Declaration of Interests

A copy of this policy is available as a pdf download here.

It is central to good and effective governance of the University that those persons holding positions of responsibility and influence should act in an open and transparent manner and not be influenced by social or business relationships that may have, or be presumed to have, affected their conduct of office or business decisions.

The University's Financial Regulations stipulate that Governors and members of staff having a pecuniary, family or other personal interest in any contract involving the University, need to declare such interests to the University. The University is required to update the declaration of interests register on an annual basis.

In addition, the Financial Regulations and the provision of the Bribery Act 2010 also require a full disclosure of the receipt of gifts and hospitality offered and received in consequence of employment or office held in the University. Governors are also required to provide an annual disclosure as a HEFCE requirement.

This policy applies to the following groups of staff and Governors:

• All Governors;
• Vice Chancellor;
• DVCs;
• PVCs;
• Deans of Schools;
• Directors of Services; and,
• Any member of CMT not included in the above categories.

These individuals must complete an annual declaration of interests form. There are two separate disclosure forms, one for staff and one for Governors.

The range of interests which might be disclosed are wide ranging and whilst it is for each person affected to determine the extent of declaration, the following might be appropriate to disclose:

• All paid employment/self-employment - including the nature or scope of activity;
• Involvement with contracts with the University or any subsidiary or associated companies or organisations;
• Directorships or equivalent;
• Major share holdings (over £25,000 value or >1% of issued share capital) held personally or immediate family members in any company with which the University (or it subsidiaries) has or might have a relationship;
• Elected Office, public appointments, trusteeship, governorship or other positions of authority/influence with organisations that the University does or might have business association;
• Ownership or control of property (land and buildings) close to any University premises; and,
• Personal relationships with any memberships with any member of the University community.

Where no such interests are identified a nil return must be given. If in doubt, declare it or seek the advice of the Secretary to the Board (ext 2626). Failure to make an appropriate disclosure may be a disciplinary matter.

The annual declaration form requests details of any hospitality or gifts received throughout the year and any conflicts of interests. This does not remove the need to disclose gifts, hospitality or conflicts as and when they arise and staff should continue to advise the Secretary to the Board of these.

Once completed, the form must be signed and returned to Corporate Strategy & Governance Unit, MA Building, Wulfruna Street, Wolverhampton, WV1 1LY.

The Corporate Strategy & Governance Unit will maintain an annual register of interests and will co-ordinate the issue of forms and completion. The Secretary to the Board will be responsible for holding and maintaining the register. Forms will be held securely in a register held by the Corporate Strategy & Governance Unit. The contents are personal data and will be kept and processed only in conformance with the University's Data Protection policies.

Page last updated: August 2012