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DECLARATION OF INTEREST FORM: School Employees

Please read the Declaration of Conflict of Interest guidance and if you have any queries raise these with your line manager in the first instance.

This form must be completed upon appointment and whenever there is a change in your circumstances necessitating amendment to any of the details declared. It must be resubmitted annually, whether or not in the interim there has been a change in your circumstances.

Please state under the appropriate headings any interests that conflict with your work. This is a requirement under your employment contract and any code of conduct applicable in school.

A form must be completed for each post held.

Please print clearly and return the completed form to your manager. You are required to complete part 1 and 2. Once your manager has completed part 3, you will be required to sign off the authorised form at part 4 and return

it to your manager. Please place a cross in none in each declaration if there is no information to report.

PLEASE PRINT CLEARLY

Full Name

Email Address

Post Title

Line Manager

School

PART 1

Other employment

1a . Give details of all other employment or voluntary work (paid and unpaid). Please state:

Job title/position

Name and address of employer (and, if applicable, school)

Details of employment including duties, hours worked per week and times and place of work

You should include any other Doncaster Council positions, any other positions at the same school, any other positions at another school, and any other positions that are not at a school ad not with Doncaster Council.

1b Please provide the total number of hours for all additional employment and voluntary work as an average per week

NONE

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Please give details of:

2. Any other business carried out by you or someone with whom you have a close personal relationship. Please state

company and position. A close personal relation is Someone to whom you are married or with whom you are in a civil partnership or co-habiting or engaged in an intimate relationship. (This

also applies to previous relationships of this nature (e.g. former spouse) as there could be a continuing influence associated with the relationship, or a reasonable perception of a continuing influence, whether to the employee’s advantage or disadvantage);

Immediate family members (e.g. parent, step-parent, son, daughter, step-child, child of a partner, brother, sister, grandparent, grandchild); Extended family members (e.g. uncle, aunt, nephew, niece, cousin, in-laws); Close friends of the employee. This means someone well known to the employee (not merely an acquaintance), who is regarded with liking,

affection or loyalty. The above is not an exhaustive list and employees should use their judgement to determine whether other interests, activities or personal relationships could reasonably be perceived to present a conflict of interest.

NONE

3. Any involvement in companies by you and/or a close relative or close friend. Please state company and position Involvement in companies includes, for example, directorships and company secretary or any other position you or a close relative or close friend have in running the company where that company has, or may have, a relationship with the school or Council.

NONE

4. Your involvement, or the involvement of a close relative or close friend, in contracts or in any business that trades, or may seek to trade, with the school or Council. Please state contract and involvement

The holding of shares or other securities in a company or other body with whom the Council contracts, or is considering contracting, must be declared if the holding exceeds £25,000 or more than 1/100th of the nominal value of the issued share capital, whichever is less. The size and nature of the holding need not be declared, simply the name of the company. This requirement does not extend to banks and building societies.

NONE

5. Any role or Governor/Trusteeship posts you hold in or on behalf of an educational establishment or an academy trust. Please state organisation and position held.

This includes membership of governing bodies, management committees and other school or academy governance structures, and covers all schools maintained by a local authority and any further education establishments, free schools, grant maintained schools, academy trusts and academies.

NONE

6. Any relationship with any employee or Elected Member of Doncaster Council, and any employee or governor in school. Please state their name, your relationship* with them and their position.

*The meaning of ‘close personal relationship’ is outlined at section 2 above. In considering what to declare, you should exercise appropriate

judgement to consider whether a relationship could raise the issue this process seeks to address: a potential conflict of interest. If unsure, you must presume there is indeed a potential conflict and the fact there is a relationship must be declared. As the purpose is to provide transparency to protect you, your school and the local authority from any suggestion of impropriety or potential impropriety, you may wish to declare a relationship as a close friendship if disclosure of its intimacy is not necessary to meet this purpose and would be contrary to the reasonable and legitimate expectations of privacy of either party to the relationship as to the precise nature of the relationship..

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NONE

7. Beneficial interest in land or property. Beneficial interest in land or property excludes your home and only relates to land and property within the Doncaster borough boundary.

NONE

8. Intention to bid for land or property owned by the Council. The intention to bid for the purchase of land or property owned by the Council should be declared as soon as is practicable.

NONE

9. Membership of any secret society Relates to any lodge, chapter, society, trust or regular gathering or meeting which:

is not open to members of the public who are not members;

includes, in the grant of membership, an obligation on the part of the member or requirement to make a commitment (whether by oath or otherwise) of allegiance to the lodge, chapter, society, gathering or meeting;

includes, whether initially or subsequently, a commitment (whether by oath or otherwise) of secrecy about the rules, membership or conduct of the lodge, chapter, society, trust, gathering or meeting.

If it forms part of the activity generally recognised as a religion then this should not be regarded as a secret society. NONE

10. Please give details of any gift or hospitality offered or received in the past year Give details including the name of the individual or organisation that has provided the gift or hospitality, a brief description of what has been provided and an estimated value.

NONE

11. Do you have any supporting documentation to attach Where you have previously discussed with your line manager any conflicts that you have declared above, for example where you have notified your line manager of any additional roles you wish to undertake before commencing other employment, a copy of this information should be attached.

NONE

PART 2

Employee Confirmation It is your responsibility to check that the above information is accurate prior to submitting your form I undertake to notify my school in writing of any changes which may occur within 28 days from the date of the change, by submitting a new declaration to my line manager (or next level of management, as appropriate). I recognise that not doing so may be a disciplinary offence and subject to disciplinary action being taken against me.

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I confirm that I have declared all gifts, hospitality or legacies received in the last 12 months (if this is not the case then these should be declared prior to completion of this registration).

Print Name: Date:

Signed:

Please pass to your manager

PART 3 (to be completed by your manager)

Please carefully consider the content of this declaration and whether there are any non-declared matters you are aware of. If action is required the manager should arrange to meet the employee with regard to the content of the form within 14 calendar days and then complete this section fully recording their decision and signing confirmation. Once complete it should be returned to the employee for sign off. If there is no action required managers should select no conflict and sign to confirm their decision. The form is then returned to the employee for sign off

Date and time of meeting with employee:

Details of discussion (Provide all relevant details of the discussion held).

Decision:

There is no conflict There is a conflict and the employee will be excluded from the activity

There is a conflict, and mitigating actions will be put in place (provide FULL details of actions being put in place)

Manager Confirmation Signature: Date:

This form should now be returned to the employee for sign off

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PART 4 - Employee Sign Off

Notes or comments:

I have read the details on this declaration (and where required, agree adjustments) Employee Confirmation Signature:

Date:

This form should now be returned to your manager and placed on your personal file

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This guidance supplements the terms and conditions of your employment and should be read in conjunction with the employee Code of Conduct and your Statement of Main Terms of Employment.

1 Our Standards

1.1 The Council and your school are committed to ensuring the highest standards of conduct in all they do. These standards are a contractual requirement as outlined in all employees’ Statements of Main Terms of Employment and the Code of Conduct applicable in school. These clearly stipulate the behaviour expected from all employees.

1.2 We know that Conflicts of Interest can occur in the course of employment and it is important that employees know what to do if or when this happens. These requirements apply to everyone who works for the Council and your school, including contractors, consultants, secondees and agency workers.

2 Responsibilities

Employee 2.1 Conflicts of Interest can arise where employees’ integrity or personal judgement can be or

perceived to be compromised. This can have an adverse effect on the Council’s or your school’s reputation.

2.2 You should maintain integrity and professionalism when undertaking your job, acting in the best interest of your school at all times. You must ensure that your private interests, whether of a personal, financial, or political nature, do not impact adversely upon your ability to undertake your official duties responsibly.

2.3 During your employment, you must:- • promote the interests and reputation of your school; • act in good faith towards your school.

2.4 You must not put yourself in a position where your actions could reasonably be perceived to

be open to improper influence. To alleviate this risk you must ensure that you make a declaration at the earliest opportunity once you:

have become aware that a conflict of interest may exist; or

have been offered a gift or hospitality, whether accepted or declined (see points 5.1 to 5.9 below); or

have been offered additional employment (see points 2.5 and 4.7 to 4.10 below); or

have been notified that a client* has left you a legacy in their will (see points 5.10 to 5.13 below); or

have entered into a close personal relationship with a colleague in school or another council employee and consider there might be a potential conflict of interest, or with a governor at your school or a councillor (see appendix 1) ; or

have joined a secret society, professional body or voluntary organisation.

*In the context of employment in a school, ‘client’ means anyone on whose behalf, or on behalf of whose family, friend(s) or any professional or social acquaintance, your work has brought you into contact with.

2.5 You must notify your line manager of any additional employment you wish to undertake and

must obtain the written agreement of your line manager before commencing other employment.

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Line Managers’ Responsibilities 2.6 As soon as a declaration has been made, your line manager must:

ensure that they review all declarations within the timescales and agree any mitigating actions if required;

monitor the frequency of declarations made by employees who have accepted gifts and hospitality;

monitor the frequency of legacy requests and refer all such requests to your head teacher;

determine whether to approve a request for acceptance of alternative employment within 7 calendar days;

maintain confidentiality 3 What Is a Conflict of Interest? 3.1 A Conflict of Interest arises where an employee has a private or personal interest that may or

could be perceived to compromise their ability to do their job. Actual, potential or perceived conflicts of interest can arise across all areas of our work. Conflicts may be of a personal, financial, or political nature.

4 Deciding whether there is a Conflict of Interest 4.1 In deciding whether a Conflict of Interest exists, you and your manager should consider

whether the interest (private or personal) is likely to interfere with your objective judgement when undertaking your duties, or could give rise to a reasonable perception that such is the case.

Personal Interests 4.2 The Council recognises that you may develop relationships and contacts in your personal and

working lives that may influence your objectivity. The majority of these relationships will not give rise to any concern and can be regarded as a private matter.

4.3 However, a Conflict of Interest arises where one party in the relationship can grant the other

an unfair advantage, or disadvantage, or can exert improper influence over a decision relating to the other. This might attract perceptions of bias and unfair treatment where one party:

can make or significantly influence any decisions about the other party in the relationship, such as selection for employment, promotion, pay and grading, performance management, discipline, access to opportunities and resources or the awarding of contracts for goods and services; or

has responsibility for the direct or indirect supervision of the other party. Financial Interests 4.4 A financial Conflict of Interest may arise where it could be perceived that you or someone you

have a personal relationship with have:

the opportunity to gain financially, prevent someone from gaining financially or place that individual at a disadvantage from decisions or actions;

financial interests that may influence your independent judgement and integrity in carrying out your role;

the opportunity to gain from the award of a particular contract for goods or services;

been declared bankrupt and your financial status makes you more vulnerable to situations which could be seen to compromise your official position.

Political Interests 4.5 You may have strongly held political views but under no circumstances must these be reflected

in any decision-making process in your work or alter aspects of your work. You must ensure that you do not allow your personal or political views, or any political actions you engage in or views you express in public, to determine any aspect of your employment or reasonably be

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thought to compromise your impartiality as an employee. (‘Expressing views in public’ includes publishing personal comments on social media.)

4.6 The above examples are not exhaustive since circumstances and relationships vary

considerably. If you are unsure about whether a Conflict of Interest exists you should discuss this further with your line manager and if still in doubt, escalate this via the appropriate management chain.

Other Employment and Interests 4.7 New employees should disclose when appointed any existing jobs or roles which they intend

to continue.

4.8 If as an existing employee, you wish to undertake any other employment, you must notify your line manager. You must obtain the prior written agreement of your line manager before commencing other employment

4.9 If no conflict of interest exists, your manager will need to determine whether the request is acceptable and advise you accordingly. Details should be recorded during the declaration process and retained on your personal file.

4.10 The following would be classified as other employment and interests: • Additional paid employment in school, including casual work; • Additional paid employment in another school, including casual work; • Additional paid employment in the Council, including casual work; • Additional paid employment outside of the Council, including casual work; • Self-employment; • Working with or for, or having an interest in, a business, organisation, council or charity

outside of your school or Doncaster Council; • Volunteering or working, whether in a paid or unpaid capacity, for a business, organisation

or charity; • Substantial shareholding in a company • Membership of a Secret Society

5 Gifts and Hospitality 5.1 It is widely recognised that it is important for school or Council employees to maintain and build

effective networks in order to support the work of the school or the Council. However, contact with organisations outside the school or Council can give rise to offers of gifts and hospitality.

5.2 Whilst accepting gifts and hospitality in certain circumstances may further the school’s or the Council’s interests, this must be balanced with upholding high standards of propriety and guarding against any reasonable suspicion of perceived, or actual, conflicts of interest or an undue obligation being created. All offers of gifts and hospitality which might be perceived to compromise your personal judgement or integrity should be declined.

5.3 If a gift or hospitality (i.e. tickets) that cannot be accepted is sent to you, it should be returned to the sender. If for any reason the sender cannot be identified, you should arrange for it to be officially appropriated to the benefit of the school or to a charity nominated by the school.

Gifts

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5.4 Gifts should not normally be accepted. The only exceptions are those that would normally be considered as low value items that can be used in the workplace such as office stationery, diaries/calendars, chocolates/biscuits etc.

5.5 Gifts which cannot be refused without causing offence, for example, a picture or an award or ornament commemorating an event, can be accepted ‘on behalf of the service’. It should be made clear that it is not being accepted as a personal gift and such gifts must be kept within the service.

Hospitality 5.6 Any hospitality accepted should be in the interests of the school and help further its objectives.

It should not be over-frequent or over-generous. Accepting hospitality from the same organisation could lead to a perception that the work of the school is being influenced by the objectives of a single organisation. Any hospitality you accept should not seem lavish or disproportionate to the nature of the relationship you have with the provider.

Recording gifts and hospitality 5.7 A gift or hospitality with a value under £20 does not need to be recorded separately at the time

of receipt. However, your line manager must determine whether it can be accepted or declined. You are nevertheless required to declare gifts or hospitality under £20 on your annual declaration form.

5.8 A gift or hospitality with a known or estimated value over £20 must (unless it is declined) be declared and recorded when accepted,

5.9 If you have any doubt as to whether or not hospitality or gifts should be accepted, you should seek advice and guidance from your line manager. Even if you decline an offer of a gift or hospitality, you must declare the offer had been made and had been declined.

Legacy Bequests 5.10 Where employees provide services direct to the public, such as caring for older or vulnerable

people, they do so on the basis of entitlement and it is essential that clients* are not put in a position where they feel obliged to offer you a financial reward.

5.11 If you have reason to believe that a client* is intending to leave a legacy of any kind to you or a close relative of yours in their will, you should make it clear to the client*, as tactfully as possible, that you are a public servant and that the services provided are part of your job.

5.12 If you discover that a client* has left you or a close relative of yours a legacy in their will, you must complete the declaration of legacy and seek the approval of your line manager and head teacher before accepting the legacy. Failure to do so will lead to disciplinary action being taken.

5.13 Approval by your head teacher will not preclude disciplinary action being taken against you if, at a future date, it comes to light that undue pressure was put on the client*.

*In the context of employment in a school, ‘client’ means anyone on whose behalf, or on behalf of whose family, friend(s) or any professional or social acquaintance, your work has brought you into contact with.

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6 Why Registering a Declaration is Important

6.1 To maintain public confidence and protect the integrity of the school, the Council and its employees, it is important for you to register a declaration of conflict of interest. This will remove any question of improper conduct and drive transparency within the organisation.

6.2 Further details can be found in codes of conduct that might apply to your employment and the Bribery Act which came into force on 1 July 2011.

7 What does this mean for you?

7.1 If a Conflict of Interest arises or you, or a close relative or close friend, are offered a gift or hospitality (accepted or declined) as a consequence of your employment, you must disclose this to your line manager and complete the appropriate form.

7.2 You are required to complete a declaration of conflict of interest when you commence employment and then any subsequent conflicts of interest as they arise. If your circumstances change, such as a new job, job transfers to a different area/service or your personal situation changes, you must also complete a declaration.

7.3 Even if you have no declarations to make you are still required to complete the form and register a ‘Nil Return’ to confirm you have read and understood these provisions. Under no circumstances should you wait to be prompted to update your declaration. You are responsible for ensuring that your declarations are kept up to date at all times.

8 Failure to Make a Declaration

8.1 If you fail to declare a Conflict of Interest, the offer of a gift or hospitality (accepted or declined), or legacy bequest, appropriate action will be taken in line with the school’s Disciplinary Policy and could result in your dismissal.

8.2 Any criminal offences will also be referred to the relevant authorities.

8.3 If you have any concerns about a conflict of interest relating to another employee this should be raised using the Whistleblowing Policy.

9 Dealing with Conflicts of Interest

9.1 Your line manager must review your declaration within 7 calendar days and where necessary, implement any mitigating actions. Your line manager should meet with you to discuss the matter in more detail including any mitigating action to be taken. They must subsequently document this within 14 calendar days.

9.2 Through discussion with your line manager you may agree:

a) that there is no Conflict of Interest;

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b) to continue with the activity but implement actions to mitigate any risk. (This could include closer monitoring, revisions to plans, exclusions from decision-making activities and disclosure of all relevant information to others involved in the process);

c) to be excluded from the activity.

9.3 If you cannot agree with your line manager what action should be taken, or you disagree with a decision taken under this process, you may escalate this via the school’s grievance procedure.

10 Data Protection

10.1 The General Data Protection Regulations 2018 requires anyone who handles personal information to comply with a number of important principles. It also gives individuals rights over their personal information. All declarations will be handled in accordance with the processing of personal information principles.

Appendix 1 - Definitions

Close Personal Relationship:

Someone to whom you are married or with whom you are in a civil partnership or cohabiting or engaged in an intimate relationship. (This also applies to previous relationships of this nature (e.g. former spouse) as there could be a continuing influence associated with the relationship, or a reasonable perception of a continuing influence, whether to the employee’s advantage or disadvantage.);

Immediate family members of the employee (e.g. parent, step-parent, son, daughter, step-child, child of a partner, brother, sister, grandparent, grandchild);

Extended family members of the employee (e.g. uncle, aunt, nephew, niece, cousin, in-laws);

Close friends of the employee. This means someone well known to the employee (not merely an acquaintance), who is regarded with liking, affection or loyalty.

The above is not an exhaustive list and employees should use their judgment to determine whether other interests, activities or personal relationships could reasonably be perceived to present a conflict of interest. In considering what to declare about a relationship, you should exercise appropriate judgement to consider whether a relationship could raise the issue this process seeks to address: a potential conflict of interest. If unsure, you must presume there is indeed a potential conflict and the fact there is a relationship must therefore be declared. As the process is intended to provide transparency to protect you, your school and the local authority from any suggestion of impropriety or potential impropriety, you may wish to declare a relationship as a ‘close friendship’ if disclosure of its intimacy is not necessary to meet this purpose and would be contrary to the reasonable and legitimate expectations of privacy of either party to the relationship as to the precise nature of the relationship.

Close Relative

Spouse or civil partner

Children and step-children, parents and step-parents, brothers and sisters and step-brothers and step-sisters; or

The spouse or civil partner of any person within the above

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Membership of a Secret Society: The Local Government Management Board defines secret societies and this is what employees should use to decide if they are required to make a declaration. It states that it relates to any lodge, chapter, society trust or regular gathering or meeting which:

is not open to members of the public who are not members;

includes in the grant of membership an obligation on the part of the member or requirement to make a commitment (whether by oath or otherwise) of allegiance to the lodge, chapter, society, gathering or meeting; and

includes, whether initially or subsequently, and whether by oath or otherwise, a commitment of secrecy about the rules, membership or conduct of the lodge, chapter, society, trust, gathering or meeting.

A lodge, chapter, society trust gathering or meeting as defined above, should not be regarded as a

secret society if it forms part of the activity of generally recognised religion.