Ministers' interests management

Ministerial Conflicts of Interest

Cabinet Office processes

Information on the management of ministerial conflicts of interest is set out at paragraphs 2.59-2.83 of the Cabinet Manual 2023: Conduct, public duty, and personal interests: Ministers' interests. The Cabinet Office processes for supporting Ministers in identifying and managing conflicts of interest are set out in paragraph 2.61 of the Cabinet Manual. The following information provides more detail about the processes followed by the Cabinet Office in accordance with the Cabinet Manual.

Following appointment of Ministers

Following the appointment of a new administration, the Cabinet Office arranges an induction programme for new Ministers. That includes a session on the identification and management of conflicts of interest.

The Cabinet Office contacts all Ministers following their appointment and provides them with a worksheet containing questions and guidance designed to prompt their thinking about a broad range of interests and possible areas of conflict, financial and non-financial. The Cabinet Office then meets each Minister for a confidential discussion about their worksheet and any issues that may arise.

Following that meeting we draw up a register of each Minister’s interests and record any recommended management actions in accordance with paragraph 2.76 of the Cabinet Manual. We then report to the Prime Minister and obtain the Prime Minister’s agreement to the proposed management plans.

Each Minister nominates a designated person in their office to support them with conflict of interest processes. That person attends meetings between the Minister and the Cabinet Office.

In most offices, the designate is the Senior Private Secretary or a senior ministerial advisor. The Cabinet Office participates in induction sessions for new Senior Private Secretaries in Ministers’ offices, including providing information about the identification and management of conflicts of interest.

Regular reviews of interests

Each year following the publication of the Register of Pecuniary and Other Specified Interests of Members of Parliament, the Cabinet Office writes to all Ministers to remind them to review their interests in the light of their portfolio or other ministerial responsibilities, to consider any possible conflict issues, and to seek advice where necessary. We then arrange to meet with each Minister in person to go through their existing register and the worksheet, to identify any new matters that have arisen and any other changes that need to be made.

At the end of the annual review process, the Cabinet Office reports to the Prime Minister, providing the full register of Ministers’ interests, and identifying any that are of particular significance. That advice will also seek the Prime Minister’s agreement to new transfers of responsibility, if those are required to manage a particular interest.

Commencing in 2024, the Cabinet Office conducts the review process with Ministers in person every six months.

Advice as matters arise

As well as these twice-yearly full reviews, the Cabinet Office provides guidance throughout the year on any conflict of interest issues that may arise. These may be matters raised proactively by a Minister, brought to our attention by an agency, or identified by us as posing a possible issue and raised for the Minister’s consideration. The Cabinet Office seeks the Prime Minister’s agreement to any particular management actions that result, as required.

Declarations at Cabinet and Cabinet Committee meetings

The Cabinet Office provides Ministers with advice and assistance in making declarations of their interests at any Cabinet or Cabinet Committee meeting where issues which relate to those interests may be discussed. The Cabinet Office keeps a record of declarations made by Ministers at those meetings.

Confidentiality of details of Ministers’ interests

The completion of each Minister’s individual register of interests is a confidential process (see para 2.61(b) of the Cabinet Manual). The Cabinet Office advises Ministers of this when meeting with them, and encourages them to share information freely and to err on the side of disclosure in their discussions with us.

Ministers’ individual registers may often include declarations of interests that never in fact create a real or perceived conflict. On the other hand, there may be interests that Ministers do not include on their register until a particular decision arises, and they realise that they have a conflict (for example, an appointment decision involving a close friend, who they have not expected to be considered for a government appointment). In that sense their registers are dynamic – they can be updated as new matters arise, or as the listed interests change.

Proactive release of information about management of ministerial conflicts of interest

Since 2012, the Cabinet Office has proactively released certain information about the management of Ministers’ interests once a year. That proactive release was the result of an agreement between the then Prime Minister and former Chief Ombudsman. The information released covers transfers of responsibility and arrangements not to receive papers.

The releases are intended to provide public assurance that systems are in place to manage conflicts of interest effectively, while protecting the privacy of individuals, the confidentiality of Cabinet discussions, and the confidentiality of correspondence between the Cabinet Office and the Prime Minister and other Ministers about actual or potential conflicts of interest. Some information is redacted, usually on the grounds of privacy (particularly where family members are involved). These releases can be found below.

The annual release usually occurs in the last quarter of each calendar year. Following the change of government in 2023 and the appointment of new Ministers, we published an additional release disclosing information for the period 27 November 2023 to 30 April 2024. This practice will continue by making an additional release within six months of the appointment of a new government.

The Prime Minister has agreed that the Cabinet Office should move to a six-monthly proactive release, in the interests of transparency. We will implement that arrangement from the 2024 year on, for the period ending 31 December, and expect to publish by the end of March and then again by the end of September.

Previous proactive releases are available below: