duties to their beneficiaries. This prevents directors improperly making profit from their office. Shareholder approval needed for financial benefit If directors are to escape liability. Section 191 says they have a duty to notify other directors of material personal interest. However, (s. 208) If a director of a public company derives a financial benefit, shareholder approval is required for benefit to 'related party'. ('financial benefit' defined in s. 229, related party defined in s. 228 and the procedure set out in s. 217-227. Approval is not required for matters set out in s. 210-6 e.g. 'terms that would be reasonable in the circumstances if the public company were dealing at arm's length'). More importantly with issue at hand he must not personal profits arising from acting as a director. He has a duty not to make undisclosed personal profits while acting in the position. See Regal (Hastings) Ltd v Gulliver [1942] 1 All ER 378