Conflicts of Interest and Executive Pay

Register of interests

The Academy Trust Handbook 2023 details that an academy trust’s register of interests must capture relevant business and pecuniary interests of members, trustees, local governors of academies within a
MAT and senior employees, including:

• directorships, partnerships and employments with businesses
• trusteeships and governorships at other educational institutions and charities
• for each interest: the name and nature of the business, the nature of the interest and the date the interest began

The register must identify relevant material interests from close family relationships between the  academy trust’s members, trustees or local governors. It must also identify relevant material interests arising from close family relationships between those individuals and employees. ‘Close family relationships’ is defined in section 5.48 (third bullet).

Trusts should consider whether other interests should be registered. Boards of trustees should keep their register of interests up-to-date at all times.

Trusts must publish on their websites relevant business and pecuniary interests of members, trustees, local governors and accounting officers. Trusts have discretion over the publication of interests of other individual named on the register. The Charity Commission offers guidance in Manage a conflict of interest in your charity.

Board of Directors (updated September 2023)

Business 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. For example, if a Governor runs their own building company or provides training courses for teaching staff.
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.

All members of the Governing Board, the Principal and senior/ staff who influence financial decisions, are expected to declare any business interests that they or any family member may have. . A register of the business interests should be  made available in the school and there should be an annual review of this register. In addition, where a Governor or member of staff has no business interests, they should complete a form saying ‘No interests to declare’. New Governors or members  of staff, influencing financial decisions, should be asked to complete a form on joining the Governing Board or school.

Pecuniary Interests
It is a common misconception that pecuniary interests are the same as business interests; however, pecuniary interest is a wider term. Pecuniary interests include personal financial interests, such as involvement in a trust fund or investment, as well as potential interests, for example, where a member of staff’s husband is applying for a vacancy in the school or where a Staff Governor is involved in the decision over the promotion of a colleague, and where they may be a potential candidate for the post made available.

Because of the nature of these interests, they cannot only be declared annually. All members of the Governing Board and all members of staff should be made aware at Governor and staff meetings of the need to declare these interests, as they arise. Declarations should be made in writing to the Principal or the Chair of the Board or Academy Committee where appropriate; these should be filed in a register of pecuniary interests. 

Publication of executive pay

Under the Academies Trust Handbook (2022, Sec 2.32), the MAC must publish on its website the number of employees whose benefits exceeded £100k, in £10k bandings, for the previous year ended 31 August. Benefits for this purpose include salary, employers’ pension contributions, other taxable benefits and termination payments.

For September 2022 to August 2023 the bandings and number of employees in each band are:

• £100,001 – £110,000      2
• £120,00   1 – £130,000   1
• £140,00   1 – £150,000   1

Note that prior to 21/22 Trusts/MACS were required to report excluding employer’s pension contributions.

Shared Services Team