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Code of Conduct & Conflicts of Interests Policy



  • Local Economic Partnerships (LEPs) are partnerships between Local Authorities and private businesses. They are charged by government with setting the economic growth priorities for their areas, providing business-led solutions to meet the UK productivity challenge, through local investment in physical infrastructure, workforce skills & training and business innovation and enterprise (please visit for further information).
  • Local planning authorities should use LEPs as a key source of information and guidance on the economic and business dimension of their plans and policies.
    LEPs should be treated as formal consultees in the plan and policy-makingprocess, including providing them access to planning expertise.
    Due to the close-knit nature of the LEPs’ engagement with local authorities, and the representation of local business on each LEP Board, LEPs are exposed to the potential of conflicting interests to emerge during their work. These conflicts can arise within the operations of the LEP local authorities and privately held businesses.
  • The “National Local Growth Assurance Framework” has been developed to guide local decision making to support accountability, transparency and value for money. It requires that LEPs:
    • have clear arrangements in place to enable effective and meaningful engagement with local partners and the public;
    • operate transparently, giving the public confidence that decisions made are proper, based on evidence and capable of being independently scrutinised; and,
    • have a published conflicts of interest policy, a published register of interests covering any decision makers, which is kept updated, and a published complaints policy. This policy is to ensure that any conflicts of interest which may arise in the LEP’s business processes are recorded and managed. This is to protect the integrity of the LEP and to give stakeholders confidence in the probity of the LEP’s decisionmaking. Therefore, it helps to protect the reputation of the LEP and of its members.


  • These arrangements apply to the LEP Board, its staff (where applicable) and committees, groups, and any co-opted members or advisers to the LEP.
  • The principles also apply to the LEP’s wider business membership or those purporting to speak for the LEP. All participants in decision-making fora, including the Board and any of its subsidiary entities, shall be required to abide by the ‘Code of Conduct’ set out in the LEP Board’s Terms of Reference.
  • Where other codes of conduct or policy arrangements apply to members in their respective roles outside of the LEP, the LEP’s Code and Policy take precedence whilst that member is acting for the LEP.
  • Interests in matters relating to the agenda of any meeting shall be declared and noted at the beginning of each meeting.
  • All LEP Board members and staff are required to conduct themselves in accordance with The Seven Principles of Public Life listed at Appendix A. These are the basis of the ethical standards expected of public office holders.


  • Interest – An interest in a matter is where there is a reasonable likelihood of the person (or other parties as defined below) being affected by the decision, either directly, or indirectly. This may include both gain and loss to the person/ parties which would not have happened had the interest not existed.
  • Interests may be associated with, for example, employment, other appointments (including trusteeships, directorships, elected office), memberships (whether corporate or personal), investments, shareholdings, land and property, intellectual property, customer/client relationships, use of the LEP’s services or anything else which could (or could be perceived to) impact on the member’s ability to act fairly
    (independently, impartially, and in the public interest).
  • Relevant Parties – The following parties should be considered when assessing the potential effect of a member’s declared interest on any decision:
    • the member, the member’s family, including spouse or civil partner or any person living in the same household as the member;
    • a firm, business, or other organisation with which the member is connected.
  • Pecuniary Interest – An interest through which the member or Relevant Party stands to gain or lose financially.
  • Non-pecuniary Interest – An interest through which the member or Relevant Party stands to gain or lose in non-financial ways.
  • Conflict of Interest – A conflict of interest is a situation in which one cannot make a fair decision on a matter because one may be affected by the result due to competing interests or loyalties. Examples of conflicts of interest are included in Appendix B – Additional Guidance for Board Members.

Policy Statement

  • The Marches LEP Board (the Board) recognises the potential for actual or perceived conflicts of interest to arise throughout the conduct of its business.
  • The Board will support its members to conduct LEP business effectively, while minimising exposure to disadvantageous outcomes and criticism arising from such potential conflicts.
  • The Board further recognises and accepts that this requires the highest standards of conduct, integrity, accountability, transparency, openness, and probity at each stage of the LEP’s business.
  • The Board shall act impartially and in the public interest throughout the conduct of its business.
  • The Board will apply the standards and procedures set out in this document and any related local and national Assurance Framework provisions to address the circumstances in which actual or perceived conflicts of interest might arise.

Policy Provisions

  • The Board will establish and keep up to date a Register of Members’ Interests which shall be available to the public.
  • Members must declare any potential conflicts of interest at the start of the meeting and again when the relevant item is reached on the agenda, regardless of whether it is already included in the Register of Interests.
  • Declarations shall be recorded in the minutes of meetings.
  • Members may not participate in the discussion or determination of matters in which they have a pecuniary interest.
  • For non-pecuniary interests, the member must consider whether participation in the discussion or determination of a matter could cause a bias or be otherwise inappropriate.

The Register of Declarations of Interests

  • The Secretariat will maintain the Register of Interests for all members of the LEP Board and sub-boards, as well as any other constituted LEP groups which make decisions on behalf of, or makes recommendations to the Board.
  • Members must declare their interests for inclusion in the Register immediately upon joining a constituted LEP group.
  • The Register of Interests shall be available to the public.
  • Members must update their declarations as and when interests change and annually.
  • The LEP shall use the Register to monitor its compliance and the compliance of the individuals completing it with the LEP’s Conflicts of Interest Policy.

Managing Conflicts of Interest

  • Where pecuniary interests are identified, and declared, the member shall absent themselves from the meeting and take no part in discussions or decisions.
  • Where interests other than pecuniary interests are declared, the Chair is responsible for deciding whether the member should:
    • participate in the discussion of that matter;
    • remain in the room for the discussion of that matter;
    • be counted in the quorum for that part of the meeting.
  • Where decisions or recommendations are made by written procedure, any member with a conflict of interest must immediately notify the Chair and take no part in the voting.
  • The Secretariat shall minute all such declarations and associated proceedings.

Code of Conduct

  • A Board Member or member of staff shall not use their position directly or indirectly, for personal gain. Additionally, they must:
    • Support the aims and objectives of the LEP and promote the interests of the
    • LEP within their local and business community.
    • Base their views on matters before the Board on an honest, reasonable, and defensible assessment of the available facts.
    • Cooperate with other members and officers in the best interests of the LEP and the public.
    • Support equal opportunities in the work of the LEP and make provision for it within the Strategic Economic Plan.
    • Acknowledge that they have no authority outside meetings of the LEP Board and its groups and committees.
    • Act honestly, diligently and in good faith, noting that to do so may require taking professional advice.
    • Resist any temptation or outside pressure to use the position of Board Member to benefit themselves or other individuals or agencies.
    • Not accept offers of money, gifts, or hospitality, or anything else that could be construed as an inducement or reward for any action or position adopted whilst serving as a member of the Board.
    • Acknowledge that differences of opinion may arise in discussion but once the Board has decided, to support implementation of the decision.
    • Understand that members do not have the right to make statements or express opinions on behalf of the Board unless specifically authorised to do so.
    • Respect the confidentiality of items of business which the Board decides should remain confidential (where permitted by law).
    • Honour the obligations on all members not to reveal to third parties the views expressed at meetings.
    • Have regard to the broader responsibilities as a Board including the need to promote public accountability for the actions and performance of the Board.
    • Take or seek opportunities to enhance their effectiveness as a member through participation in training and development programmes and by increasing their knowledge of the Marches economy and the LEP.
    • Give priority, as far as practicable, to attendance at meetings of the Board and its meetings and its committees or groups.
  • Any Board Member who has or has had an interest in a company liquidation, receivership, or administration of a company, or who has been summonsed or convicted of a criminal charge, or who has been involved in any activity which might undermine public confidence in the LEP shall immediately inform the Chair and LEP
    Chief Executive.
  • Any Board Member who becomes bankrupt or makes arrangements with their creditors related to bankruptcy shall inform the Chair and the LEP Chief Executive.
  • Within 5 working days of receipt, any Board Member shall notify the LEP Team in writing of any gift, benefit or hospitality with a value equal to or more than £50 which they have accepted as a member of the Board, from any person or body. The LEP Team will record such notification on a public register of gifts and hospitality.


  • The Board shall keep under review the provisions set out in its Accountability and Assurance Framework (AAF), including this document.
  • The Board will discuss and propose changes to the AAF as and when deemed necessary, and formally at least once a year.
  • The Board will keep their private sector representation under review, in accordance with the Terms of Reference for the LEP Board and those of each of its sub-groups

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