The Declaration of Interests purpose is to prevent any conflict of interest that may arise for individuals between their role as members of, or contributors to the work of, committees or staff of the Welsh Liberal Democrats and their private or family interests or their association with other voluntary or community organisations, public authorities, commercial organisations or other bodies.
Similarly, the policy seeks to avoid any conflicts of interest that may arise for staff employed by the Welsh Party of the Liberal Democrats, if staff are or have been associated in a personal capacity with specific voluntary or community organisations, public authorities, commercial organisations or other bodies.
Such conflicts can:
- Inhibit free discussion;
- Result in decisions or actions that are not in the interests of the Welsh party; and
- Risk the perception that the Board and/or the Welsh Liberal Democrat Party has acted improperly.
Conflicts of interest could include, but are not limited to:
- unfair access to information, influence, services or resources;
- being a party to or interested in both sides of a contract or other agreement; or
- financial benefit arising from being a party to or interested in both sides of a grant or donation.
- Members of the Committee/Board are elected, co-opted or appointed to the Committee to direct, coordinate and oversee the implementation of the strategy and the work of the Welsh Party.
- Members of the Committee/Board should whenever contributing to the work of the Committee/Board act in the interests of the Welsh Party only and without regard to their own private interests and should not derive any personal benefit or gain from their membership of the Committee/Board.
- Organisations or bodies with which members of the Committee/Board are associated should not benefit from their membership of the Committee/Board, other than the benefits that all, or significant groups of voluntary and community organisations can receive from the Welsh Liberal Democrats and its work.
- Staff are employed to serve the interests of the membership of the Welsh Liberal Democrats.
- Organisations and bodies with which staff members are associated in a personal capacity should not benefit from this employment, other than the benefits that all, or significant groups of, voluntary and community organisations can receive from the Party and its work.
C. Register of Interests
- All members of a Committee/Board on election, co-option or appointment will be required to complete a Declaration of Interests in the prescribed form here to this policy listing all relevant interests which might affect their work for the Committee/Board generally whether singularly or on an ongoing basis, or which could be seen (by a reasonable member of the public) to do so. This includes any gifts or hospitality received in connection with their role in the Committee/Board of a value greater than £100.
- A register of such Declarations of Interest (the “Register of Interests”) shall be kept by the CEO. The CEO will ask all members of Committee/Board and staff to update their entry in the Register of Interests annually, but it is the responsibility of all members of the Committee/Board and staff to notify the CEO of all updates as and when they arise. The Register of Interests shall be open to reasonable public inspection on application to the CEO.
D. Declarations of interest at Committee meetings or at sub-committee or working group meetings
- All members of the Committee/Board and any other person attending a meeting (or sub-committee or working group), including any member of staff of the Welsh Liberal Democrat Party, shall declare any interest which might affect or be seen to affect their contribution to the work of that body taking place in that meeting or any part of that meeting, and in particular to declare any actual or potential conflict of interest or loyalty. Oral declarations shall be recorded in the minutes of the meeting.
- If any member of the Committee/Board or other person attending a meeting (or sub-committee or working group), including any member of staff of the Federal Party, fails to declare an interest that is known to, the Chair of a meeting of the Committee will declare that interest.
If the outcome of any discussion or decision taken at a Committee/Board meeting (or sub-committee or working group) could have a direct financial effect on:
- a member of the Committee (or sub-committee or working group) or
- a member of staff of the Party or
- on a member of the family (defined as the spouse, civil partner, parent, grandparent, child, grandchild, sibling or the spouse or civil partner of any of the aforementioned) of a person falling within (D.3.1) or (D.3.2) or
- on a voluntary or community organisation or other body in which a person falling within (D.3.1) or (D.3.2) has a relevant interest (other than an interest which relates to all, or a significant group of, voluntary and community organisations),
- the person falling within (D.3.1) or (D.3.2) may participate in the discussion of matters but may not participate in the determination of matters and should withdraw from the meeting at the point at which a vote is called. They may not be included in determining whether the meeting is quorate for the purposes of any such vote. Withdrawals shall be recorded in the minutes of the meeting.
- Subject to paragraph E.1, if a member of the Committee/Board has any other interest which does not fall within paragraph D.3, but which might reasonably cause others to think it could influence their decision, they should declare the nature of the interest, but may remain in the room, participate in the discussion, and vote if they wish. This paragraph does not apply to disciplinary, grievance or similar procedures.
- In addition, members of the Committee/Board shall declare an interest and withdraw from the meeting for the discussion of the timetable, rules or other arrangements for any internal Party elections in which they are, or intend to be a candidate, agent or other campaign team member except in the case of such discussions related to the general rules for the conduct of Board/committee elections.
- No Members of the Committee/Board (or sub-committee or working group) or other person attending meetings of the Committee on behalf of other party bodies shall be mandated. If such a person intends to represent the views or best interests of a particular party body in discussions or decisions take by the Committee (or sub-committee or working group) they shall declare this intention at the commencement of the discussion or their contributions to it.
- Members of the Committee/Board and staff attending meetings and conferences in a personal capacity may at times be able to usefully support the best interests of a party body which does not have an official representative at that Committee meeting. In such circumstances, they may represent that party body but they should make it clear in which capacity they are acting or speaking.
- Members of the Committee/Board and staff or other persons who may be placed in any conflict of interest while attending meetings should discuss their concerns at the earliest possible opportunity with the Chair or the CEO or, if the Chair and CEO are not present, the acting Chair of that particular meeting of the Committee.
F. Managing contracts
- Any member of the Committee or other person attending a Committee/Board meeting (or sub-committee or working group), including any member of staff of the Party who has a conflict of interest must not be involved in managing or monitoring a contract made by or on behalf of the Committee/Board (or sub-committee or working group) or in the use or application of a donation or a grant or other sums from the Board’s funds affected by the conflict of interest. Monitoring arrangements for such contracts, donations, grants or other sums will include provisions for an independent challenge of bills and invoices, and termination of the contract or repayment in whole or in part of the grant if the interests of the Party are adversely affected by the conflict of interest.
- A de minimis exemption applies to contracts, donations, grants or other sums less than £500 in value. Random checks against the Register of Interests will be made on the award of contracts, donations, grants or other sums below this value. If the cumulative value of a series of small contracts, donations, grants or other sums exceeds £5,000 over the course of one term of the Committee/Board, the Committee Member will treat such contracts as being subject to the restriction used for individual contracts, donations, grants or other sums over that value.
- The de minimis exemption does not apply (i) to contracts of employment with the Party or any other body of the Liberal Democrats, including any Parliamentary party, State parties or local parties or (ii) to any contract, donation or grant which has to be recorded or reported under electoral law, including PPERA.
Any exceptions, or potential exceptions, to this policy must be discussed at an appropriate meeting of the Committee/Board and with due regard to the Board and CEO.