HSE University Anti-Corruption Portal
The UK Releases Recommendations on Conflict-of-Interest Management

The document is targeted at ministerial departments, their executive agencies and other authorities in developing internal policies on conflict-of-interest management and applies to civil servants at all grades, both those with permanent and fixed term arrangements.

The Guidance stresses that the declaration of outside interests and open discussion of the management of such interests by employees and their superiors constitute an inherent element of effective detection and subsequent management of conflicts of interest.

All in all, the decision which interests are to be declared is taken by employees autonomously. To this end, they should assess the extent to which a certain interest is relevant to or overlaps with their roles/duties. However, the Guidance provides for a minimum list of interests that must be declared. It includes:

  • Personal interests, where the job holder has relevant family or personal relationships which could influence their objectivity;
  • Financial interests, where the job holder stands to gain financially from the work they are undertaking or they can use their status to deliberately prevent someone else from gaining financially;
  • Private shareholdings where an individual holds shares in a business that their team, directorate, or, if appropriate, department has an interest in;
  • Outside occupations meaning any other paid work and activities which are not remunerated directly but can benefit financially third parties;
  • Voluntary roles;
  • Previous employment, appointment or other outside roles including elected positions;
  • Business interests - where an individual holds an interest in any organisation (including directorships) which they could use their official position to further;
  • Insider dealing;
  • Direct or indirect financial or other personal interest which might be perceived to compromise relevant staff members’ impartiality and independence in the procurement process;
  • Any other relevant interests.

Under the Guidance, the job holders must disclose their outside interests:

  • On commencing employment (including a secondment in);
  • Moving between roles (including a secondment out);
  • On an ongoing basis, in particular, the job holders of the Senior Civil Service (SCS) need to confirm on an annual basis that their declarations of interest are up to date;
  • When recruiting – it is good practice to declare interests at interview to make clear that interests will be compatible with the candidate’s duties.

Furthermore, outside interests of family members and close friends of employees should be declared to the extent to which they can reasonably be expected to know of such interests. The list of family members is not exhaustive and can include, in particular, spouse, children, parents, and siblings; however, in each case the list of these persons is defined separately taking account of such factors as frequency of their contacts and closeness of family relations. For instance, the lack of personal contacts with siblings will probably mean that there is no need to declare interests, whereas the interests of in-laws with whom the employee maintains regular contacts can deserve attention from the point of view of potential conflicts of interest (for example, if the employee’s position allows him/her to conclude contracts with the organisation where these relatives are employed).   

After the interests declaration is filed, the decision maker assesses the data submitted from the point of view of indicators of a conflict of interest. As a rule, these functions are entrusted to the line manager of the employee, however in certain cases another person, such as the direct supervisor, can be engaged. Moreover, provision should also be made in internal policies for advice about the declaration of sensitive matters to be sought directly from the HR Director or Permanent Secretary’s office.

Analysis of the declaration by the competent officer can conclude with the detection of the indicators of:

  • Actual conflicts - where there is a risk that an official’s ability to apply judgement is or could be impaired or influenced by an extant secondary interest.
  • Potential conflicts - where an official’s ability to apply judgement or act in their role could be impaired or influenced by a secondary interest in the future.
  • Perceived conflicts - where an official’s ability to act in one role could reasonably be perceived as impaired or influenced by a secondary interest (i.e it could cause a reasonable person to think there was a conflict of interest).

If there are indicators of a conflict of interest, the decision-maker should determine and document the necessary corrective action (upon agreement with the employee, where possible). These measures can include, in particular:

  • Conclusion of an agreement that there is no conflict of interest, including perceived conflict of interest, - it may be that the decision maker and individual decide that there is in fact no conflict of interest to be found;
  • Exclusion from the activity which creates the conflict-of-interest situation, in particular, by changing responsibilities, recusal from decision making etc.;
  • Closer monitoring of the activities of the employee who is in a conflict-of-interest situation, revisions to existing work plans, or the additional disclosure of all relevant information to others involved in the decision making process etc.

Under the Guidance, it is a must to take measures to manage actual conflicts of interest, whereas potential or perceived conflicts of interest can remain unregulated provided that effective measures are taken to mitigate their impact.

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