Policy
Digital Advisory Panel: Managing conflicts of interest policy
The policy on managing conflicts of interest for the Gambling Commission's Digital Advisory Panel. The policy aims to maintain public trust and confidence.
Annex A: Rules and handling
Decision makers
A definition of this role would be senior decision makers. Those who make final decisions or decisions where there is a right of appeal. Those who take significant decisions which will bind the Gambling Commission or third parties.
Likely role titles within definition
Likely role titles may include:
- Commissioner
- Chief Executive Officer (CEO)
- member of the Executive team
- independent committee member
- member of the Social Responsibility Funds Group.
Required handling
Can expect the highest level of scrutiny. Declarations of full interests published on the Commission's website for transparency.
Source of rules
For all - HM Treasury Managing Public Money (PDF) (opens in new tab).
Commissioners and independent committee members - Code of Conduct for Commissioners, Cabinet Office Code of Conduct for Board Members of Public Bodies (PDF) (opens in new tab) and terms and conditions of appointment.
For Commission employees - Code of Conduct for Employees and contract of employment.
Advisers
A definition of this role would be providing advice to the Commission on matters of policy or strategy.
Likely role titles within definition
A likely role titles may include be a member of an advisory group.
Required handling
Can expect a high level of scrutiny. Declarations of relevant interests published on the Commission's website for transparency.
Source of rules
For all - Terms and conditions of appointment, Cabinet Office Code of Conduct for Board Members of Public Bodies and terms of reference of each group.
Financial and/or commercial decision makers
A definition of this role would be those who procure goods and services (including evaluation of procurement processes). Those who manage a contract. Those who are budget holders.
Likely role titles within definition
Likely role titles may include:
- Contract manager
- budget holder
- Procurement manager.
Required handling
Relevant interests to be declared annually and when entering procurement process and/or taking on the management of a contract. Internal management.
Source of rules
Source of rules include contract of employment, Code of Conduct for Employees and Managing Public Money.
General
A definition of this role would be all Commission employees and contractors.
Likely role titles within definition
All Commission employees and contractors.
Required handling
Relevant interests (including indirect interests) to be declared as they arise and particularly at beginning of work with the Commission, when moving to a new role within the Commission and during notice period. Internal management.
Source of rules
Contract of employment and Code of Conduct for Employees.
Specific circumstances
A definition of this role would be circumstances where, by virtue of the work being undertaken, there are particular demands that require specific rules in relation to conflicts of interest.
Likely role titles within definition
At present, those working on the 4th National Lottery Licence competition (Commission employees, contractors, Commissioners and advisers). Adjudicators as members of Regulatory Panels.
Required handling
None.
Source of rules
For all - Contract of employment or engagement and Code of Conduct for Employees.
For the fourth National Lottery - 4th National Lottery Licence competition Conflict of Interest (COI) policy.
For adjudicators - Adjudicator Governance Framework.
Previous sectionDAP: Managing conflicts of interest policy - Data protection and confidentiality Next section
DAP: Managing conflicts of interest policy - Annex B: Privacy notice – register of personal interests
Last updated: 14 February 2023
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