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Conflicts of interest

Conflicts of interest lead to unfair, dishonest and even corrupt behaviour.

Conflicts of interest can also break the law. They can cause serious problems for you and real damage to our integrity and reputation.

Even when there's no actual conflict just the appearance of one can do serious harm.

A Conflict of Interest arise when your private interests interfere, or could appear to interfere, with the best interests of Serco.  Your own business judgement may be improperly influenced as result of the conflict, or because you or someone you know may benefit to the expense of the company or another employee.

Organisational Conflicts of Interest can arise when a company could end up with an unfair competitive advantage in the market.  If we don't identify and resolve these, they can do enormous harm.  One example is when we employ someone who has access to proprietary information or who might be able to influence government decisions that could benefit Serco.  This is called "Unequal Access to Information". But there are other kinds of OCIs as well. Whenever you think there may be an OCI you should raise it at once.

Examples of actual or potential conflicts of interest

  • Serco is competing for work from a customer you are advising.
  • You have secondary employment.
  • You, your spouse, partner or family member:
    • has a financial interest in any company or business venture we do business with.
    • is employed by any other Serco business or joint venture.
    • is employed by a direct competitor to any other Serco business or joint venture.
    • is employed by a supplier of goods or services to Serco.
  • As a leader or manager you find yourself making an employment decision relating to a spouse, partner, close family member or friend.
  • You become aware of conditions that might compromise impartiality or neutrality so Serco will benefit unfairly.
  • You know competitive terms are unequal, favouring one company over another.

For more information, help and advice, check out our SayNo Toolkit and App.

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For more information download:

Conflicts of Interest fact sheet

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What you can expect from us:

  • At Serco all actual and potential conflicts of interest should be identified, declared, recorded, monitored and managed.
  • We will take care to identify and resolve any Organisational Conflicts of Interest (OCIs) that may result in us having an unfair competitive advantage.
  • We also have strict procedures and regulations regarding personal conflicts of interest that may cause the interests of our employees to conflict with those of Serco.
  • Beyond that, we leave you entirely free to make personal investments and enjoy both social and normal business relations.
  • We also encourage you to participate in community, charitable and professional organisations, so long as these do not involve any business or personal relationships that may create an actual or potential conflict of interest. For example, an outside relationship with an organisation you deal with as part of your job will always appear to have the potential for a conflict of interest.

We expect you to:

  • Make business decisions on behalf of Serco rather than your own personal interests or the interests of your family or friends.
  • Avoid actual conflicts of interest and the appearance of them.
  • Identify and always declare any actual or potential conflict of interest you may have. If you're not sure, ask.
  • Always report any outside business relationships or roles you have to your manager (for example, if you have a second job, provide services, or are a director in another organisation). If the relationship is with a competitor, customer or supplier, you should obtain your manager's written approval.
  • Never have any significant financial interest in a supplier, including investments and debts, if you are involved in any aspect of our relationship with them, either directly or through someone who reports to you.
  • Report any potential or actual Organisational Conflict of Interest as soon as you become aware of it, and follow any plans put in place to manage it.

Conflicts of interest lead to unfair, dishonest and even corrupt behaviour. They can also break the law. They can cause serious problems for you and real damage to our integrity and reputation.

Even when there's no actual conflict just the appearance of one can do serious harm.

During the week you use a company van as part of your role. On the weekend, you need to move some furniture at home.

Is it okay to use the van providing you pay for the fuel you use?

1. Unless I had permission, it would be wrong

Right answer because:

Company assets, like the van, are for company use, but you are using them for your own private use. So this is actually a conflict of interest.

A conflict of interest happens when your private interests interfere, or could appear to interfere, with the best interests of Serco. You benefit at the expense of the company.

In this case, the van isn't like a company car that's been provided as part of the terms of your employment, and can be used privately. The van is there for company business. You don't have permission to use it outside business.

And the vehicle is probably not insured for this activity, so an accident would not be covered, and could cause problems for the business, and for you.

Using the van like this is in your interests, but is not in anyway in Serco's interests.

It's also dishonest, and goes against our Code on the use of company assets.

 

What our contractors do is our business

2. Yes, it's one of the perks of the job

Wrong. Please try again.

3. If I'm paying for the fuel, what's the harm?

Wrong. Please try again.

Your partner has just joined one of Serco's key suppliers.

Should you declare that?

1. How am I supposed to know?

Wrong. Please try again.

2. Yes

Right answer because:

At Serco we have strict procedures and regulations regarding personal conflicts of interest that may cause the interests of our employees to conflict with those of Serco.

We expect you to make business decisions on behalf of Serco rather than your own personal interests or the interests of your family or friends. And to identify and always declare any actual or potential conflicts of interest you may have.

Our Code gives you some specific examples of actual or potential conflicts of interest, which include the following:

You, your spouse, partner or family member:

  • has a financial interest in any company or business venture we do business with
  • is employed by any other Serco business or joint venture
  • is employed by a direct competitor to any other Serco business or joint venture
  • is employed by a supplier of goods or services to Serco

In this case, therefore, you can have no doubt that this represents a potential conflict of interest, and you must declare it. By doing this, we can make sure that no actual conflict of interest arises.

It can sometimes be a little confusing to know if there is a potential or actual conflict of interest. That's why our Code tells us:

If you're not sure, ask.

 

3. No, it's just a supplier

Wrong. Please try again.

Your boss is looking for a new local cleaning company as he is unhappy with the service provided by the current supplier.

Your brother-in-law runs a local cleaning business.

Can you recommend your brother-in-law's company?

1. So long as my relationship to him is declared, that's fine

Right answer because:

It is your boss who is making the decision. So providing that your relationship has been disclosed, and you are not involved in the awarding or running of the contract in any way, there is no conflict of interest here.

One of the key points about a conflict of interest is that your own business judgement may be improperly influenced as a result of the conflict, or because you or someone you know may benefit at the expense of the company or another employee. None of this applies here.

However, it's vital that you declare your relationship with your brother-in-law right at the outset. If you didn't, and this emerged later, then a suspicion of favouritism could arise, even if there was none. And just the appearance of a conflict of interest can do serious damage.

What you can't do in this case is to provide a reference for your- brother-in-law's business, as you should not be involved in any part of the decision to appoint the new cleaning contractor.

It can sometimes be a little confusing to know if there is a potential or actual conflict of interest. That's why our Code tells us:

If you're not sure, ask.

 

2. No, he's family

Wrong. Please try again.

3. There are too many potential issues, so no

Wrong. Please try again.

A major customer is desperately looking for project managers for the team that works with you.

You know your sister is perfectly qualified and looking for a new role.

Is it OK to recommend her?

1 Yes, if I've told the customer and my manager that she's my sister

Right answer because:

You can recommend your sister, but only if you are totally open and transparent on this matter.

You must not only tell the customer of the connection, but also your manager. If you do that, and you have your manager's agreement, you can recommend your sister.

Both the customer and your manager may choose not to allow this, because working closely with a family member might lead to conflicts of interest, particularly if you have disputes to resolve or negotiations to complete.

But because you are being open and transparent they are free to assess this for themselves, and make their own judgement based on full disclosure.

Both the customer and your manager would have to consider if you or your sister would or could benefit at the expense of their companies, or another employee.

However if your sister is properly interviewed and accepted for the role, this would benefit the customer, and your team.

It would be important that both you and your sister continue to monitor things, and declare any potential or actual conflict of interest that may arise in the future.

2. No, because I'd then be working with my sister

Wrong. Please try again.

3. No, it would be a conflict of interest

Wrong. Please try again.

Dilemma 1

During the week you use a company van as part of your role. On the weekend, you need to move some furniture at home.

Is it okay to use the van providing you pay for the fuel you use?

1. Unless I had permission, it would be wrong

Right answer because:

Company assets, like the van, are for company use, but you are using them for your own private use. So this is actually a conflict of interest.

A conflict of interest happens when your private interests interfere, or could appear to interfere, with the best interests of Serco. You benefit at the expense of the company.

In this case, the van isn't like a company car that's been provided as part of the terms of your employment, and can be used privately. The van is there for company business. You don't have permission to use it outside business.

And the vehicle is probably not insured for this activity, so an accident would not be covered, and could cause problems for the business, and for you.

Using the van like this is in your interests, but is not in anyway in Serco's interests.

It's also dishonest, and goes against our Code on the use of company assets.

 

What our contractors do is our business

2. Yes, it's one of the perks of the job

Wrong. Please try again.

3. If I'm paying for the fuel, what's the harm?

Wrong. Please try again.

Dilemma 2

Your partner has just joined one of Serco's key suppliers.

Should you declare that?

1. How am I supposed to know?

Wrong. Please try again.

2. Yes

Right answer because:

At Serco we have strict procedures and regulations regarding personal conflicts of interest that may cause the interests of our employees to conflict with those of Serco.

We expect you to make business decisions on behalf of Serco rather than your own personal interests or the interests of your family or friends. And to identify and always declare any actual or potential conflicts of interest you may have.

Our Code gives you some specific examples of actual or potential conflicts of interest, which include the following:

You, your spouse, partner or family member:

  • has a financial interest in any company or business venture we do business with
  • is employed by any other Serco business or joint venture
  • is employed by a direct competitor to any other Serco business or joint venture
  • is employed by a supplier of goods or services to Serco

In this case, therefore, you can have no doubt that this represents a potential conflict of interest, and you must declare it. By doing this, we can make sure that no actual conflict of interest arises.

It can sometimes be a little confusing to know if there is a potential or actual conflict of interest. That's why our Code tells us:

If you're not sure, ask.

 

3. No, it's just a supplier

Wrong. Please try again.

Dilemma 3

Your boss is looking for a new local cleaning company as he is unhappy with the service provided by the current supplier.

Your brother-in-law runs a local cleaning business.

Can you recommend your brother-in-law's company?

1. So long as my relationship to him is declared, that's fine

Right answer because:

It is your boss who is making the decision. So providing that your relationship has been disclosed, and you are not involved in the awarding or running of the contract in any way, there is no conflict of interest here.

One of the key points about a conflict of interest is that your own business judgement may be improperly influenced as a result of the conflict, or because you or someone you know may benefit at the expense of the company or another employee. None of this applies here.

However, it's vital that you declare your relationship with your brother-in-law right at the outset. If you didn't, and this emerged later, then a suspicion of favouritism could arise, even if there was none. And just the appearance of a conflict of interest can do serious damage.

What you can't do in this case is to provide a reference for your- brother-in-law's business, as you should not be involved in any part of the decision to appoint the new cleaning contractor.

It can sometimes be a little confusing to know if there is a potential or actual conflict of interest. That's why our Code tells us:

If you're not sure, ask.

 

2. No, he's family

Wrong. Please try again.

3. There are too many potential issues, so no

Wrong. Please try again.

Dilemma 4

A major customer is desperately looking for project managers for the team that works with you.

You know your sister is perfectly qualified and looking for a new role.

Is it OK to recommend her?

1 Yes, if I've told the customer and my manager that she's my sister

Right answer because:

You can recommend your sister, but only if you are totally open and transparent on this matter.

You must not only tell the customer of the connection, but also your manager. If you do that, and you have your manager's agreement, you can recommend your sister.

Both the customer and your manager may choose not to allow this, because working closely with a family member might lead to conflicts of interest, particularly if you have disputes to resolve or negotiations to complete.

But because you are being open and transparent they are free to assess this for themselves, and make their own judgement based on full disclosure.

Both the customer and your manager would have to consider if you or your sister would or could benefit at the expense of their companies, or another employee.

However if your sister is properly interviewed and accepted for the role, this would benefit the customer, and your team.

It would be important that both you and your sister continue to monitor things, and declare any potential or actual conflict of interest that may arise in the future.

2. No, because I'd then be working with my sister

Wrong. Please try again.

3. No, it would be a conflict of interest

Wrong. Please try again.