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Key points

  • Conflicts of interest are interests that are likely to prejudice the way a person carries out their role as a pension board member.
  • The scheme manager must be satisfied that public service pension board members don’t have a conflict of interest.
  • You should set up a process to identify, monitor and manage potential conflicts of interest of pension board members.
  • Pension boards must have equal numbers of employer and member representatives.

What is a conflict of interest?

In public service schemes a conflict of interest is a financial or other interest likely to prejudice the way in which someone carries out their role as a member of a pension board. It doesn’t include a financial or other interest arising merely from them being a member of the scheme or any connected scheme.

For example, an employer representative appointed to the pension board to represent employers generally could be conflicted if they only serve to act in the interests of a section of employers, rather than all participating employers.

Actual conflicts of interest aren’t allowed in public service schemes – they can’t be managed. Only potential conflicts can be managed.

If you’re a pension board member you must provide information to the scheme manager when requested, so that they can be satisfied you don’t have a conflict of interest.

Setting up a conflicts process

You should have processes that enable conflicts to be identified, monitored and managed. It is important for you to be alert to situations that could create potential conflicts of interest.

Your process should include the following controls:

  • a conflicts policy setting out the scheme’s approach to dealing with conflicts
  • a register of interests for recording all actual or potential conflicts
  • disclosure before pension board members are appointed
  • ongoing disclosure as soon as potential conflicts arise
  • advance planning to identify conflicts that may arise in the future

Public Service toolkit online learning

Go to the Public Service toolkit You can learn more about what conflicts of interest are, their potential impact and how to manage them in the 'Conflicts of interest' course. You must log in or sign up to use the Public Service toolkit.

Pension board representation

Pension boards must have an equal number of employer and member representatives, but otherwise there is flexibility for the pension board representation arrangements to be designed in a way that best suits your scheme.

Detailed guidance

'Conflicts of interest' section of the public service code of practice.

The seven principles of public life on GOV.UK.

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