One form for nil and positive returns
A tick for nothing to declare, or one block per interest with the four types named. The nil return is signed and kept, because a register with gaps is not a register.
Conflict of interest declaration form
The form a conflict of interest policy runs on, printed here rather than hidden behind a download. One form for a nil return and for any number of interests, with the section where the decision is recorded and the fields that feed the register of interests.
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What this template covers
The authorizer's section
The person who assesses the declaration writes the outcome, the conditions and the review date on the same form, so the decision is recorded with the declaration and not in an email beside it.
The fields that feed the register
Type, description, dates, value, outcome, conditions, reference number and review date: every field the register of interests needs, in the order it needs them.
Conflict of interest declaration
1. How to use this form
Complete this form if you have an interest that conflicts, or might conflict, with your work for [Organization], and once a year if you are in a decision-making role, whether or not you have anything to declare. Complete it at the earliest opportunity and in any event within 28 days of the interest arising, of a change to an interest already declared, of joining, or of moving into a decision-making role.
Send it to your line manager, who completes section 6, and to [the compliance lead], who enters it in the register of interests and tells you the outcome. Directors send theirs to the chair and the company secretary. If you are not sure whether something is an interest, declare it and let the assessment decide.
2. About you
- Name
- Your full name as it appears in HR records.
- Role
- Your job title and, for a director or trustee, the board or committee you sit on.
- Team or department
- The part of the organization you work in.
- Line manager
- The person who will complete section 6. For a director, the chair.
- Where the outcome of the assessment will be sent.
- Date
- The date you complete the form. The 28 days run from when the interest arose, not from this date.
3. Your declaration
Tick the nil return if you have nothing to declare, then go to section 4. Otherwise complete one block for each interest.
- Nil return
- I have no interests to declare. Tick only if there is nothing in any of the four types below, including those held by people connected to you.
- Type of interest
- One of: financial (you or a connected person could gain or lose money); non-financial professional (your career, reputation or standing could benefit); non-financial personal (a personal commitment that could shape your judgment); indirect (a relative, partner, friend or business associate holds one of the above).
- Description of the interest
- What the interest is, naming the company, body or individual involved. The name lets the register be searched when a contract or panel comes up.
- How it relates to your role
- The decisions, contracts, people or information in your work that the interest could touch. If you cannot think of one, say so.
- Dates from and to
- When the interest began and, if it has ended or will end, when. Leave the end date open for a continuing interest.
- Value or shareholding, where relevant
- The approximate value, the percentage held or the fee received. Required for financial interests, including indirect ones.
4. Gifts and hospitality received or offered in the last 12 months
List anything received, or offered and declined, from a supplier, a bidder, a client or anyone you make decisions about, above the threshold in the gifts and hospitality policy. Write none if there is nothing to list.
- Item
- The gift, meal, tickets, sponsored place or travel.
- From whom
- The organization and, where known, the individual, and your relationship with them.
- Estimated value
- Your best estimate in [pounds sterling]. If you do not know, say what it was and the assessor will estimate.
- Date
- When it was received or offered.
- Accepted or declined
- Which, and if accepted, whether it was entered in the gifts register at the time and under what reference.
5. Your confirmation
- Statement
- I confirm that this declaration is complete and accurate to the best of my knowledge, that I have read the conflict of interest policy, and that I will submit a new declaration within 28 days of any change to the interests declared here or of any new interest arising.
- Signature
- Your signature, or your typed name where the form is submitted electronically.
- Date
- The date you sign.
6. For the authorizer
Completed by the line manager, or by the chair or board for a director, within [10 working days]. The authorizer must not share the interest declared.
- Assessment
- One of: no conflict; potential conflict; actual conflict. A perceived conflict is assessed as potential. For a nil return, record no conflict.
- Management action
- One of the four outcomes in the policy: no action; record and monitor; exclude from the decision; remove the interest. Name the decision, contract or process an exclusion applies to.
- Conditions
- What the person must do or must not do while the interest continues, in plain words they can be held to. Write none if there are no conditions.
- Register entry reference
- The reference number [the compliance lead] gives this declaration in the register of interests, written on the form so the two can always be matched.
- Authorizer name and role
- Who made the assessment, by name.
- Authorizer signature and date
- The date the assessment was made, which is the date the conditions apply from.
- Review date
- When the entry will next be looked at: the next annual return for no action, or a date within [12 months] for the other outcomes.
7. Data protection
The information on this form is held in the register of interests by [the compliance lead] and used to assess and manage conflicts of interest under the conflict of interest policy. It can be seen by your line manager, [the compliance lead], the board and audit committee, the organization's auditors and any regulator entitled to see it. You can see your own entries. It is kept for [three years] after the interest ends, or [six years] for directors and senior managers, and then deleted, unless we must keep it longer because of a legal hold, legal proceedings or another legal requirement. Board minutes recording a director's declaration are kept for at least ten years under section 248 of the Companies Act 2006. Access to the register is logged.
We process this information on [a lawful basis under Article 6 of the UK GDPR, for example legitimate interests or a legal obligation]. Give only the detail needed to assess the interest. Keep information about relatives, partners and other connected people to a minimum, and do not include special category data (such as health, religious beliefs, political opinions or trade union membership) unless the interest cannot be described without it. Where special category data is included, we process it under [a condition in Schedule 1 to the Data Protection Act 2018]. Our [privacy notice] explains your rights and how to exercise them. [Confirm the lawful basis and condition with your data protection officer.]
A starting point to adapt to your organization, not legal advice.
From a signed form to a managed conflict
The form is the first page of a process. These six steps take a declaration from the person who signs it to a register entry with a decision against it.
Book a demoIssue the form with the policy
Send the form, the policy and the date it is due in the same message, to each person by name. The 28-day rule starts when the interest arises, so the annual return date is the one you set. Ask for nil returns as plainly as positive ones.
Give every form a reference on arrival
The compliance lead logs each form in the register the day it arrives, with a reference number, before it is assessed. A form that is logged cannot be lost in a manager's inbox, and the register shows what is waiting for a decision.
Route it to an assessor who does not share the interest
The line manager assesses declarations from the people they manage. Where the manager is named in one, or has the same interest, it goes one level up or to the compliance lead. For a director, the board or its committee decides, with the interested director out of the room.
Decide within ten working days and write it down
Assessment, outcome, conditions, review date, name and signature, in section 6 of the form and then in the register. An outcome that lives in a conversation does not survive a change of manager.
Tell the person and act on the conditions
The person who declared is told what was decided and what it means for them. If the outcome is an exclusion, the panel, the approval chain or the meeting papers change the same week, and the minute records why.
Review on the date, not when someone remembers
Every entry has a review date. The compliance lead checks the register each quarter for entries past theirs, asks the person whether anything has changed, and records the answer. The annual return then confirms what the reviews found.
Conflict of interest declaration FAQ
What is a conflict of interest declaration form?
The form on which a person tells their organization about an interest that conflicts, or might conflict, with their work, or confirms that they have none. It records who the person is, what the interest is, how it relates to their role, its dates and value, and any gifts or hospitality received. The authorizer's section records how the declaration was assessed, what action was chosen and the reference under which it was entered in the register of interests. The form, the policy and the register are one system, and this form is designed to feed the other two.
What counts as an interest to declare?
Anything that could gain or lose you money, advance your career or standing, or shape your judgment, and anything of that kind held by a relative, partner, friend or business associate. The four types on this form, financial, non-financial professional, non-financial personal and indirect, follow NHS England's guidance on managing conflicts of interest, and its categories give practical examples: outside employment, shareholdings and other ownership, patents, loyalty interests, donations, sponsored events, research or posts, private practice, gifts and hospitality. If you are not sure, declare it and let the assessment decide.
Do I need to declare if I have no conflicts?
If you are in a decision-making role, yes. Tick the nil return in section 3, complete the gifts section and sign section 5, once a year and on joining or changing role. NHS England's guidance requires decision-making staff to submit an annual declaration even if there are no interests to declare, and this form follows it, because a register that only holds positive declarations cannot show who was asked. If you are not in a decision-making role you complete the form only when an interest arises.
Who sees my declaration?
Your line manager, who assesses it; the compliance lead, who enters it in the register; and the board, audit committee, auditors and any regulator entitled to inspect the register. You can see your own entries. Colleagues cannot. Under this template the register is held securely, access to it is logged, and entries are kept for the periods the organization sets (by default three years after the interest ends, or six years for directors and senior managers) and then deleted, unless a legal hold or another legal requirement means they must be kept longer. Section 7 of the form states this so the person signing knows before they sign.
What happens after I submit the form?
The compliance lead gives it a reference number and enters it in the register. Your line manager, or the board for a director, assesses it within ten working days and chooses one of four outcomes: no action, record and monitor, exclude from the decision, or remove the interest. The outcome, any conditions and a review date are written in section 6 and in the register, and you are told what was decided. You then submit a new form within 28 days if anything changes.
See the document become a process