BLOG: The Ethics & Integrity Commission, One Year On
As the EIC approaches its first anniversary, our Chief Executive, Stu Sterling, reflects on a busy year.
It has been a privilege to oversee a productive inaugural year for the EIC as its first CEO. In 1995 as the chair of EIC’s predecessor, the Committee on Standards in Public Life, Lord Nolan set out in his first report some general recommendations applying across the entire public service. These restated the general principles of conduct underpinning public life in the UK; asked public bodies to draw up codes of conduct; recommended independent scrutiny for standards; and argued for the promotion of standards of good conduct through education. These recommendations are as relevant today as they were then, and they formed the basis for our new structure when establishing the EIC. In the course of the year, additional commission members have been appointed and new officials recruited to fulfil the wider commitments set out in our terms of reference from the Prime Minister. We have also been active in launching two reviews and delivering our, unplanned for, first published report into Lobbying, Business Appointment Rules and Disclosure.
The EIC is the custodian of the seven Principles of Public Life: selflessness, integrity, objectivity, accountability, openness, honesty and leadership, which are widely known as the Nolan Principles. In essence the seven principles set out the public’s expectations for the legitimate use of entrusted power in public life. They apply to everyone who holds public office: elected officials and those appointed to work in the Civil Service, local government, probation services, those in non-departmental public bodies and in health, education and in social care services. But, as Robert Barrington sets out in his recent book, Corrupted Kingdom, ‘they are not regulated and there are no formal sanctions for breaching them’.
Codes of Ethical Conduct
This is why Codes of Ethical Conduct play such a vital role. As the Public Office (Accountability) Bill (the Hillsborough law) moves closer to achieving Royal Assent, public bodies will be turning to the EIC for guidance on embedding a code of ethical conduct. This will be a new duty for public authorities. The initial guidance that the EIC issues, which will coincide with Royal Assent, will signify the first step in its journey to becoming a centre of excellence on ethical codes of conduct. This was a role entrusted to the EIC by the Government when it was established a year ago.
This work is all about protecting the public. Organisations that embed high ethical standards into all aspects of how they operate are more likely to identify the early warning signs of things starting to go wrong. This helps in avoiding and mitigating the sort of institutional failings that have had such a devastating impact on so many, such as Post Office Horizon, Infected Blood, Windrush and the tragedy that acted as the catalyst for the current Bill, Hillsborough.
As we have collected evidence it has become clear that ‘how’ an organisation develops and promotes its code is just as important as the code itself. Employees must be brought into the process, and the code should be brought to life with examples from that organisation’s area of business. Not every code will be the same. For example, a code of ethical conduct that works in local government will be different from that adopted by a police force. In addition to our guidance, we will be working with umbrella organisations to examine how they can support the organisations under their remit to develop and promote the importance of embedding a code to shape culture.
The guidance will support public authorities, whether a local council, police service or NHS trust, to establish organisational cultures that build trust within the organisation so that employees are listened to when something doesn’t feel right, and can be confident that action will be taken. Where employees feel they will be supported when they tell the truth, no matter how unpalatable that might be to the reputation of the organisation, they will have more confidence in speaking up. We hope that the Hillsborough Law, which will also establish a legal duty of candour, will in time help to increase public trust. But this will only occur if public authorities and the individuals within them live that code – it is not enough to have a policy that once written goes no further than being pinned to a notice board.
Independent Scrutiny
Our first planned review was launched in March and was also focused on protecting the public. It is looking at whether public ombudsman services can identify systemic failings at an early stage, before they escalate, by playing a greater role in linking and proactively investigating complaints that suggest a wider issue. We will publish this review early next year. I mention our first ‘planned’ review because also in March, we were asked by the Prime Minister to examine the systems for regulating lobbying, financial interests and post government employment. We were keen to do this as lobbying was an area that our predecessor had previously examined and about which it had made a number of recommendations, many of which remain unacted upon.
The report dealt primarily with lobbying, where the majority of the recommendations emerged and where evidence pointed to urgent action being needed. Lobbying sits at the heart of building and sustaining public trust and confidence in our system of government. The recommendations offer the Government the opportunity to improve how it demonstrates openness about external influence over its policy and commercial decisions. Evidence shows that action is needed now to improve government owned transparency data and to start the work of legislating to increase the number of lobbying meetings recorded by the Registrar of Consultant Lobbyists. At present the Register does not meet the Nolan test for openness, and only records the activity of consultant lobbyists which account for an estimated 4% of all lobbying carried out in the UK.
Education
The Nolan Principles lie at the heart of standards in public life, but to be the beating heart they need to be brought to life through promotion, guidance, training and debate. The EIC is working on a number of exciting engagement projects for 2027 to do this. These will include a standards week, where each day a different Nolan principle will be focused upon, and a dedicated leadership in standards conference. This will bring together those across the standards landscape to present, share, debate and discuss current standards issues at a leadership level. There is also work afoot to partner with schools and the education sector in readiness for the Government’s legislative changes to the voting age, so that our young people are aware of the principles and can learn and discuss what they mean to and for them.
As the EIC sends its first annual letter to the Prime Minister on the health of standards in public life in the coming week, it is encouraging that our public life is more transparent than it was. But there is no room for any complacency. Whilst sunlight may be the ‘best disinfectant’ we know that transparency alone does not translate into greater public trust. There are areas that can and must be improved. The Government must move faster on local government standards reform, an area that will both make a difference to councillors and officers and contribute to public confidence. The recommendations in our report on lobbying are urgently needed and if adopted will increase openness in an area lacking this currently. These will also help pave the way for better and more inclusive policy making in government and therefore provide a genuine benefit to the public. We look forward to the Government’s swift response to our report and its recommendations and in working with the Prime Minister and his team on these important areas.
Cultures of trust are fragile. They are easily broken, but are mended only with difficulty and over time. The EIC is committed to ensuring that the public services of the country are worthy of the public’s trust. It is that challenge that the EIC has embraced and it will be at the centre of its activities over the coming years.
Stu Sterling will be joining a panel at UCL on 15 October 2026: Policy & practice seminar: Regulating lobbying in the UK. Use this link for further details and to book your place.