Register of Interests

Scheme for a Register of Interests

1. Purpose of the Register

The aim is to identify those activities and interests which governors and senior officials consider they should volunteer into the public domain because those interests might be interpreted as carrying a risk of bias in the conduct of the person's LSE duties. The aim is also to protect traditional academic freedoms and legitimate personal privacy.

2. Main characteristics of the Register

The Register is a deliberate mix of voluntary and compulsory. Whether a person is in the compulsory or voluntary section, they would only have to declare relevant interests ie in their judgement, as impartially as possibly, interests relevant to their LSE duties.

3. Do I need to register?

The Register is categorised into two parts. If you are a member of the groups listed under Part A it is compulsory to complete the form; if you are a member of Part B alone, registration is voluntary in the sense that you only have to complete the form if you have a relevant interest to declare.

A. Compulsory sections

Compulsory registration i.e. those who must file an entry even if they have no interest to declare:

  • All governors
  • Non-governor external members of School committees
  • All senior staff who must file an entry even if they have no interest to declare
  • Non-governor Chairs of School committees
  • Non-governor members of the APRC, Finance and General Purposes Committee and Audit Committee
  • Heads of Services ie. the Secretary, Director of Development and Alumni Relations, Librarian and Director of Information Services
  • Heads of Division in the Central Administration

B. Voluntary sections

Other persons who are invited to file an entry on the Register, but need do so only if they have a relevant interest to declare:

  • All budget holders and controllers
  • Heads of Departments
  • Heads of Research Centres
  • All committee members (including full members of the Academic Board), other than those who are in the compulsory sections of the Register

4. How to decide if an interest is relevant

An interest need only be declared if the individual considers it relevant to their LSE duties and that there is therefore a risk of it being reasonably perceived as biasing their decisions while conducting those LSE duties.
As far as possible there should be a distinction between the criteria for declaring an interest and the fact that declaring an interest is a personal decision. The following notes are therefore designed to assist those making entries on the Register to decide as impartially as possible whether to record an interest:

  • always bear in mind the HEFCE test: whether "an external observer, knowing the facts of the situation, would reasonably think that the person might be influenced by the interest";
  • the form for registration will have headed columns for the type of interest to be registered, thus providing a framework for deciding what to register;
  • the presumption is always in favour of declaring an interest: if a person is in doubt whether to register an interest, that means they should register it;
  • those who are still in doubt can approach the Head of the Planning and Corporate Policy Division for guidance about whether to declare a particular interest or not;
  • failure to declare an interest will be investigated by the Secretary of the School as in section 10 below.

5. Types of interest to be registered

The exact nature of the interest will vary according to personal circumstances but the following are examples of interests which should be declared if relevant to LSE duties:

  • company: any relationship with a named company with which the LSE might do business, including the LSE's own subsidiaries. Such interests would include:
    • ownership or part ownership;
    • share-holdings or other beneficial interest such as options, warrants etc. (where known; a lower limit for declaration of £10k).
       
  • Only share-holdings above the 3% notifiable level need be declared;
    • directorships;
    • paid employment, specifying position held (a lower limit of £1000pa);
    • partnership, consultancy, or close family connection.

       
  • self-employment: names of any client accounting for more than 5% of your total annual earned income;
  • property: freehold or leasehold ownership of any properties in which the School might have an interest;
  • charities: trusteeship or governorship of or employment with, any charities or voluntary organisations;
  • public appointments: paid or unpaid;
  • memberships: membership of professional bodies, trade or other association, or external bodies;
  • close family links: specified close family interest in any of the above. The definition of "close" would be up to the registrant to decide. It is appreciated that a declaration may be difficult to declare if information is not forthcoming from a family member.

In all of the above, registrants are not expected to quantify the extent of a financial interest, merely the fact that one exists.

6. Form of Registration

The information on LSE's Register consists of the following pro forma for each person registering:

  • Name
  • LSE official position held
  • Any LSE budgets held or controlled
  • LSE Committee memberships or secretary ships
  • Declaration of the nature of any possible conflict of interest, in columns labelled as follows with explanatory notes: company; self-  employment; property; charities; public appointments; memberships; close family links; other if not covered by these categories.
  • Date and signature of the registrant

7. Inspection of the Register

The Register is held centrally by the LSE Governance Team and will be made available for inspection by the public upon request during office hours (9.30am-5.30pm). For further information please call 020 7955 7975 to make an appointment

The School will not use information provided on the form for any other purpose than the Register.

8. Updating of Register entries

The Register is updated annually. The information to use is that which is current at the time of filling in the pro forma. Those who register are expected to update their entry whenever any relevant change of personal circumstances occurs.

9. Declarations at meetings

The Court of Governors requires governors to declare a conflict of interest if necessary at a meeting. This remains in force but will also apply to all staff of the School as defined in Parts A and B of the Register. Under the Companies Acts, there is an obligation for a director to ensure that disclosure of a conflict of interest is noted by the next meeting of directors. This will be covered by having the Register formally open at Court meetings and noting the fact in the minutes.

10. Undeclared conflict of interest

Any failure to declare a relevant interest may be investigated by the Secretary of the School.

11. Effective date

1 August 1998 onwards.

12. Register of Declared Interests| (Word) form to complete and to return.

August 2008

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