Digital Advisory Panel: Managing conflicts of interest policy
What is a conflict of interest
6. The Gambling Commission has adopted the National Audit Office’s definition of a conflict of interest:
'A conflict of interest is a set of circumstances that creates a risk that an individual’s ability to apply judgement or act in one role is, or could be, impaired or influenced by a secondary interest. The perception of competing interests, impaired judgement or undue influence can also be a conflict of interest'2.
7. Conflicts of interest can create problems for the organisation and individuals. They can:
- diminish public confidence in the Commission as a regulator and public body
- result in decisions or actions that are not in the best interests of the Commission
- undermine a decision or position taken by the Commission
- give rise to the perception that the Commission has acted improperly
- compromise the Commission’s ability to regulate effectively
- undermine the Commission’s position as a statutory adviser to government and source of official statistics
- invalidate decisions and/or risk legal challenge to decisions taken by the Commission
- lead to criminal prosecution or disciplinary action against individuals.
8. Professional experience and connections can bring benefits to the work of the Commission, and often form part of the reason why an individual has been appointed to a particular role. However, they can give rise to conflicts of interest, which must be managed effectively.
9. Not every interest will result in a conflict. Conflicts of interest can change over time – meaning that an interest that did not initially represent a conflict may become one. If you are unsure whether an issue represents an issue please seek advice from the Governance team.
Acting as a trustee of a housing association is unlikely to present a conflict with Commission business, however, if that housing association were to submit a proposal to the Commission seeking regulatory settlement funds a conflict may well arise.
DAP: Managing conflicts of interest policy - Introduction Next section
DAP: Managing conflicts of interest policy - Types of interest
Last updated: 21 April 2023
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