Management of Conflict of Interest in the Workplace

The Nolan principles of probity in public life 
Equality Impact Assessment

1. Purpose

To communicate the University’s policy regarding the recruitment, employment and subsequent management and supervision of relatives of current employees who are appointed to a role in the University. This policy also applies to any personal and / or professional relationships that could, or be perceived to impact on the integrity of the working relationships within the University.  

The University welcomes interest in advertised posts from all applicants and each application is treated on its own merit and with careful attention to the principles of equality, fairness and transparency of process. It is hoped that adherence to this policy will minimise the likelihood of any awkwardness, accusations of favouritism or any other difficulties caused by the employment of relatives or close friends either within or across departments.

Where following due process a relative of an existing member of staff and / or a personal or professional contact is appointed to a post at the University they must adhere to the requirements of this policy. 

2. Definitions

For the purposes of this policy, an ‘employee’ is someone who currently has a contract of employment with Aberystwyth University

A ‘relative’ for the purposes of this policy is classified as a close family member, that is spouse or domestic partner, child, step-child, parent, step-parent, grand-parent, grandchild, brother, sister, father-in-law, mother-in-law, brother or sister in law, aunt, uncle, niece, nephew or first cousin.

 A personal or professional  relationship is defined in this policy as a relationship that is more than a passing acquaintance to an individual. A conflict of interest may arise in the workplace when an employee has such competing interests or loyalties that either are, or potentially can be, at odds with each other. A conflict of interest could impact on integrity of the parties and could be contrary to the Nolan principles as outlined in the Financial Regulations.

3. Policy

3.1. Recruitment

The declaration of interest form for shortlisting, before and at interview must be completed in all cases. A record of these declarations will be stored in line with the University’s Data retention policy. Where a declaration of interest could impact on the integrity of the recruitment process, the Chair will liaise with HR with a view to the individual not being involved any further in the Recruitment and Selection process. Where appropriate a replacement will be nominated to continue in the Recruitment and Selection process in their place.

3.2. Line Management

Where the preferred candidate for a post involves either direct or indirect line management by a relative, personal or professional contact the Director of HR or depute must be informed by the Chair of the panel before the offer of employment is made to enable advice to be given about the nature of the offer.   The offer will be subject to the applicant and relative being made aware of their responsibilities under the Nolan principles of probity in public life (detailed below and in the Financial Procedures see section 4.4)

This will be detailed in writing to each party with a request for signature to acknowledge receipt of the document. The Director of the Department and Director of Human Resources will then decide if the line management should be changed.

3.3. During employment.

An employee would not normally be line managed by their relative, personal or professional contact unless this has been agreed by the Director of the Department and Director of HR. Whatever arrangement has been put in place the employee should not be disadvantaged or advantaged in terms of their development opportunities or where any University HR policy is being followed. Where managerial arrangements are already in place which do not comply with this policy, the relevant Director will consult with the Director of HR in order to discuss the situation to clarify if revised arrangements need to be put in place.

It is the responsibility of the employee to raise any potential conflict of interests with their line manager once a situation has been identified that may impact on the integrity of the working relationship.

4. The Nolan principles of probity in public life

Every employee of Aberystwyth University is expected to conduct their working relationships according to the ‘7 Nolan Principles of Public life’ and this is particularly true of those who may be working with relatives or close friends.  The principles are as follows:

  1. Selflessness: Should act solely in terms of the public interest.
  2. Integrity: Must avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work. They should not act or take decisions in order to gain financial or other material benefits for themselves, their family or their friends. They must declare and resolve any interests and relationships.
  3. Objectivity: Must act and take decisions impartially, fairly and on merit, using the best evidence and without discrimination or bias.
  4. Accountability: Be accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.
  5. Openness: Should act and take decision in an open and transparent manner. Information should not be withheld from the public unless there are clear and lawful reasons for so doing.
  6. Honesty: Holders of public office should be truthful.
  7. Leadership: Holders of public office should exhibit these principles in their own behaviour. They should actively promote and robustly support the principles and be willing to challenge poor behaviour wherever it occurs.

5. Equality Impact Assessment

The University is committed to embedding the Equality Scheme into its policies, procedures and practices. This policy has been equality impact assessed in accordance with this scheme.

Policy Review

Human Resources will co-ordinate a review of this policy in order to maintain compliance with legislation and good practice. The review will be undertaken in liaison with the recognised trade unions and any proposed amendments will be submitted to the appropriate relevant committee, University Executive and Council if required.

Version 1.1

Last Reviewed: March 2015

Review Date: March 2020