Colleague conflict of interest policy

Published: 12 June 2026
Freedom of information class: How we manage our resources

RoS requires all colleagues to act with integrity, honesty, objectivity, and impartiality, in line with the Civil Service Code. This policy applies to all employees and contingent workers, who must avoid improper influence or personal gain.


1. Purpose and scope

1.1 This policy sets out RoS commitment to act with integrity, honesty, objectivity and impartiality in all that it does, these standards are reinforced by the Civil Service Code.

1.2 As civil servants, all RoS colleagues should be aware of the core values of integrity and honesty set out in the Civil Service Code and the requirement that civil servants must not accept gifts or hospitality or receive other benefits from someone who might reasonably be seen to compromise our personal judgement or integrity. Similarly, they should not be influenced by improper pressures from others or the prospect of personal gain.

1.3 This policy applies to all employees and contingent workers.

2. Definition

2.1 The term conflict of interest occurs when a colleague's personal interests - such as financial interests, relationships, or external activities – could compromise, or appear to compromise, their ability to act impartially and in the best interests of RoS. Further examples of where a conflict can arise are provided in Annex 1.

3. The policy

3.1 If a colleague has a connection to a third party engaging with RoS, then the colleague must discuss the connection with their line-manager before any further interaction with that person on behalf of RoS.

3.2 If the line manager identifies that the connection could indicate a conflict of interest or a potential conflict of interest, then the work must be reassigned to another colleague.

3.3 Line managers will be expected to exercise discretion and judgement based on the strength of the conflict (or potential conflict), the likely perception that this could create inside or outside of the organisation.

3.4 If the colleague and line manager require further support after discussing the matter, then they should refer the matter to Employee Relations.

3.5 A colleague who fails to disclose a potential conflict of interest and/or continues to interact with a connected party on behalf of RoS could be subject to the RoS Disciplinary Process.

3.6 Conflicts of interest can bias how we make decisions and in some rare instances can cause or contribute to fraud.

3.7 Further guidance for colleagues and managers can be found in Annex 1.

4. Approval and review

4.1 This policy will be reviewed and approved by the Policy and Practice Group annually, unless earlier review is appropriate.

AuthorFraud Prevention Team
ReviewedCounter Fraud Officer
Cleared Head of Policy and Legal
ApprovalPolicy and Practice Group (PPG) Approval date September 2025
Policy versionV 2.0
Review responsibilityPolicy and Practice Group (PPG) Review date January 2027
Publication scheme Yes
Email to contactinternalfraud@ros.gov.uk