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Information related to the Civil service conflicts of interest register.

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First published:
11 May 2022
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9 May 2022



ATISN 16233

Thank you for your request which I received on 6 April 2022.  You asked for information in the following areas covering the years 2017-2021:

  1. The number of senior civil servants in the Welsh Government employed by another company/body whilst in the employment of the civil service;
  2. A list of the names of the companies/bodies who employed these staff;
  3. The number of violations of civil service conflict of interest regulations in relation to such employments’ (either Civil Service Code violations or breaches of departmental rules on conflict of interest) by senior civil servants in the Welsh Government that were recorded; and
  4. The register of conflicts of interest in the Welsh Government for senior civil servants as of 1st January in each of these years.

I have set out at Annex 1, the information you requested in relation to parts 1-3 of your request.

In relation to part 4, some of the information you have requested is already in the public domain and accessible via the Welsh Government website as detailed below:

Civil service conflicts of interest register – this is a list of Welsh Government employees and their membership of external boards, whether in a private or official capacity (paid or unpaid). This register includes employees of all grades though the majority will be senior civil servants (SCS). For the purpose of this register, an ‘external board’ is defined as an outside board or committee that has a statutory remit, i.e. public bodies, or which are formally registered, such as a charity or company. It does not include social / leisure organisations such as hobbies or interest groups or membership of school governing bodies or other bodies which do not have the capacity to influence Welsh Government policy.

Senior officials: register of interests - to fulfill its obligations under section 6.4.3(e) of the Government Financial Reporting Manual, the Welsh Government has also published details of the declared interests of senior officials who have served on the Welsh Government’s Board and Executive Committees in the 2020/21 financial year (both executive and non-executive members).

An update of both the Civil service conflicts of interest register and the Senior officials: register of interests is scheduled and the latest information will be made available in due course.

I have therefore concluded that SCS declarations in the areas above which have not yet been published are exempt from disclosure under Section 22 of the Freedom of Information Act (2000) - information intended for future publication. I have also concluded that details of SCS declarations recorded internally but not intended for publication on either of the external registers are exempt under Section 40(2) of the Freedom of Information Act (2000).

My full reasoning for applying both these exemptions is given at Annex 2 of this letter.

If you are dissatisfied with the Welsh Government’s handling of your request, you can ask for an internal review within 40 working days of the date of this response. Requests for an internal review should be addressed to the Welsh Government’s Freedom of Information Officer at:

Information Rights Unit 
Welsh Government
Cathays Park 
CF10 3NQ 

or e-mail:

Please remember to quote the ATISN reference number above.   

You also have the right to complain to the Information Commissioner. The Information Commissioner can be contacted at: 

Information Commissioner’s Office 
Wycliffe House 
Water Lane 

Telephone: 0303 123 1113

However, please note that the Commissioner will not normally investigate a complaint until it has been through our own internal review process.

Yours sincerely