Declarations of Interests and Gifts & Hospitality
Expectations:
Part D of the Financial Manual of Guidance states the requirement for schools to set up and maintain a register of financial interests that includes returns from governors, the headteacher, and other school staff involved in financial management. There is no prescribed form for the register to take, but it must be updated annually and when new members of staff join the school.
Audit:
An internal audit was conducted by the Council’s Audit Team late last year. The audit tested whether a sample of 17 schools complied with this requirement by requesting a copy of their most up to date register of interests in September 2024. The Schools Financial Value Standard (SFVS) returns for 2023/24 (submitted in February 2024) were also obtained for the schools sampled. All had answered question 4 – ‘Are business interests of governing body members and staff properly registered and taken into account as to avoid conflicts of interest?’ – as ‘Yes’.
13 of the 17 schools (76%) were able to evidence registers that contained declarations from governors, the headteacher, and other staff members involved in financial decision-making. Of the remaining schools, one only held a register for staff (not governors), one only held a register for governors (not staff), and two were unable to provide any form of register. Of the registers provided, 4 schools (24%) provided registers that had not been updated in the last two years. Additionally, 2 schools provided registers that were dated after the request was sent by Internal Audit. This means that the possibility that the schools did not hold a register prior to the audit cannot be ruled out. Some registers provided were not dated or did not contain an appropriate level of detail about the interest (e.g. the name of the relevant business).
The Financial Manual of Guidance does not mandate that a school’s register must take a prescribed format, however, a lack of relevant information in the register may indicate that conflicts are not fully understood or that declarations are not being reviewed annually. It was also found that within their SVFS returns, 4 of the schools sampled had declared Related Party Transactions (RPTs). These are transactions where a related party, such as the family member of a governor or staff member, has been paid for goods or services provided to the school. One school declared as RPTs that the spouse of the School Business Manager had been paid £16,800 for services in 2023/24. However, the declaration of the School Business Manager, dated after the request was sent by Internal Audit in September 2024, was a nil return.
Risk:
If a number of schools are not appropriately declaring and monitoring interests in accordance with the requirements of the guidance, then this increases the risk of conflicts being undetected or inappropriately managed.
Actions:
We would be very grateful if this matter could be highlighted with schools, whether though the Headteachers Executive Group or other forum/publicity (for example School News etc). We need to ensure that schools have an appropriate registration process in place to enable colleagues to make declarations for both interests and gifts & Hospitality. We’ve attached a copy of the registers and declaration forms that we use in the Council, for reference.