1.Purpose

The purpose of this Policy is to ensure that decisions made by the Slade Green and Crayford Marshes Neighbourhood Board ("the Board") are taken fairly, transparently and in the best interests of the local community.

The Policy establishes arrangements for identifying, declaring, recording and managing conflicts of interest and supports the Board's commitment to integrity, accountability, openness and transparency.

Board Members are expected to act in accordance with the Nolan Principles of Public Life:

  • Selflessness
  • Integrity
  • Objectivity
  • Accountability
  • Openness
  • Honesty
  • Leadership

The Board will adopt the principle:

If in doubt, declare.

Where a Board Member is uncertain whether an interest should be declared, they should err on the side of transparency and make a declaration.

This Policy forms part of the wider governance framework for the Neighbourhood Board and should be read alongside the governance documents listed below.

2. Scope

This Policy applies to:

  • The Independent Chair;
  • All Neighbourhood Board Members;

Any Deputy Chair appointed by the Board;

  • Substitute representatives attending Board meetings;
  • Members of any sub-groups, task and finish groups or working groups established by the Board; and
  • Any individual regularly attending Board meetings in an advisory or decision-making capacity.

3. Related Governance Documents 

Core Governance Documents

This Policy should be read in conjunction with:

  • Terms of Reference;
  • Code of Conduct; and
  • Declaration of Interests Form.

4. What is a Conflict of Interest?

A conflict of interest arises where a Board Member's personal, professional, political, financial or organisational interests could influence, or could reasonably be perceived to influence, their ability to act impartially as a member of the Board.

Conflicts may be:

Actual Conflict

A direct conflict exists between a Board Member's interests and a matter under consideration by the Board.

Potential Conflict

A situation where a conflict may arise in the future.

Perceived Conflict

A situation where a reasonable person could conclude that a conflict exists, even where no actual conflict is present.
Board Members should seek to avoid situations that may create actual, potential or perceived conflicts of interest wherever reasonably possible.

5. Interests Which Should Be Declared

The following are examples of interests that should be declared:

  • Employment, self-employment or consultancy arrangements;
  • Directorships;
  • Trusteeships;
  • Ownership of businesses or commercial interests;
  • Shareholdings;
  • Membership of charities, voluntary organisations, community groups, faith groups or social enterprises;
  • Membership of governing bodies, housing associations, resident groups, community associations, business forums and other organisations relevant to the Board's work;
  • Positions held within organisations that may seek Pride in Place Fund support, funding or other benefits through the Pride in Place Programme;
  • Existing or proposed contracts with the London Borough of Bexley or the Board;
  • Financial interests that may be affected by Board decisions;
  • Interests held by spouses, partners, close family members, household members or close associates; and
  • Gifts and hospitality connected with Board business.

This list is not exhaustive.

Where there is uncertainty as to whether an interest should be declared, Board Members should declare the interest.

6. Examples of Interests Requiring Declaration

The following examples are intended as a guide and are not exhaustive. 

A Board Member should declare an interest where:

  • They are employed by an organisation seeking Pride in Place Fund support;
  • They are a trustee, director, committee member, volunteer or advisor to an organisation seeking support;
  • A close family member, household member or close associate works for or is connected with an organisation under consideration;
  • They own property, land or assets that may be affected by a proposed project;
  • They may receive a direct or indirect financial benefit from a Board decision;
  • They have helped prepare an application, business case or proposal being considered by the Board;
  • They have a close personal or professional relationship with an applicant organisation;
  • They have publicly campaigned for or against a proposal being considered by the Board; or
  • They have received gifts, hospitality or other benefits from an organisation connected with a proposal.

Where uncertainty exists, the interest should be declared and advice sought from the Chair or Secretariat.

7. Declaration of Interests

All Board Members must:

  • Complete a Declaration of Interests Form upon appointment to the Board;
  • Update their declaration whenever relevant circumstances change;
  • Review their declaration annually;
  • Declare any relevant interest before discussion of a relevant agenda item.

Declarations of Interest shall be a standing item on every Board agenda.

Board Members are responsible for ensuring that their declarations are complete, accurate and up to date.

Completion of a Declaration of Interests Form and inclusion within the Register of Interests forms part of the appointment process for all Board Members and the Independent Chair. Completed forms shall be submitted to the Secretariat and reviewed for inclusion within the Register of Interests.

8. Register of Interests

Governor Services of the London Borough of Bexley, acting as Secretariat to the Board, shall maintain a Register of Interests.

The Register will:

  • Record interests declared by Board Members;
  • Record changes notified during the year;
  • Support transparency and accountability; and
  • Be reviewed periodically to ensure information remains current.

The Secretariat may identify interests requiring monitoring and draw relevant declarations to the attention of the Chair where appropriate.

Board Members remain responsible for ensuring their declarations are accurate and up to date.

9. Managing Conflicts of Interest

Board Members are encouraged to indicate to the Secretariat prior to a Board meeting whether they intend to declare an interest in an item on the agenda and if necessary seek advice in relation to withdrawing from the meeting in relation to that item.

Each Board meeting and any sub-group meetings will have a standing item relating to conflicts of interest. Where a conflict of interest is declared in relation to an item, the Board member will indicate whether he/she intends to withdraw from the meeting whilst that item is being discussed. If the Board member considers that the nature of the interest does not require the Board member to withdraw from the meeting, the Chair shall determine the most appropriate course of action, taking account of the nature and significance of the interest and after seeking any advice as necessary.

Possible actions include:

  • Recording the declaration and permitting participation;
  • Recording the declaration and permitting participation in discussion but not decision-making;
  • Requiring withdrawal from discussion of a specific item;
  • Requiring withdrawal from the meeting for the duration of a specific item.

The action taken should be proportionate to the nature of the conflict and the need to maintain confidence in the Board's decision-making.

10. Chair's Decision-Making Framework

In determining how a declared interest should be managed, the Chair shall consider:

  • The nature of the interest;
  • Whether the interest is financial or non-financial;
  • The extent to which the interest may benefit the individual or a connected person;
  • Whether the conflict is actual, potential or perceived;
  • The importance of maintaining public confidence in the Board's decision-making; and
  • Any advice received from the Secretariat or the Accountable Body.

Following consideration of the above factors, the Chair may determine that:

  • The declaration is recorded and no further action is required;
  • The member may take part in discussion but not vote;
  • The member may provide factual information but must withdraw prior to discussion or decision-making; or
  • The member must withdraw from the meeting for the duration of the item.

As a minimum, a Board Member with an actual conflict of interest shall not participate in any decision or vote relating to the matter in question.

The Chair's decision and the reasons for that decision shall be recorded in the minutes.

11. Funding and Project Decisions

Particular care must be taken where the Board is considering projects, grants, contracts, commissions, investments or any other proposals involving Pride in Place Programme funding or resources.

Board Members must declare an interest where they:

  • Work for an organisation seeking support;
  • Are a trustee, director, committee member or office holder of an organisation seeking support;
  • Have participated in the development of a proposal under consideration;
  • May receive a direct or indirect benefit from a project; or
  • Have any connection that could reasonably be perceived as compromising their impartiality.

Where such an interest exists, the member will normally be excluded from both discussion and decision-making relating to that matter.

12. Elected Members

Councillors serving on the Board remain subject to:

  • The London Borough of Bexley Members' Code of Conduct;
  • Relevant legislation relating to the declaration of interests; and
  • Requirements contained within the Council's Constitution.

Where a councillor has a Disclosable Pecuniary Interest or other registrable interest, they must act in accordance with the relevant legal and constitutional requirements.

13. Role of the Secretariat

Governor Services, acting as Secretariat to the Board, shall:

  • Maintain the Register of Interests;
  • Receive and retain completed Declaration of Interests Forms;
  • Ensure declarations of interest are included as a standing agenda item;
  • Record declarations and actions in meeting minutes;
  • Monitor declared interests where appropriate;
  • Draw relevant declarations to the attention of the Chair;
  • Identify where further advice may be required;
  • Support the Chair in administering this Policy; and
  • Retain records of declarations and related decisions.

The Secretariat provides administrative support but does not determine whether a conflict exists. Responsibility for determining how conflicts are managed rests with the Chair.

14. Role of the Chair

The Independent Chair is responsible for:

  • Promoting openness, transparency and accountability;
  • Ensuring conflicts are declared and managed appropriately;
  • Determining the action to be taken where a conflict arises;
  • Ensuring decisions relating to conflicts are recorded; and
  • Ensuring all members are treated consistently and fairly when considering conflicts of interest.

Where the Chair has a conflict of interest, responsibility shall pass to the Deputy Chair or another member nominated by the Board for that particular item.

15. Recording Conflicts

The minutes of Board meetings shall record:

  • The name of the individual declaring an interest;
  • The nature of the interest;
  • The action taken; and
  • Whether the individual remained for discussion and/or decision-making.

The Register of Interests and meeting records shall be maintained by Governor Services in accordance with the Board's governance arrangements.

16. Breaches of this Policy

Failure to comply with this Policy may undermine confidence in the integrity of the Board and its decision-making.

Examples of breaches include:

  • Failing to declare a relevant interest;
  • Providing inaccurate or incomplete information on a Declaration of Interests Form;
  • Participating in a discussion or decision where a conflict exists;
  • Failing to update declarations when circumstances change; or
  • Deliberately withholding information relevant to a conflict.

Failure to comply with this Policy, the Declaration of Interests Form, the Code of Conduct or any direction issued by the Chair regarding the management of conflicts of interest may constitute a breach of the Board's governance arrangements.

Where a breach is identified, the Chair may:

  • Require a declaration to be made retrospectively;
  • Require the Register of Interests to be updated;
  • Exclude the member from participation in a particular matter;
  • Refer the matter to the Board for consideration;
  • Seek advice from the London Borough of Bexley as Accountable Body; or
  • Recommend suspension or removal from Board membership where the breach is serious or repeated.

The Board may review or revisit decisions where a material conflict of interest is identified after a decision has been made.

17. Review of the Policy

This Policy shall be reviewed:

  • Annually;
  • Following any significant amendment to Pride in Place Programme guidance;
  • Following any significant governance issue identified by the Board; or
  • At the request of the London Borough of Bexley as Accountable Body.

Policy Owner: Governor Services, London Borough of Bexley

Approved By: Slade Green and Crayford Marshes Neighbourhood Board

Effective Date: 09/09/2026 

Review Date: N/A - Initial Version

Next Review Due: 09/09/2027