Further to Minute 24 of the meeting of the Audit and Governance Committee on 21 January 2025, this report updates Committee on steps taken to introduce centralised and regularly updated registers of Officer Declarations of Interest and Gifts and Hospitality.

Further to Minute 24 (2) of the meeting held on 21 January 2025, the Committee considered a report giving an update on steps taken to introduce centralised and regularly updated registers of Officer Declarations of Interest and Gifts and Hospitality.

The report explained that, at a meeting of the Audit and Governance Committee on 21 January 2025, the Committee had considered a report by the Council’s External Auditor and had resolved that officers be asked to consider applying a more rigorous approach to registering declarations of interest and gifts and hospitality, and whether the process should include monitoring by the Audit and Governance Committee to ensure records were complete.

The report gave details of the following relevant Codes and Policies, which were appended to the report:

• Appendix 1 - The Officers’ Code of Conduct, which dealt with employee conflicts of interest and gifts and hospitality, requiring employees to declare to their manager any outside interests they had, financial or otherwise, if and when an outside interest could conflict with the Council’s interests or policy, or with their duties and responsibilities as an employee.

• Appendix 2 - The Council’s Employee Gifts and Hospitality Policy, which required employees to seek approval from their line manager before accepting any offer of hospitality or a gift of more than nominal value. This had to be declared by completing the appropriate form, which was filed on the Council’s systems by the Human Resources team.

• Appendix 3 - A standalone Employee Conflict of Interest Policy, which had recently been developed building on the provisions of the existing Code of Conduct, and had been approved by Personnel Committee on 12 March 2026.

• Appendix 4 - Anti-Fraud, Bribery and Corruption Policy.

• Appendix 5 - Whistleblowing Policy.

The report explained that the Employee Conflict of Interest Policy had been developed in response to the new Failure to Prevent Fraud offence, which had been created by section 199 of the Economic Crime and Corporate Transparency Act 2023 and had come into force on 1 September 2025. Under the new offence, the Council might be held criminally liable if it failed to prevent fraud committed by employees or associated persons, unless it could demonstrate that reasonable and proportionate fraud prevention procedures were in place. This included having clear governance frameworks, effective monitoring, and documented controls, to mitigate the risk of prosecution and reputational damage.

Previously, staff Declarations of Interest had been required upon first employment and subsequently where there had been a change of circumstances, but they had not been renewed annually. The new Employee Conflict of Interest Policy strengthened governance arrangements by introducing mandatory annual Declarations of Interest for all staff, including the submission of a nil return where no interests existed, together with a renewed requirement for staff to update their declaration immediately if circumstances changed. These measures sought to ensure that the Council could demonstrate proactive compliance with the new legislation, strengthen transparency, and reduce the Council’s exposure to fraud, corruption, and procurement risks. They would also create a clear audit trail, evidencing that the Council had taken reasonable steps to prevent conflicts, thereby protecting both staff and the organisation.

A communications campaign was currently under way to raise staff awareness of the new policy and ensure its implementation.  The report invited the Committee to receive a monitoring report to its next meeting giving an update on compliance with the new policy requirements.

Resolved:    

(1)          That the Council’s arrangements for dealing with Employee Conflicts of Interest and the registration of Gifts and Hospitality be noted;

(2)          That a report be received at the next meeting monitoring compliance with the Council’s new Employee Conflict of Interest Policy.