · v1.0 DRAFT — for director review, not in force

Impartiality and conflict of interest

Separate-company relationship, assessor independence and management of conflicts.

Legal ownership and relationship

CPD Global is operated by MARTIN WOLF LTD (14466857). CPD College is operated by a separate limited company under different ownership, belonging to a business partner. The two businesses maintain a commercial relationship. Based on the owner’s confirmation there are no cross-shareholdings, ownership interests or reciprocal control rights; the CPD College company details must be verified before contracting.

A formal legal separation does not establish the absence of personal, commercial, referral, financial or reputational influence. We therefore do not use blanket statements such as “fully independent”.

Commitments

No course is approved because of ownership, friendship, commercial value, customer status or payment. Course authors, salespeople and commission recipients must not control an outcome. Every assessor and approver signs a course-specific conflict declaration; anyone with a disqualifying conflict recuses and a competent replacement is assigned.

Conflict categories

Commercial, authorship, personal, management and business-partner relationships are each recorded with a required mitigation. The CPD College relationship is kept in a relationship register, with external competence and an independent approver as needed.

Authorisation

A final decision requires a named authorised approver who is not the course author and has no unmitigated material conflict. If impartial approval cannot be evidenced, the decision is deferred.

Review

Conflicts are reviewed at application, reviewer appointment, decision, renewal and appeal. This policy is reviewed at least annually or on a change of relationship. No assessor or approver has been appointed by the creation of this document.

CPD Global is operated by MARTIN WOLF LTD (company no. 14466857), registered in England and Wales. It is a private course-quality assessment service and does not claim official government recognition or third-party accreditation. Certification is not currently operational.

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