Financial relationships

Overview

Why do we need this policy?

All of us face decisions about managing our finances, including where to save or invest our money. Those of us who join the Bank mid-way through our career may also retain connections with a previous employer, for example through deferred remuneration or membership of a company pension scheme. The information that we have access to is often not in the public domain and our role as a regulator and policy maker creates a risk that we could be perceived as using the Bank’s information to further our personal interests if we don’t take appropriate steps to guard against this.

That is why the Bank also needs to know about any ongoing relationships with financial institutions that might influence or be perceived to influence your judgement or affect your decisions at work.

Who does this policy apply to?

This policy applies to all colleagues employed by the Bank, including colleagues on fixed-term contracts. It also extends to contractors and/or agency workers.

What you must know or do?

You must disclose certain financial relationships that create a continuing financial interest in the profitability of a firm that we regulate or a supplier holding or tendering for a contract with the Bank. You must do so on joining the Bank and update them if/when they change.

In addition, once you have joined the Bank, you must seek advance permission before you make certain personal financial transactions (see the Personal Financial Transactions (PFT) policy).

1: What relationships do I need to declare?

• Direct holdings of securities or related investments in a Bank-regulated firm or its financial holding company, including stock options and share related reward schemes.
• Direct holdings of individual gilts.

Direct holdings of cryptoassets by which it is meant a cryptographically secured digital representation of value or contractual rights that uses a form of distributed ledger technology and can be transferred, stored, or traded electronically (examples include Bitcoin and Ether) that is not a tokenised bank account, tokenised deposit or any other UK regulated instrument.

Holding a cash balance or deposit in a Bank-regulated firm of a value greater than the FSCS limit. (If you have accounts that are covered by Temporary High Balance Scheme under the FSCS scheme – up to £1.4m for six months for certain life events – you are not required to disclose this).

• Holding an investment or a pension product with a Bank-regulated insurer whose return depends in part on the profits of the insurance company – for example, a ‘with profits’ policy.
• Any other financial relationship that could reasonably be considered an actual, potential or perceived conflict of interest. This would include deferred remuneration arrangements and direct holdings of securities or related investments in suppliers holding or tendering for a contract with the Bank where you are involved in those procurement processes.
• Similarly, you are required to disclose these types of financial relationships held by another individual or organisation where you direct or advise on their financial arrangements.^{footnote [1]}

To find out whether a firm is Bank-regulated search for and select the firm via the Financial Services Register, then expand the ‘Regulators’ section. For a list of Financial Market Infrastructure (FMI) firms we supervise (also included in the Bank-regulated definition) see the FMIs we supervise section on the Bank’s website.

Appendix 1 sets out a flowchart to help you understand which financial relationships you need to disclose.

2: Your day-to-day work

If you consider that an actual, potential or perceived conflict of interest relating to a financial relationship could arise in the course of your day-to-day work, you must bring this to the attention of your manager (for example, in taking decisions regarding Bank-regulated firms or suppliers holding or tendering for a contract for the Bank where you have direct holdings or investments in those firms or suppliers). Your general disclosure in the Our Code Compliance system is not a substitute for this responsibility. If you are unsure about whether to disclose a particular financial relationship, please seek guidance from the Conflicts team.

3: Financial relationships that do not need to be declared

The following examples do not need to be declared under this policy:

• shares held in banks and insurers via a tracker fund;
• bank accounts where the combined amounts held with a firm is below the FSCS limit;
• a Bank-regulated firm is acting as the asset manager for your investments; and
• holdings of crypto assets in collective investment schemes.

Key policy requirements

What support is available to help you comply with this policy?

The following links will aid your understanding of, and compliance with, this policy:

• Our Code
• Personal Financial Transactions policy

The application of this policy will be in accordance with the relevant data protection legislation. For information on how the Bank processes your data, please see the Bank’s Privacy Notice to Staff.

What is the impact of non-compliance?

If you realise you have breached – or suspect that you might have breached – a requirement in this policy please tell AskCompliance as quickly as possible, so that the issue can be reported and redressed under the Bank’s Breach Management Policy. The Bank gives credit for you taking prompt responsibility for your mistakes. You should be aware that failing to discharge your responsibilities could lead to disciplinary action or action taken under the Bank’s other formal processes.

Appendices

• Appendix 1: Do I need to declare a financial relationship?

  Figure 1: Flowchart to help you understand if you need to declare a financial relationship

  

  Box A: Financial relationships that must be declared

  • direct holdings of securities or related investments in a Bank-regulated firm, or its financial holding company, including stock options and share-related reward schemes;
  • direct holdings of individual gilts;
  • direct holdings of crypto assets;
  • balances or deposits in a Bank-regulated firm greater than the FSCS compensation limit;
  • holding an investment or pension product with a Bank-regulated insurer whose return depends in part on the profits of the insurance company – for example a ‘with-profits’ policy;
  • any other financial relationship that could reasonably be considered an actual, potential or perceived conflict of interest.

• Appendix 2: Example mitigants

  Specific mitigants are unlikely to be needed for many of the financial relationships that are declared. This is because the Personal financial transactions (PFT) policy acts as a Bank-wide mitigant for the majority of them. The PFT policy requires colleagues to seek approval if they wish to change the nature of most of these relationships – PFT requests are screened in Secretary’s Department and considered by the individual’s Local Reporting Officer (LRO) for sensitivities. For example:

  • Significant movements (above £5,000) out of accounts above the FSCS limit to another account/NS&I need advance approval under the PFT policy. Approval must also be sought for any transaction that could be deemed sensitive because the individual knows something about the firm from their role at the Bank that is not in the public domain (such as advanced contingency planning, an adverse stress test result, a breach of regulatory requirements, an intervention by the Bank with respect to that firm etc).
  • Individuals are permitted to retain pre-existing direct shareholdings in Bank regulated firms or their financial holding companies, but may not acquire more, and must seek approval before disposing of any of these holdings. An appropriate mitigant for some roles may be that disposal of such shares will not be permitted (for example while working in the relevant Supervisory team).
  • For ‘with-profits’ policies, it may be necessary to set a mitigant, such as that an individual must hold the policy to maturity if they are working in an area where they would have regular access to confidential information relating to the firm concerned (such as in Insurance Supervision).
  • For deferred remuneration, in the majority of cases it will not be necessary to set a mitigant. In cases where role holders will have significant seniority or are key decision makers then mitigants such as converting to cash/debt before taking up the role (to remove equity exposure) or being removed from making certain decisions may be necessary. Please reach out to the Conflicts team to discuss.
  • For direct holdings of cryptoassets, in the majority of cases it will not be necessary to set a mitigant as pre-approval rules apply for disposal of direct holdings where colleagues have privileged access to information (please see the Personal Financial Transactions policy). In certain cases, other considerations may include amending decision-making capabilities and potential limiting or removal of access to relevant insider information. Please reach out to the Conflicts team to discuss.

January 2026