REGISTER OF BUSINESS AND PECUNIARY INTERESTS
A business interest is the involvement of an individual or their family members in any trade or profession, along with any direct interest they may have in any company providing goods or services to the school.
A pecuniary interest is a wider declaration to include personal financial interests, such as involvement in a trust fund or investment, as well as potential interests, for example, where a relative is applying for a vacancy in the school or where a trustee or governor is involved in the decision over the promotion of a colleague, or where they may be a potential candidate for the post made available.
When making a decision about what or what not to declare, the individual should consider how they may be challenged about their decision not to disclose information. Senior employees, budget holders, Directors, Trustees, Members and Local Governors of the Trust are required to register all relevant business and pecuniary interests, financial or otherwise, including:
- Directorships, partnerships and employment with businesses that provide goods or services to the Trust
- Trusteeships and governorships, including at other educational institutions and charities, irrespective of whether there is a trading relationship with the Trust
For each interest, the following:
- The name of the business, the nature of the business, the nature of the interest, and the date the interest began.
The above list is not exhaustive and the Trust requires all other interests to be disclosed which are likely, or if publicly known, would be perceived to be likely, to interfere with the exercise of independent judgement and the decision-making processes of the Trust.
The Trust also requires the business and pecuniary interests of close family members of senior employees, Directors, Trustees, Members and Local Governors of the Trust, influencing or making financial decisions (e.g. budget holders) to be disclosed in the register. New executive, non-executive and school staff should complete this form on joining the Trust or Local Governing Board or school.
Close family member includes any spouse, child, stepchild, parent, grandparent, grandchild or sibling, or any person living with them as his or her partner.
All of the above are specifically required to declare their interests in transactions or arrangements which are proposed but not yet entered into by the Trust, and to declare any interest in any existing transaction entered into by the Trust which could give rise to a conflict of interests.
RELATED PARTY TRANSACTIONS
Related parties include persons and entities with control or significant influence over the academy trust and members of the same group of companies:
- Academy trusts must declare their intention to enter into a new agreement before confirming the transaction with a related party supplier. This includes agreements being renewed with a related party supplier.
- Academy trusts do not need to declare income transactions with related parties. For expenditure related party transactions with a new supplier, academy trusts must confirm whether they have previously received a donation from the related party.
- In line with paragraph 5.42 of the Academies Financial Handbook, salaries and other payments made by an academy trust to a related party under a contract of employment, through the academy trust’s payroll, are not in the scope of this reporting requirement.
- Academy trusts must continue to report all related party transactions, regardless of value, in their annual financial statements as set out in the Academies Accounts Direction
- Academy trusts are required to seek prior approval from the ESFA when a single proposed contract or agreement with a related party exceeds £40,000; a proposed contract or agreement of any value means the total value of contracts or agreements with the same related party exceeds £20,000 in a financial year; and/ or a series of intended transactions with the same supplier can be submitted as a single request for approval, as long as sufficient detail about each transaction is included in the evidence provided.