Overview
This policy is part of Our Code, which we are all required to attest to annually.
Why do we need this policy?
The Bank needs to be sure that any other employment:
- does not adversely impact an individual’s wellbeing and the requirements of their Bank role; and
- does not give rise to a conflict of interest, perception of undue advantage, reputational risk, or other detriment to the Bank.
This aim of this policy is to ensure that we can consider, mitigate, or resolve any risks to an individual and to the Bank before any other employment is 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
You must have appropriate authorisation to undertake any other employment while you are working at the Bank. Such authorisation will normally be given so long as it is not, in the Bank’s opinion, incompatible with the full and proper performance of your Bank duties and does not give rise to a conflict of interest, a perception of advantage, or a risk to the Bank.
For the purposes of this policy, ‘any other employment’ covers any paid or unpaid work undertaken for another employer under contractual obligation (other than where you are volunteering for a charity or community role), for example, working as a professor or lecturer in academia, or as an adviser to research groups (where unrelated to your Bank role). It also covers self-employment as a sole trader, within a partnership or via a limited company in which you are a shareholder.
Certain employment will not be permitted as there is an inherent conflict of interest or perception of advantage. These are:
- employment with a Bank-regulated firm;
- acting as a dealer in gold or foreign exchange, whether as a principal or intermediary;
- acting either directly or indirectly as a broker or dealer or other intermediary in buying, selling, or exchanging any securities on commission; and
- receiving any commission or gratuity from such a broker or dealer for recommending business to them.
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. Before taking on any other employment you must:
1.1. discuss it with your line manager, particularly if it will impact on your ability to deliver your work at the Bank to the necessary standard;
1.2. seek pre-approval from your HoD (or above if it’s a HoD requesting) via the Our Code Compliance system;
1.3. seek separate pre-approval via the Our Code Compliance system if the other employment also requires you to take up a directorship; and
1.4. complete any action required of you by the HoD (or above if it’s a HoD requesting) reviewing your request (including, for example, refusing the role or stepping down from it, reducing the proposed time commitment etc).
2. While you hold any other employment you must continue to comply with the following if applicable:
2.1. if you make or advise on financial decisions as part of your other employment the Personal Financial Transactions policy pre-approval requirements apply as though the transactions were your own;
2.2. the Bank’s External Communications and Engagement policy; and
2.3. the Directorship policy if your other employment is likely to require you to take on a directorship.
3. You must ensure that your approved other employment is not undertaken in Bank time, when you are expected to be working, or using Bank resources (including your Bank email address).
4. If you are employed as a Bank expert (eg IMF Missions), where you are paid directly and you continue to also be paid by the Bank you must surrender any monies received from your other employment to the Bank.
5. You must create a new request for approval in the Our Code Compliance system if the nature of your other paid employment changes and must receive approval before commencing the changed employment.
For all Head of Departments (HoDs) (and above)
6. You must ensure that you and those working in your Division understand the requirements of this policy.
7. You must promptly review any other employment requests made via the Our Code Compliance system.
This means:
7.1. using the guidance to assess the request;
7.2. approving or rejecting the request in the Our Code Compliance system; and
7.3. ensuring you receive confirmation that an individual promptly completes any actions required (eg not accepting the proposed role or stepping down from it, reducing the proposed time commitment etc).
What support is available to help you comply with this policy?
The following documents will aid your understanding of, and compliance with, this policy:
- Guidance to HoDs (and above) on assessing other paid employment requests.
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 2025