Standards of Conduct and Probity
BHT Sussex expects the highest standards of conduct and probity. These standards are reinforced by legislation, our ethos, and our constitution.
We promote a culture in which potential and actual conflicts of interest, whether financial or more general, are formally recorded and available for public inspection.
A list of all members of the Board Co-optees, and Senior Managers will be held on the BHT Sussex Public Register held by the Company Secretary, together with details of the BHT Sussex external auditors and key regulators.
Each member of the Board will make a declaration of their interests which will be lodged in the BHT Sussex Public Register.
Senior Managers, and employees involved in the procurement of repairs and contracts, will also make a declaration of interests which will be lodged in the BHT Sussex Public Register.
Examples of conflicts of interest
This is a list of conflicts of interest which commonly arise, the list is not exhaustive:
- Close links with, or interest in, a particular organisation or institution from which a grant or other funding application is being considered (e.g. employment or academic collaborations).
- A commercial or pecuniary interest e.g. where an individual, or an organisation with which an individual is involved, may benefit financially, directly or indirectly, from a decision made.
- A non-pecuniary interest where an individual has other interests that might be thought to influence them, either wittingly or unwittingly.
- Personal or family interest with regard to both pecuniary (from connections with bodies which have a direct financial interest, or from being a business partner, or being employed by a person with such an interest) and non-pecuniary (any benefit or favour “in kind” including arising from membership of clubs or other organisations) interests.
The BHT Sussex Public Register will be made available for public inspection within five working days of a written request being received by the Company Secretary. The Company Secretary will ensure the BHT Sussex Public Register has all sensitive personal information redacted, such as home address, bank, or family member details.
A separate policy exists relating to the receiving of gifts and hospitality. All employees and members of the Board will be reminded of this policy on an annual basis. The Gifts and Hospitality Policy requires various declarations be made for inclusion in the BHT Sussex Public Register.
All Board members and senior managers are required to declare any gifts and hospitality received. The acceptance of gifts and hospitality is governed by strict rules.
BHT Sussex encourages its employees to participate in civic duties including becoming magistrates or standing for elected office. BHT Sussex recognises there is a potential for conflicts of interest not least in standing for and on election to public office.
As a matter of policy, BHT Sussex does not have elected representatives on its Board, be they local councillors, Members of Parliament, or any other elected office. If a member of the Board is elected to public office, they will be asked to stand down from the Board.
BHT Sussex has policies and procedures that may be activated in the event of an alleged conduct breach, or where issues of probity might arise. Advice on the most relevant policy and procedure to be used can be obtained from the Chief Executive, Company Secretary or Chair of the Board.
Further information regarding the BHT Sussex Whistleblowing Policy and Procedure can be found here.