Overview
This policy is part of Our Code, which all colleagues are required to attest to on joining the Bank and annually thereafter.
Why do we need this policy?
The requirements in this policy are designed to protect us against the risk that certain personal or professional relationships could create, or could be perceived as creating, a conflict of interest, or the perception of influence, or unfair advantage.
This includes where we are having active discussions about prospective employment (eg participating in a formal interview or selection process) with a Bank regulated firm, a significant dealing counterparty of the Bank, a firm with whom we have contact with as a supplier of the Bank, or any other organisation that might be considered sensitive given the nature of its work and its relationship to the Bank such that a conflict of interest, or the perception of influence or unfair advantage, could arise.
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?
Working for the Bank, we are expected to be independent of personal interests that might influence our judgement or affect our decisions in fulfilling the Bank’s mission.
We respect our colleagues’ right to a private life. However, the Bank needs to know about close personal or professional relationships with certain individuals and organisations in order to manage the risk of any actual, potential or perceived conflict of interest, or the perception of influence or unfair advantage.
You must disclose any close family members (ie spouse/partner, parents, siblings, and children) in the following roles:
- working in the Bank;
- working in financial, economic, or political journalism;
- working in a Bank-regulated firm;
- working in a significant dealing counterparty of the Bank;
- working in a supplier holding a contract with the Bank;
- working in a supplier or prospective supplier tendering for a contract with the Bank where you are involved in that tendering process;
- holding a national or regional elected public office (MPs, the Scottish Parliament, the Welsh Parliament, Regional Mayors, the London, or Northern Ireland Assemblies), or a member of the House of Lords
You must also declare any other close personal relationship that could give rise to an actual, potential or perceived conflict in relation to a specific decision in which you are involved, or your day-to-day work more generally, given your role and that of the individual in question. This could be with individuals working in or outside the Bank. Such conflicts relating to a particular situation are likely to arise only occasionally.
Please see Appendix 1 for a flowchart to help in deciding which relationships need to be declared.
1: Close personal relationship with someone working in the Bank
Where a close personal relationship with someone working in the Bank exists, adjustments may be needed. This is particularly relevant for example in areas where there is dual control of assets, or signature panels for release of payments.
You must not participate in the hiring process, a decision to hire, directly or indirectly manage, or contribute to appraisals, pay and promotion decisions of someone with whom you have a close personal relationship. Beyond this, if you personally know someone seeking employment with, or business from the Bank, you should discuss with your line manager the extent to which it is appropriate for you to be involved in the related decision-making process.
You are not expected to declare all of your friends at the Bank, but you should declare romantic relationships and cohabitation arrangements.
2: Close personal relationship with someone working outside the Bank
Where you have a close personal relationship with someone working for an organisation with a financial interest in the activities and/or decisions of the Bank, this may mean that you cannot take on or continue in some roles because this may give rise to an actual, potential or perceived conflict of interest, or the perception of influence or unfair advantage. Where such a relationship exists it could mean, for example, you not directly supervising a Bank-regulated firm; not having any involvement in contingency planning for a Bank-regulated firm; not having a role that requires being part of insider lists eg. MPC or FPC or not being involved in a particular procurement process.
The following principles are considered when deciding the mitigants that may be required in a given case:
- the precise role of the individual working outside the Bank – for example, do they have a role of senior responsibility in a firm that profits, in part, on the outcomes of Bank deliberations where there is a heightened risk that the role creates a motive for perceived use of inside information;
- the nature of the relationship – for example, a cohabiting spouse/partner brings an increased perception that information could be shared;
- the role that you currently have at the Bank/are applying for at the Bank – for example, how much insight you have into sensitive policy discussions or significant decisions.
You are not expected to declare all friendships with those who work in regulated firms or suppliers to the Bank however, romantic relationships or cohabitation arrangements with such individuals must be declared. Additionally, if, for example, you work on capital and liquidity policy and have a close friend working in the capital-planning function of a PRA-regulated firm, this should be declared.
You should always consider whether a prior acquaintance with someone seeking employment with, or business from the Bank, ought to be disclosed where you are in any way involved in the decision to appoint.
3: Your day-to-day work
3.1. If you consider that an actual, potential or perceived conflict of interest relating to a close personal or professional relationship could arise in the course of your day-to-day work, you must bring this to your manager’s attention promptly. Your general disclosure in the Our Code Compliance system is not a substitute for this responsibility.
4: Discussions about prospective employment
Actual, potential or perceived conflicts of interest may arise where you are seeking a role with a prospective new employer and may also need to be disclosed.
You must disclose, with reasonable advance notice, if you are having active discussions about prospective employment (eg participating in a formal interview or selection process) with any of the following:
- a Bank-regulated firm;
- a significant dealing counterparty of the Bank;
- a supplier that you have contact with as a Bank supplier or as a potential supplier tendering for a contract with the Bank; or
- any other organisation that might create a conflict of interest, such as Lloyd’s Managing Agents or consultancy and legal firms providing advice or services to Bank-regulated firms.
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.
Discussions of prospective employment should be declared as a Personal Relationship in the Our Code Compliance System so that your manager is aware, and any potential conflict of interest can be managed appropriately.
If you do not wish to notify your line manager in advance of your active discussions with one of these types of firms, suppliers or potential suppliers, you must inform the Conflicts team aware promptly and take advice on the management of any conflicts that may arise. The Conflicts Team will maintain your confidentiality unless the nature of the conflict(s) identified make some form of disclosure to management unavoidable. That would be discussed fully with you in advance. The Conflicts Team can help determine whether you need to alert your line manager in order to mitigate any such risks. They can also advise line managers on the management of any conflicts that may arise.
Key policy requirements
For all colleagues
1. You must promptly disclose the personal relationships set out above in the Our Code Compliance system.
2. You must not participate in the hiring process, a decision to hire, directly or indirectly manage, or contribute to appraisals, pay and promotion decisions of someone with whom you have a close personal relationship.
3. If you are unsure about whether to disclose a relationship, please seek guidance from your manager or the Conflicts team before making a declaration.
3.1. This includes where you are no longer in contact with a family member and may need to be granted an exception to the disclosure requirement.
4. Where a conflict is identified you should co-operate with any steps taken in order to protect you, the person with whom you have declared the relationship, and/or the Bank.
4.1. In some circumstances, it may be necessary to discuss with you a transfer to another area or to other work, or avoidance of particular work. This would be in full consultation with the parties involved.
5. If circumstances change, you must promptly update any declarations in the Our Code Compliance System and notify your line manager.
6. Remember that the Bank’s Declaration of Secrecy requires us all to maintain the strictest secrecy over information of any kind that is acquired whilst working at the Bank.
For all Managers
1. You must ensure that you and members of your team understand the requirements of this policy.
2. If a personal relationship has been declared, you must:
2.1. review the disclosure promptly via the Our Code Compliance System and consider whether it is required;
2.2. assess the nature of the risk that might arise from this relationship;
2.3. agree the risk assessment and any mitigants that might need to be put in place with a HoD (or above). See Appendix 2 for some example mitigants;
2.4. if mitigants are needed, put them in place and review them at least annually;
2.5. record the agreed actions in the Our Code Compliance System;
2.6. ensure you receive confirmation that the individual has completed any actions required; and
2.7. contact AskConflictsAdvice if you have any questions about a personal relationships disclosure you have received from one of your team.
What support is available to help you comply with this policy?
The following link will aid your understanding of, and compliance with, this 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
Figure 1: Flowchart to help you understand if you need to declare a personal relationship
Box A: Close family members (spouse/partner, parent, sibling or child)
Declare close family members working in:
- the Bank;
- financial, economic or political journalism;
- a Bank-regulated firm;
- a significant dealing counterparty of the Bank;
- a supplier holding a contract with the Bank;
- a supplier or prospective supplier tendering for a contract with the Bank where you are involved in that tendering;
- or holding national or regional elected public office.
Box B: Other close relationships
Declare any other close personal relationship that could reasonably give rise to an (actual, potential or perceived) conflict of interest in relation to:
- a specific decision in which you are involved; or
- your work more generally, given your role and that of the individual/organisation.
Box C: Prospective employment
Declare active two-way discussions about prospective employment with:
- a Bank-regulated organisation;
- a significant dealing counterparty of the Bank;
- a supplier that you have contact with as a Bank supplier or potential supplier tendering for a contract with the Bank; or
- any other organisation that might create a conflict of interest, such as consultancy and legal firms providing advice/services to Bank-regulated firms.
Some existing examples of mitigants include:
For internal relationships:
- ensuring that any dual control/access is appropriately reviewed.
- considering whether participation in decisions around pay or promotion is appropriate.
- considering cross directorate/division working; managing any actual, potential or perceived conflicts of interest or unfair advantages etc.
For external relationships:
- not supervising the firm/attending firm-specific meetings.
- disclosure to management on social interactions.
- recusal from any investigation of the firm.
- changes in reporting lines.
- no involvement in contingency planning for a specific firm.
- not having a role where being part of the MPC or FPC insider lists is required.
- not being involved in a particular procurement process or management of a particular supplier.
January 2026