Overview
This policy is part of Our Code, which we are all required to attest to annually.
Why do we need this policy?
Certain roles have formal duties, such as charity trustee or school governor. For the most part such activities are uncontentious, though they may occasionally be controversial – as public cases have shown.
We must consider, mitigate, or resolve any actual or perceived conflicts of interest or reputational concerns arising from such roles before they are taken on.
Who does this policy apply to?
This policy applies to all of us working at the Bank. This includes consultants, contractors, and agency staff.
What you must know or do?
If you wish to take on a community or charity role with legal duties or formal responsibilities, we will need to consider any real or perceived conflicts of interest or reputational concerns. If these exist, we will discuss with you how they may be handled. In rare circumstances you may be asked to stand down from the role. Some charities take the form of companies, in which case the approval process in the Directorships policy applies.
You should alert the Press Office and your management in advance of any possibility of press comment or political contention arising from community activities, as your association with the Bank may lead to heightened interest and a possible impact on the Bank’s own reputation, even though your involvement is in a purely personal capacity.
1: Membership of a charity’s investment committee
1.1. Membership of a charity’s investment committee, where you might be involved in making or advising on financial transactions or investment decisions, falls under the Personal financial transactions policy, and its pre-approval rules apply.
1.2. You do not need to disclose other forms of community and charity volunteering, such as coaching a football team, being a guide leader, leading a Bank club or society, helping with a charity event or working in a charity shop, but you will need to discuss this with your line management if it could have an impact on your work at the Bank, eg due to time commitments.
2: Protecting your information
2.1. The application of this policy will be in accordance with the relevant data protection legislation. For information on how the Bank processes your data, please see our staff data privacy notice.
Key policy requirements
For all colleagues
1. You must disclose via the Our Code Compliance system before taking on a community or charity role with legal duties or formal responsibilities such as a charity trustee, member of a charity’s investment committee, or a school governor.
2. If you make or advise on financial decisions as part of that role, then the ‘personal financial transactions’ policy pre-approval requirements will apply as though the transactions were your own.
3. Any compensation you receive for community or charity roles, or volunteering (other than expenses) must be refused or donated to charity rather than being retained, unless the role has been approved as ‘other employment’.
4. If your role changes, you must promptly update your declarations in the Our Code Compliance system and/or submit a new declaration as required.
5. If the nature of the charity/organisation and its activities changes, you must notify the Secretary/Conflicts team and your line manager.
For all managers
6. You must ensure that you and members of your team understand the requirements of this policy.
7. You must promptly review any community or charity role disclosures via the Our Code Compliance system. Contact the Secretary or the Conflicts team if you have any questions about a community or charity role disclosure you have received.
What support is available to help you comply with this policy?
The following documents will aid your understanding of, and compliance with, this policy:
- Our Code.
- Staff Handbook (see Section C2).
- Personal financial transactions policy.
What is the impact of non-compliance?
If you realise you have breached – or suspect that you might have breached – a requirement in this policy please tell AskCompliance as quickly as possible, so that the issue can be reported and redressed under the Bank’s Breach management policy. The Bank gives credit for you taking prompt responsibility for your mistakes. You should be aware that failing to discharge your responsibilities could lead to disciplinary or other action.
January 2024