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Corporate Governance Framework

Our corporate governance framework sets out the necessary responsibilities and procedures that guarantee we operate properly.

  1. Contents
  2. Code of conduct for employees
  3. Confidentiality and conflicts of interest

Confidentiality and conflicts of interest


21. It is the nature of the Commission’s work that you are likely to have access to sensitive information. This may cover, for example, sensitive commercial, political or personal information. You must not (except in the proper course of your duties) either during your employment with the Commission or at any time after its termination (howsoever occurring), divulge sensitive information to any person; or otherwise make use of any confidential information relating to the business, policies, operations, affairs, interests or financial position of the Commission or any person, firm or body with whom the Commission has or has had any dealings. (In addition, you should use your best endeavours to prevent the unauthorised publication or disclosure of any such sensitive information).

22. Failure to adhere to this policy will be regarded as a serious matter and may amount to gross misconduct.

Conflicts of interest

23. We recognise that you may legitimately have interests outside the Commission. However, you should be aware that the conduct of private business might give rise to actual or perceived conflicts of interest between your private position and that of the Commission. You should ensure that any possible conflicts of interest are identified at an early stage and that appropriate action is taken to resolve them (for example, informing your manager, seeking your manager’s advice).

Private interests and possible conflict with public duty

24. As a public servant you have a particular duty to ensure that you do not abuse, or raise any reasonable suspicion that you have abused, your public position in your own personal interest. In particular, you must not:

  • use information gained in your work to advance your private financial or other interests, or the financial or other interests of other persons. There are circumstances in which this would be insider dealing, which is a criminal offence (see Annex B)
  • participate in the taking of any decision which could affect the value of your private financial or other interests, or the financial or other interests of those to whom you give investment advice. Such a conflict of interest could, in certain circumstances, result in legal action against the Commission and against you.

25. Further guidance is in Annex B and the Employee Handbook.


26. If you are in a position to influence the outcome of regulatory decisions (see paragraphs 10 and 13), or you appear to be in such a position, you are not permitted to hold shares directly in companies operating in the gambling industry which are, or which may be, licensed by the Commission. You should instruct anybody carrying out investments on your behalf of this constraint. This restriction extends to your close family. Other employees may fall into this category and, if so, you will be informed of this by your manager. If you are unclear as to your status, you should seek guidance from your manager in the first instance or, failing this, the Head of Human Resources.

27. If you are not in a position to influence regulatory decisions, you may invest in shareholdings and other securities connected to the gambling industry, unless the nature of your work is such as to require constraints on this, in which case you will be informed. You must not be involved in taking any decision which could affect the value of your private investments, or the value of those on which you give advice to others. In addition, you must not use information acquired in the course of your work to advance your private financial interests or those of others. You should be aware of the strict controls which apply to insider dealing, which is a criminal offence. Further details are in Annex B and the Employee Handbook.

28. You must declare to the Head of Finance any business interests (including directorships) or holdings of shares or other securities that you or members of your close family hold, to the extent which you are aware of them, which you may be able to further as a result of your official position. Such interests are primarily likely to be interests and direct investments in the leisure sector. You must comply with any subsequent instructions from the Commission regarding the retention, disposal or management of such interests.

Business interests and outside occupations

29. You may only have limited external business interests and occupations, provided that these do not interfere with your work or in any other way compromise the Commission’s position. The starting point is that your principal paid occupation is with the Commission and nothing you do in addition to this should compromise your ability to fulfil your obligations to the Commission. The following general principles must be observed in respect of business interests and outside occupations:

  • you must not engage in private activities which would require your attendance during office hours or impair your usefulness to the Commission by, for example, leaving you with insufficient time for rest and relaxation (for which you receive paid leave)
  • you must not be involved in occupations or other activities, which might conflict with the interests of the Commission or be inconsistent with your position as a Commission employee
  • you may only do things externally which depend upon your official experience if you first obtain the consent of a Director
  • generally you may only hold directorships in, or undertake work in or for, public or private companies, firms or other organisations - including in a consultancy or advisory role, with the consent of the Chief Executive. A single directorship may be allowed where individuals have the express permission of a Director. (The holding of a non-executive directorship of a small private ‘family-type’ company may also be permitted, if no conflict of interest is caused)
  • unremunerated directorships of charitable companies or similar organisations are permitted, provided there is no potential conflict of interest.

30. If, as a part of your work, you come into contact with matters concerning a business organisation in which you have an interest, then you must declare that interest to the Head of Finance.

31. You should not handle any official business where, because of private interests, your actions could be open to misunderstanding.

32. You should not carry out any private business transaction with an outside organisation with which you have had official dealings on behalf of the Commission unless, exceptionally, specific written approval is first obtained from a Director or Programme Director.

33. Directors, Programme Directors and Senior Managers will be asked to make a formal declaration of interests to the Head of Finance at least annually. This will include nil returns. The Commission will publish such declarations in accordance with its publication scheme.

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