This morning brought what in my opinion is a long overdue Charity Commission statutory inquiry into the Professional Football Association's charitable arm.

This is a charity which in it's 2018 accounts declares in note 8 staff costs of raising Donations and Legacies £1.1m, in Note 10 support staff costs of £4.05m and in note 15 "The charity does not have any employees and therefore no salaries or wages have been paid during the year"!!

Leaving that anomaly aside, in note 23 it states that "some of the Trustees are also senior offices or members of the PFA General Fund and the PFA Accident Fund" and that "some of the Trustees are also directors of PFA Enterprises Limited" Finally it states "one of the Trustees is also a director of ProSport Wealth Management which acts as investment broker to the Charity" The charity has funds of £21.6m under management. These Trustees are not named.

This is in the context that the PFA is the player's Trade Union and it's CEO is also the CEO of the Charity and a Trustee. It is not my job to preempt the findings of the Charity Commission but from the outside looking in I see potential conflicts of interest everywhere and find it difficult to differentiate between the Union and the Charity.

Now just taking the CEO of the charity also being a trustee. In certain circumstances individual charity's constitutions do allow this to happen but it is very much discouraged by the Charity Commission. Likewise, it is permissable to make payments to an individual trustee or a corporate entity that the trustee is involved in, PROVIDED that it is in a professional capacity AND that the trustees have either gone out to tender or have had robust discussion excluding the trustee involved and are convinced that this is the BEST solution for the charity and not just the cheapest. Many charities have seperate trading subsidiaries and more and more those subsidiaries have Board members who are NOT involved with the charity and can provide some independent thought that puts the subsidiary's needs first before that of the charity to enable it to have a profitable future for the benefit of the charity. In addition, we've all seen it particularly in smaller charities. A trustee has "a mate that can do that and he/she will give us mates rates". "It's only £1,000 so do we really need to go out to tender?"

The point is that Conflict of Interest can crop up anywhere. Whether it's employing one of the trustee's children for a holiday job to the CEO of a charity having potentially undue influence over the Board of Trustees. At the very least every charity should have an Annual Declaration of Interests and there should be an Agenda Item at the beginning of each meeting to ensure that any potential conflicts disqualify that trustee or employee from that agenda item. A golden rule of thumb is that if one trustee has a niggle about a potential conflict then the person with the conflict should not participate in the discussion and if you are still uncertain, THINK AGAIN and take advice!