Employee Handbook
Conflict of Interest Policy
Introduction
Great Places’ activities are financed by both public and private funds. It is therefore important to avoid
perceived or potential conflicts of interest that could arise from improper links between individual members of
staff and suppliers, contractors, professional consultants or other third parties.
We consider that the establishment of relationships between employees and outside bodies, whether
government departments, commerce, industry, or others, is essential to our work. Occasionally however it is
possible that such relationships may give rise to potential conflict of interest.
The following guidelines provide guidance in assessing whether or not proposed activities have potential for
conflict of interest, and outline the procedure for disclosure of any perceived or potential conflict which may
arise.
Key points:
We require you to avoid financial, ethical, legal, or other conflicts of interest. All such actual, perceived or
apparent and potential conflicts must be disclosed.
Guidelines
It is not possible to provide a comprehensive definition of circumstances which necessarily give rise to a conflict
of interest, but the following are examples of situations giving rise to perceived conflict of interest. The list is
not exhaustive, and in any situation where you are uncertain, advice should be sought from Human Resources.

A financial interest held by you (or by your immediate relative/s, partner or household
member/s) in an external enterprise engaged in activities closely related to those of Great
Places. For example, paid consultancies, service on a board of directors or advisory board.

A personal relationship with another Great Places employee or an employee of an external
enterprise engaged in activities closely related to those of Great Places.

A personal involvement in any company or commercial enterprise which is in a contractual
relationship with Great Places or which is in the process of negotiating the terms and
conditions of a contract with us.

Ownership of, or interest in, investment property in regeneration areas where we operate.
You should take care that financial or personal relationships entered into do not disadvantage or unfairly
advantage anyone, for example applicants for jobs or service providers.
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Employee Handbook
Conflict of Interest Policy
Declarations
The existence of such an interest does not necessarily imply conflict, but is likely to give an appearance of
conflict, and should be declared using the Declaration of Interest form which can be obtained from Human
Resources or found on Flo.
A confidential record of all declarations made is maintained centrally by the Chief Executive’s PA. In addition to
declarations made from time to time, all records shall be updated on an annual basis, and you will be required
to provide updated information on request.
Any declaration made will be shared with your manager who will treat these matters in confidence at all times
and will, in consultation with you, find ways in which conflicts of interest might be avoided.
The content of the register will not normally be open to inspection by members of the public or other external
bodies nor by other employees.
In addition to declaring the interest as outlined above:

Should such interests occur, you are expected to inform your manager as soon as any actual,
perceived or potential conflict of interest arises to ensure that it can be minimised.

If the interest involves a relationship between you and another employee, and you are
working in the same department or section or are in a supervisory relationship and the
actual or perceived conflict of interest cannot be resolved by other means, it may be
necessary to explore the possibility of one party being moved to another area of work or
work location.

If you have a close personal or familial relationship with an applicant for employment it will
normally be necessary for you to avoid any involvement in the appointment process or
acting as a referee. Such appointments are subject to Board approval.

External and internal applicants for posts will be asked to declare any close personal or
familial relationships on the application form for the post.
Context
Detail the context for the policy (ie. any strategic aims that the strategy will help to deliver on) and any
legislative or regulatory implications.
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Employee Handbook
Conflict of Interest Policy
Equality Impact Assessment Screening
Question
Could there be any equality issues arising from this policy? (If no,
you do not need to answer the following questions but must
provide justification for why)
Is there any reason that some groups may not receive a fair and
equal service?
Could this issue have a significant impact?
Will the policy impact on a significant proportion of people?
(include justification for why you think it is significant or not)
Is there any reason to believe service user/employee profile is not
consistent with community profile?
Is there any evidence to suggest that any part of the policy,
practice or procedure could discriminate unlawfully, directly or
indirectly, against different groups?
Yes/No (add explanatory notes if
appropriate)
N
N
N
N
N
N
Score:
5-6 = high priority
3-4 = medium priority
1-2 = low priority
0 = no EIA required
Policy Approval Date:
November 2013
Equality Impact Assessment Date:
NA
Safeguarding impact
NA
Policy Review Date:
November 2016
Lead Team:
Human Resources
Level of Authorisation Required:
Directors
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