What is the duty of a director of a company to be held accountable for their own profits?

Counsel for the defendants also relied upon the judgment of Lord Blanesburgh in Bell v. Lever Bros. Ltd., [1932] A.C. 161 at 193-95, [1931] All E.R. Rep. 1. There His Lordship drew a distinction between the duty owed by a director in respect of contracts with the company when the director has a personal interest in the contract, and that owed in respect of a director’s own contracts in which the company has no financial interest at all. In the latter case, Lord Blanesburgh says [p. 194]: “… the company has no concern in his profit and cannot make him accountable for it unless it appears — this is the essential qualification — that in earning that profit he has made use either of the property of the company or of some confidential information which has come to him as a director of the company.”