Guidance

Conflict of Interest Policy

Updated 13 October 2025

Applies to England

Purpose

This document sets out the organisation’s approach to perceived, potential and actual conflicts of interest.

Applies to

• All employees, including Non-Executive Directors
• All contractors working for the organisation including, but not limited to, those contracted directly, those providing Planning Appeal Decision Services (formerly called Non-Salaried Inspectors) and through agencies and strategic suppliers.

Main supporting information

• For employees: Civil Service Code
• For those involved in procurement and contracting activities: Procurement Policy Note 04/21: Applying Exclusions in Public Procurement, Managing Conflicts of Interest and Whistleblowing
• For non-executive directors: Code of conduct for board members of public bodies

1. Policy principles

1.1 The Planning Inspectorate expects anyone employed, engaged by or working on its behalf to conduct themselves in accordance with, and exhibit, the Civil Service Code and the Seven Nolan Principles of Public Life:

• Integrity
• Selflessness
• Objectivity
• Accountability
• Openness
• Honesty
• Leadership

1.2 The Franks Principles for Administrative Tribunal and Enquiries also overarch the way we manage our casework and now form the core organisational values by which all those employed, engaged by, or working on behalf of the organisation are expected to behave.

The Franks Principles are:

• Openness
• Fairness
• Impartiality

1.3 Those who work for, or on behalf of, the Planning Inspectorate must not put themselves in a position where previous or current employment, or personal relationships or private interests conflict, or could be perceived to conflict, with these principles. The Planning Inspectorate’s approach to all potential conflicts of interest, whether actual or perceived, is to:

• Always disclose at the earliest opportunity
• Agree arrangements to manage the conflict
• Prohibit activity where necessary

1.4 With effective management of interests, employees/contractors with declared interests should be able to conduct their work without restriction, particularly when they use their time and talents for the benefit of the community.

1.5 A conflict, whether actual or perceived, that is not managed effectively can severely jeopardise individual reputation as well as the Planning Inspectorate’s public standing and the trust in our decisions and recommendations.

1.6 Everyone in scope of this Policy must, therefore, uphold their obligation to declare any potential conflict of interest immediately and adhere to any conditions or measures put in place to manage it.

1.7 Potential conflicts of interest must be recorded.

2. Policy summary

2.1 There are three general areas of conflict:

• Financial conflicts, including professional activity outside the Planning Inspectorate
• Conflicts with the Planning Inspectorate’s values
• Conflicts in our casework

2.2 These conflicts can also arise from interests of household members, friends, colleagues, and anyone with whom there was/is an association.

2.3 All potential conflicts must be assessed to determine whether they can proceed alongside work for the Planning Inspectorate without affecting the integrity and reputation of the Planning Inspectorate, the individual, and the decision-making process.

2.4 Measures or conditions may be implemented to minimise and manage any conflict. Failure to declare potential conflicts of interest will be investigated and managed, with sanctions up to and including terminating any contract. This applies whether the failure was intentional or unintentional and where actions continue contrary to the established conditions and/or measures.

3. Our approach to potential conflicts of interest

3.1 All potential conflicts of interest, whether actual or perceived, must be disclosed immediately and updated on a regular basis. Anyone in doubt or requiring further advice must speak to their line manager and comply with this Policy before undertaking any activity that could be impacted by the potential conflict of interest.

3.2 New potential conflicts of interest can occur at any point. Employees and contractors must be alert to this and disclose changes in circumstances and new potential conflicts of interest immediately.

3.3 Contracts with third party suppliers must identify explicitly how conflicts of interests shall be declared, considered and managed. Employees and contractors must apply the recommended government framework for managing conflicts of interests related to procurements and commercial activity (including contract management).

3.4 Any activity that may contravene this Policy is a potential conflict of interest and must be declared.

3.5 Employees and contractors with declared potential conflicts of interest are often able to conduct their work without restriction. The purpose of this Policy is to ensure that all actual or perceived conflicts are declared in good time to enable the Planning Inspectorate to consider them. This helps to protect both the individual and the organisation.

3.6 For ease of reference, possible conflicts of interest and potential conflicts of interest that must be declared are included in this Policy from paragraph 4.4 onwards. The list is not exhaustive. Employees and contractors are expected to apply good judgement in assessing whether any other activity may also represent an actual or perceived conflict of interest. Each situation should be considered individually.

3.7 All declared potential conflicts of interest should be reviewed when there is a material change in circumstances, and at least annually.

3.8 If a conflict of interest cannot be managed, the employee/contractor should be asked to stop the interest. Where this is not possible and the employee/contractor intends to continue with the interest, the Planning Inspectorate may take steps up to and including terminating any contract. Each situation will be dealt with on a case by case basis.

3.9 Recording conflicts and potential conflicts of interest may involve personal data. We manage that data in accordance with our Employee Privacy Notice. Access to the data is, therefore, controlled.

4. What is a conflict of interest?

4.1 A conflict of interest arises where an employee or contractor, their household members, close friends or colleagues has a private interest that might influence, or be reasonably perceived to influence, their judgement in carrying out their duties.

4.2 It is important that employees and contractors are also aware of the perspective of others. Any interests that could be perceived to give an appearance of bias or where misuse of position could reasonably be inferred must also be declared.

4.3 In the Planning Inspectorate, conflicts of interest are grouped by, but not limited to, three types as identified in paragraph 2.1. More detail on each type of conflict is provided below.

Financial conflicts including professional activity outside of the Planning Inspectorate

4.4 A financial conflict is a personal monetary interest or financial interest of close associates, colleagues, household members or friends that may be affected by the Planning Inspectorate’s work. All such conflicts, including those at risk of being perceived to be so, must be declared.

4.5 Those involved in the procurement, evaluation, selection and management of commercial contracts with third party suppliers must be particularly careful to ensure that they are not influenced, nor could be perceived to be influenced, by an association with any of those contracting with the Planning Inspectorate.

4.6 Separate to this Conflict of Interest Policy, employees must also follow the organisation’s approach to declaring (and normally declining) gifts and hospitality.

4.7 Examples of potential financial conflicts of interest including professional activity (including of household members and close friends) which must be declared include:

• Any financial interest in an applicant, appellant or interested party or a competitor to an applicant, appellant or interested party, which submits casework or comments to the Planning Inspectorate.
• Any financial interest in an organisation with which the Planning Inspectorate contracts or any financial interest in an organisation that competes with an organisation with which the Planning Inspectorate contracts (including private shareholdings).
• Any employment or volunteer work, paid or unpaid, including leadership roles in charities, professional bodies and trusts.
• Previous, present or future paid employment or consultancy work, including goods and services to applicants, appellants or interested parties.
• Paid and unpaid engagements, academic papers, advisory work or journalism in any medium, including written or spoken, outside work for the Planning Inspectorate.
• Membership of local or national regulatory or professional bodies or advisory committees.
• Public service appointments, for example a Magistrate or Special Constable.
• Editing and/or publishing books, articles or letters in newspapers, magazines or on the internet including personal views or memoirs.
• Participation in any interviews or broadcasts (including online broadcasts and blogs) outside the work of the Planning Inspectorate.
• Undertaking lecturing teaching, tutoring or training, paid or unpaid.
• Sharing information you become aware of for financial (or other) gain. This could also be ‘insider dealing’, which is itself a serious criminal offence.

Conflicts with the Planning Inspectorate’s values

4.8 Employees and contractors must always act in a way that is consistent with the Planning Inspectorate’s values:

• Openness
• Fairness
• Impartiality
• Customer focused

4.9 Examples of potential conflicts of interest with the Planning Inspectorate’s values (including of household members and close friends) which must be declared where a perceived bias or conflict of interest could result include:

• Membership of political or pressure groups, including the online presence of these groups.
• Membership of a society or other group.
• A strongly held view or personal belief.
• Standing for, or holding, elected office (this will not normally be agreed)
• Canvassing on behalf of a political party or on behalf of a candidate for election (this will not normally be agreed)
• Any personal workplace relationship, such as romantic involvement or family relationship, between Planning Inspectorate employees, suppliers or contractors.
• Acting as an agent in any planning or related casework, irrespective of whether it is before the Planning Inspectorate.
• Contributing or taking part in any Planning Inspectorate casework in a personal (non-work) capacity.

Conflicts in our casework

4.10 Employees and contractors should not work on activities where past, present or future employment, engagement, allegiance, relationship or location suggests an actual or perceived bias or any personal benefit.

4.11 A potential conflict of interest could arise directly from a case (for example, permission being granted by an appeal). The potential conflict of interest could also arise indirectly (for example, a development proceeding (or not proceeding) on one site/in one area, making it materially less (or materially more) likely that development will proceed on another site/in another area).

4.12 Examples of potential conflicts of interest in our casework (including of household members and close friends), which must be declared, include:

• Previous employment, contracting, consulting, advising or volunteering with local planning authorities, appellants, applicants, statutory undertakers and other parties which submits casework or comments to the Planning Inspectorate.
• Previous employment, contracting, consulting, advising or volunteering with competitors of local planning authorities, appellants, applicants, statutory undertakers and other parties which submits casework or comments to the Planning Inspectorate, or indirect beneficiaries.
• Living near, or owning property near, a site where you are working on a case.
• Living near, or owning property near, a site which could be materially more or less likely to be developed because of a case on which you are working.

People Policy Development

We are committed to creating inclusive policies that support equality and diversity at the Planning Inspectorate.