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Guidance and Protocols

Guidance and Protocols

Contents

Introduction

  1. The Ethics and Integrity Commission is an independent advisory, non-departmental public body that reports to the Prime Minister. It is sponsored by the Propriety and Constitution Group in the Cabinet Office, which also provides the Commission’s budget.
  2. This note sets out guidance and protocols for Ethics and Integrity Commission members. Members are expected to ensure that they are familiar with the purpose and functions of the Commission and understand their duties and responsibilities as set out in this document.
  3. The Ethics and Integrity Commission’s code of conduct sets out the values and standards of behaviour expected of members of the Commission.

Roles and responsibilities

Role of Commission members

  1. Members of the Commission have collective responsibility for its operation. They must:
    1. engage fully in collective consideration of the issues, reading meeting papers and taking account of the full range of relevant factors;
    2. take collective responsibility for the operation and decisions of the Commission, reaching consensus decisions where possible. Should it not be possible for members to reach a consensus on a particular issue, members may record a dissenting view;
    3. ensure that information about the Commission’s activities is placed in the public domain, including through the publication of an annual report;
    4. uphold the letter and spirit of the Ethics and Integrity Commission’s code of conduct; and
    5. ensure that the Commission does not exceed its powers or functions.
  2. Communications between the Commission and the Prime Minister will generally be through the Chair. Nevertheless, any Commission member has the right to approach the Prime Minister on any matter which he or she believes raises important issues relating to his or her duties as a Commission member. In such cases the agreement of the rest of the Commission should normally be sought.

Role of the Chair

  1. The Chair has particular responsibility for providing effective leadership on the matters set out above. In addition, the Chair is responsible for:
    1. ensuring that the Commission meets at appropriate intervals, and that the minutes of meetings accurately reflect the decisions taken and, where appropriate, the views of individual Commission members;
    2. representing the views of the Commission to stakeholders and the general public;
    3. ensuring that new Commission members are briefed on appointment; 
    4. ensuring that the provisions of the Freedom of Information Act 2000 (including prompt responses to public requests for information) are adhered to; and
    5. providing an assessment of the performance of Commission members to the Prime Minister, on request, when members are considered for appointment to the board of another public body.

Role of Commission Staff

  1. In order to undertake its work the Commission is supported by a team of civil servants employed by the Cabinet Office. The size of the team is determined by the budget available to the Commission.
  2. Commission Staff support the Commission in the exercise of its functions by:
    1. providing policy advice and draft documents for consideration;
    2. managing the Commission’s work programme, ensuring that decisions are taken at the appropriate time and that they are carried through;
    3. respond appropriately and in a timely manner to all correspondence, including requests for information under the Freedom of Information Act, and complaints;
    4. ensure value for money in deploying the Commission’s budget; and
    5. support the Commission in maintaining an authoritative reputation at home and abroad.

Monthly Commission meetings

  1. The aim of the monthly meetings is to direct the work of the Commission and to consider issues on which the Commission may wish to take a view. From time to time an external speaker is invited to attend the Commission ahead of formal business in order to inform the Commission on standards issues (sometimes but not always in connection with a current report) or to reinforce institutional relationships.
  2. The meeting minutes are published on the Commission’s website. 

Scheduling of Commission meetings

  1. The Commission meets monthly (except in August), usually on the third Thursday of the month. Meetings begin at 14:00 and normally last around 2 hours.  When the Commission is involved in an inquiry and discussing draft reports, meetings can be longer. On occasion, additional meetings will be scheduled to meet tight publication deadlines or to respond to an emerging issue.
  2. Meetings take place in person in London, but can be hybrid to enable remote attendance when necessary.

Meeting attendance

  1. Members are expected to attend each Commission meeting wherever possible. When attendance is not possible, apologies and reasons should be given.

Quorum

  1. The Commission has a quorum of three which should comprise two independent members and one political member.  Should a quorum not be possible, the Chair may decide to postpone a meeting or, if urgent business requires it, consider and take decisions by e-mail or telephone.

Meeting agenda

  1. The standing agenda for monthly Commission meetings is as follows:
    1. Apologies for absence
    2. Register of interests
    3. Agreement to minutes of previous meeting
    4. Core business for the meeting
    5. Current standards issues
    6. Any other business

Consensus agreement

  1. The Commission aims for consensus decision-making.  It is not usually necessary to put matters to a vote.  Should it not be possible for members of the Commission to reach a consensus, members may record a dissenting view.

External Meetings 

  1. Members are expected to attend external meetings as part of the Commission’s work programme. Where they have agreed to be a lead member on a particular report or work area, they are expected to attend all relevant meetings, as required.

Academic support

  1. The Commission is supported by a senior academic adviser, Professor Mark Philp, who has a standing invitation to attend meetings of the Commission. From time to time the Commission may request specific pieces of academic work to support particular inquiries, including opinion polling.

Handling media relations

  1. The Commission is supported by a part-time contracted press officer whose role is to provide appropriate visibility of the Commission’s work (for instance via the Commission’s website and social media accounts), to issue press releases and to manage relations with the press and media more generally. This role is filled by Maggie O’Boyle (D F Press Ltd).
  2. The Chair is the main spokesperson on Commission policy, including on potential future reviews, but other Commission members leading on a project may act as the spokesperson as agreed with the Chair.  Commission members may sometimes be asked to undertake media interviews or make comments on behalf of the Commission. 
  3. Members should always liaise with the Press Officer or Head of Commission Staff before speaking or being interviewed on standards issues even if those issues are not directly related to the Commission’s work. Members should be aware of the Commission’s position on an issue before speaking publicly or being interviewed. The Press Officer or Commission staff will, when appropriate, provide briefing and ‘lines to take’.
  4. Likewise, members should consult the Press Officer or Head of Commission Staff before commenting on Commission matters using social media. 
  5. The Commission’s authority is enhanced by members being consistent with the Commission’s position when speaking in public about the Commission work; any disagreements are best discussed in Commission meetings.
  6. The Commission does not comment on individual cases, in keeping with its terms of reference.

Guidance on completing the Register of Members’ interests

The purpose of the Register

  1. All Commission members – the Chair, independent and political members – should register in the Commission’s Register of Interests any private interest which might influence their judgement or which could reasonably be thought by others to do so.
  2. There are nine categories of registrable interests which are described below. In addition to these specific rules, a more general obligation lies with members to bear in mind the overall purpose of the Register when declaring their interests.
  3. Members should seek advice from the Head of Commission Staff if at all unsure about whether to declare an interest.

Duties of members in respect of registration

  1. Commission members should register:
    1. relevant personal direct and indirect pecuniary interests;
    2. relevant direct and indirect pecuniary interests of close family members of which Commission members could reasonably be expected to be aware; and
    3. relevant personal non-pecuniary interests, including those which arise from membership of clubs and other organisations.
  2. In this paragraph “relevant” interest, whether pecuniary or non-pecuniary and whether direct or indirect, means any such interest which might influence the judgement of a Commission member or which could reasonably be thought by others to influence his or her judgement in the exercise of his or her public duties; “indirect pecuniary interest” means an interest which arises from connection with bodies which have a direct pecuniary interest or from being a business partner of, or employed by, a person with such an interest.

Publication and public inspection

  1. The Code of Conduct states that “The Register of Interests should be kept up to date and published on the Commission’s website within one month of any updates”. The Register is informed by a standing agenda item at the monthly Commission meetings.

The Categories of Registrable Interest

Applicable timeframe

  1. New members are required to register all their current financial interests and any registrable benefits received in the twelve months before their appointment. Members are advised to register interests and benefits received earlier than this if they consider that these continue to be relevant.
  2. Interests remain in the Register for twelve months after they have expired, or longer if the member deems the interest to continue to be relevant.

Remunerated employment, office, profession, occasional work

  1. This is the category for registering any employment, office, trade, profession or vocation which is remunerated or in which the member has any pecuniary interest. Fees received as a member of the Commission are excluded.

Remunerated directorships

  1. In this section, members are required to register any remunerated directorships in public and private companies including directorships which are individually unremunerated, but where remuneration is paid through another company in the same group.
  2. In this category, and in others, “remuneration” includes not only salaries and fees, but also the receipt of any taxable expenses, allowances, or benefits, such as the provision of a company car.

Land and property

  1. The requirement in this section is to register any land or property owned or held by the member, either personally, or with or on behalf of the member’s spouse or partner or dependent children:
    1. has a value of more than £100,000; or forms part of a total property portfolio[2] whose value exceeds £100,000; and/or
    2. alone or together with other properties owned by the member, provides rental income of more than £10,000 in a calendar year.
  2. The nature of the property should be indicated.[3]

Registrable shareholdings

  1. In this section, members are required to register interests in shareholdings held by the member, either personally, or with or on behalf of the member’s spouse or partner or dependent children, in any public or private company or other body which are:
    1. greater than 15 percent of the issued share capital of the company or body; or
    2. 15 percent or less of the issued share capital, but greater in value than £70k.[4]
  2. The nature of the company’s business in each case should be registered.  If a member has a holding in a company which is below the due value, but which might be directly or indirectly involved in a matter under scrutiny by the Commission then such a holding should be declared at that time.
  3. Holdings in blind trusts are exempt from registration.

Clients for whom services are provided relevant to the Commission’s interests

  1. In this section Members are required to disclose the names of clients, other than companies or organisations already identified elsewhere, but including clients of those companies or organisations for whom they provide services.
  2. Where a Member feels unable to register a client due to a duty of confidentiality, then the Member should not participate in any Commission proceedings where there may be a real or perceived conflict of interest.

Miscellaneous financial interests

  1. This is a discretionary section for use by members wishing to register remunerated interests that do not clearly fall within any of the specific categories above but which they consider to be relevant to the Register’s purpose. Members should be mindful that the significance of a particular interest may change depending on the Commission’s concerns at any one time.

Miscellaneous non-financial interests

  1. Members should use this category to register unpaid interests, which they consider to be relevant to the Register’s purpose.

Political activity during the previous ten years

  1. The members should list any political activity which they consider relevant over the previous ten years, unless they believe disclosure of earlier relevant activity is advisable on propriety grounds.

Gifts, benefits and hospitality

  1. Members should exercise the utmost care in accepting hospitality or gifts where there could be a real or perceived conflict with their membership of the Commission.
  2. Members must register any gifts, benefits or hospitality with a value over £140 which they receive from a UK or overseas source which relates to their role as a member of the Commission. They must also register multiple benefits from the same source if these have a value of more than £140 in a calendar year. They must declare in the Register of Interests all such gifts, benefits or hospitality (including gifts that are received and surrendered).

Fees and expenses

  1. Independent members of the Ethics and Integrity Commission may claim £240 for each day they work on Commission business. Political members of the Commission do not receive any fees.
  2. All members of the Commission may claim reasonable travel and accommodation expenses (in line with Cabinet Office guidance), for journeys made specifically for the Commission’s work. 

Rail Travel

  1. In line with Cabinet Office guidance, when members are travelling by rail, they must always travel:
    1. standard or economy class, or
    2. via the lowest fare (even if this is 1st class).
  2. In certain circumstances it may be acceptable to choose a more expensive option if it offers greater flexibility.

Air Travel

  1. If air travel is necessary, members are asked to abide by the Cabinet Office guidelines. Air travel makes a significant contribution to climate change, and can be more expensive than surface travel. Members should carefully consider the need, the full cost (including travel between airports and offices) and the travel alternatives before booking flights.
    1. If the flight is less than 5 hours only an economy ticket is permitted.
    2. If the flight is greater than 5 hours a premium economy ticket may be purchased.
    3. If the flight is greater than 5 hours and a premium economy ticket is not available, business class may be purchased.

Accommodation

  1. When accommodation is required, every effort should be made to stay within Cabinet Office nightly rates.
  2. Propriety must always be exercised when claiming reimbursement.

[2] Excluding property used wholly for the member’s own personal residential purposes, or those of their spouse, partner or dependent children.

[3] Property in this context refers to land and buildings.

[4] This is in line with the House of Commons threshold for registration of shareholdings.