Our commitment

A conflict of interest is not automatically wrong. Hiding one is. We ask everyone to declare interests early so they can be managed openly.

Examples to declare

• Outside employment, consultancy or directorships
• Investments in a supplier, partner, competitor or portfolio company
• Close personal or family relationships with a supplier, candidate or colleague you influence
• Involvement in a decision that could benefit you or someone close to you

How declarations are handled

Declarations go to the CEO and are recorded in the interests register. Management usually means stepping out of a decision, reassigning ownership, or adding a second approver. Directors additionally comply with their duties under the Companies Act 2006.

Governance and review

This policy is owned by the Chief Executive Officer and approved by the board. It is reviewed at least annually, and sooner if the law, our operations or our risk profile changes.