Gifts

Summary

The requester sought policies, training materials, and records of gifts declared by teachers from students and families for the 2021/22 to 2023/24 financial years. The Department of Education, Sport and Culture provided a partial response including a specific register of accepted gifts and a conflict of interest procedure document, while noting that some information was exempt.

Key Facts

• The request covered policies, manuals, training materials, and gift declaration records for teachers.
• The outcome was 'Some information sent but part exempt'.
• A register of gifts and rewards was disclosed, listing items accepted by various schools.
• The disclosed policy document is titled 'PSG Division Declarations of Conflict of Interests and Gifts/Rewards V1.0 March 2023'.
• Gifts listed include vouchers, wine, chocolate, and an office chair, with values ranging from £23 to £169.

Data Disclosed

• 2024-09-24
• 2024-10-21
• 2021/22
• 2022/23
• 2023/24
• 19 pages
• 4 documents
• £50.00
• £23
• £55
• £35 - 40
• £120
• £40
• £30
• £25
• £45
• £100
• £169
• 01/07/2022
• 19/07/2022
• 21/07/2022
• 22/07/2022
• 18/07/2022
• 06/09/2022
• 12/12/2022
• 21/12/2022
• 22/12/2022
• 14/12/2022
• March 2023

Original Request

I am seeking records related to the policies, procedures, manuals, and training presentations provided to teachers regarding the declaration of gifts from students and student families. Specifically, I request: 1. Any and all policies or procedures regarding the declaration of gifts given to teachers by students or their families. 2. Any internal manuals or guidelines that outline the appropriate actions to be taken by teachers when offered or receiving gifts from students or their families. 3. Any training materials, including presentations, handouts, or guides, that have been used to train teachers on the proper handling of gifts from students or their families. 4. Any records of gifts declared by teachers in the 2021/22 financial year, 2022/23 financial year and 2023/24 financial year. For points 1 to 3, I would appreciate if these documents cover the most recent versions as well as any historic versions of these records that date back over the past five years, if available. If the Department holds records which are similar in nature, but not identical, to the description above, then I am happy to amend this request to reduce the time taken by staff to process this request. If this is the case, please contact me to discuss.

Data Tables (15)

Full Response Text

Area/Division Date of Offer Description of Offer Est./actual value of offer £ Details of contracts, commercial interests or potential conflicts of interests. Action taken i.e. Accepted / Refused / Returned Ballasalla School 01/07/2022 Voucher £50.00 None Accepted Ballasalla School 01/07/2022 Voucher £50.00 None Accepted Ballacottier School 19/07/2022 Vouchers £23 and £55 Teacher / Parents Accepted Ballacottier School 21/07/2022 Vouchers £23 and £55 Teacher / Parents Accepted Ballacottier School 21/07/2022 A gift bag from M&S Estimated value £35 - 40 Teacher / Parent Accepted Cronk y Berry School 18/07/2022 Voucher, wine, chocolate £120 Accepted Cronk y Berry School 22/07/2022 Voucher £50 Accepted Cronk y Berry School 22/07/2022 Voucher £40 Accepted Cronk y Berry School 22/07/2022 Voucher £30 Accepted Cronk y Berry School 22/07/2022 Voucher £25 Accepted Cronk y Berry School 22/07/2022 Voucher £45 Accepted Cronk y Berry School 22/07/2022 Voucher £25 Accepted Cronk y Berry School 22/07/2022 Voucher £25 Accepted Cronk y Berry School 22/07/2022 Voucher £25 Accepted Cronk y Berry School 06/09/2022 Offfice Chair £50 Accepted Cronk y Berry School 12/12/2022 Voucher £50 Accepted Cronk y Berry School 21/12/2022 Voucher £30 Accepted Scoil Vallajeelt 22/12/2022 Voucher £100 Accepted Scoil Vallajeelt 20/07/2022 Voucher £100 Accepted Scoil Vallajeelt 20/07/2022 Voucher £100 Accepted Scoil Vallajeelt 21/07/2022 Voucher £40 Accepted Scoil Vallajeelt 22/07/2022 Voucher £169 Accepted Scoil Vallajeelt 22/07/2022 Voucher £169 Accepted Onchan School 14/12/2022 Voucher £45 Accepted <> Register of Gifts & Rewards

PSG Division Declarations of Conflict of Interests and Gifts/Rewards V1.0 March 2023

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C: \ Users \ gtsshur \ Documents \ OCSIA - CCIA \ Information Management Forum \

Department of Education, Sport and Culture

Declarations of Conflict of Interests and Gifts/Rewards

March 2023

PSG Division Declarations of Conflict of Interests and Gifts/Rewards V1.0 March 2023

1 Contents

Summary ..................................................................................................................... 2 About this procedure .................................................................................................. 2 Who is this document for? .......................................................................................... 2 Key points ................................................................................................................. 2 Effective Date ............................................................................................................ 2 Procedure for Declarations of Conflicts of Interests and Gifts/Rewards............................... 3 Purpose .................................................................................................................... 3 Roles and Responsibilities ........................................................................................... 4 Conflict of Interest ..................................................................................................... 4 Declaration of Interest ............................................................................................... 5 Gifts and Rewards...................................................................................................... 6 Appendix 1 ................................................................................................................ 7 Appendix 2 ................................................................................................................ 9 Associated Resources ................................................................................................... 10 Version Control ............................................................................................................ 11 Review Date ................................................................................................................ 11

PSG Division Declarations of Conflict of Interests and Gifts/Rewards V1.0 March 2023

2 Summary

About this procedure

This document describes the action to be taken by the Department of Education, Sport and Culture in order to fulfil its’ duties under the Isle of Man Government Financial Regulations, the Isle of Man Government Code and the Isle of Man Government Civil Service Code.

Who is this document for?

The information contained in this document applies to all staff including the Minister for Education and the Department’s political members.

Key points

All officers of the Department must comply with the Isle of Man Government Financial Regulations, the Isle of Man Government Code and the Isle of Man Government Civil Service Code

All budget holders shall designate and maintain a register detailing the offer of all gifts and rewards and any conflicts of interest for a budget area.

The Department’s Corporate Services Administration Team will hold a central register for the Department and update annually.

Registers shall be reviewed annually in line with Financial Regulations.

Effective Date

This document is effective from January 2023. It will be kept under review and amended when any changes are made to the Financial Regulations, following internal or external review of the Register or at least every three years, whichever is earliest.

PSG Division Declarations of Conflict of Interests and Gifts/Rewards V1.0 March 2023

3 Procedure for Declarations of Conflicts of Interests and Gifts/Rewards

Purpose

The purpose of this procedure is to ensure the Department fulfils its duties under the Financial Regulations1, the Government Code2 and the Civil Service Code34 to properly record, review and mitigate any conflict of interests with all staff, political members, third party providers or volunteers. It also applies to the recording of offers of gifts and rewards, whether received or refused.

A.2.2 All officers must ensure that they do not use, or give the appearance of using, their public position to further the private interests of themselves, their families, their friends or organisations in which they may have an interest.

A.2.3 All officers must ensure that whenever they have an actual or perceived conflict of interest that they immediately identify the relevant Budget Holder. Where it is the Budget Holder raising the conflict then they should inform their line manager.

A 2.4. Budget Holders must ensure that all actual or perceived conflicts of interest are recorded in a Conflicts Register covering the relevant Budget Area.

3.1 No officer of a designated body may accept, directly or indirectly, any gift, reward, hospitality or benefit from any member of the public or organisation with whom they are brought into contact by reason of their official duties other than: a) conventional ‘corporate’ hospitality in the course of working visits or meetings; b) isolated gifts of low value such as diaries, calendars, flowers or chocolates or other items up to the value of £20. Where feasible, such gifts should be shared amongst all of the team members within the relevant budget area.

3.5 The recipient of any offer of any gift, reward or hospitality received (whether received or refused) must ensure that it is properly recorded within the register designated for their budget area.

1 2020-financial-regulations-july-2020-v2.pdf (gov.im) 2 THE GOVERNMENT CODE 3 https://hr.gov.im/terms-conditions-for-employees/civil-service/section-a-conditions-of-service/acceptance- of-gifts-and-rewards/
4 https://hr.gov.im/terms-conditions-for-employees/civil-service/section-a-conditions-of-service/conduct-of-a- civil-servant/
PSG Division Declarations of Conflict of Interests and Gifts/Rewards V1.0 March 2023

4 Roles and Responsibilities

It is the responsibility of all relevant persons to ensure they make a timely, honest and relevant declaration of interest or the offer of a gift.

It is the responsibility of all Budget Holders to ensure that all actual or perceived conflicts of interest are recorded in a Conflicts Register covering the relevant Budget Area.

It is the responsibility of all Budget Holders to ensure a Gifts and Rewards Register is kept up to date.

A list of the Departments’ Budget Areas and Budget Holders can be found in Appendix 1.

A template Register can be found in Appendix 2.

The Register shall be available for inspection by the Chief Executive Officer and Deputy Chief Executive Officer, or any other approved person.

Information held maybe subject to Freedom of Information (FOI) or Subject Access Requests (SARs) by the individual themselves.

Conflict of Interest

As outlined within the Isle of Man Government Financial Regulations, budget holders are required to maintain a record of conflicts of interest. These should be recorded on the Gifts and Rewards Register.

A conflict of interest arises when any of the following people associated with the Department;

• all Department officers • minister and political members of the Department • independent bodies associated with the Department i.e. Education Council members and school governors • agency board members • volunteers

might reasonably be perceived by a member of the public to be likely to be biased, partial, or otherwise personally interested in the outcome of dealings between citizen, business or organisation and the Government.

All persons have the responsibility to declare an interest as soon as the potential for conflict arises, if in any doubt please contact the budget holder of the area which applies. PSG Division Declarations of Conflict of Interests and Gifts/Rewards V1.0 March 2023

5

A conflict of interest could arise in a variety of ways and it is for the officer to be alert to their own situation. It would not be possible to list all the ways in which a conflict of interest might arise however, there are a number of main issues, which could lead to real, or apparent, conflicts of interest. These include:

• Receipt of Departmental Papers (e.g. Committee or Department meeting); • Enquiries from members of the public; • Relevant financial or other interests outside of the Department, Board or Office for which you work; • Membership of some societies or organisations; • Relationships with parties/organisations which could lead to split loyalties, real or perceived; • Knowledge of emerging Government Policy which could give unfair personal advantage to individuals or groups with allied business interests – for example, access to privileged information e.g. trade secrets or commercially confidential information; • Perception of rewards in return for favours; • Family relationships; • Area of residence; • Tender process (noting a separate declaration process is followed for tender panel engagement) • Recruitment and selection process • Annual call for declaration of interests from all relevant persons • Conflicts of interest shall be a routine item of business on all Departmental agenda’s which includes Sub Committees and any declaration and subsequent actions will be recorded in relevant Minutes for the meeting the conflict was declared and a concurrent record made in the Register

No one should use, or give the appearance of using, their public position to further the private interests of themselves, their families or organisations in which they may have an interest. This is an area of particular importance, as it is of considerable concern to the public and could receive media or other attention.

The above are examples only, so you should consider carefully your own circumstances to gauge whether or not a real, or perceived, conflict might exist.

Declaration of Interest

A call for declarations will be undertaken annually in March. The Department’s Corporate Services Administration Team will contact each Budget Holder and ask for a copy of the Budget Areas’ Register. Each Register will be placed onto a central Department register which is available for review at any time. Any declaration that suggests action is required to manage or mitigate the interest will be flagged to the Department’s Policy Hub for review and further guidance will be given where necessary.
PSG Division Declarations of Conflict of Interests and Gifts/Rewards V1.0 March 2023

6

Gifts and Rewards

In line with the Isle of Man Government Financial Regulations, public servants should not accept gifts, hospitality or services from anyone which would, or might appear to, place them under an obligation. The same principle applies if gifts, etc., are offered to a spouse, partner or member of their immediate family.

The receipt of any offer of any gift, reward or hospitality (wither received or refused) must be properly recorded within the Register designated for their budget area.

Conventional ‘corporate’ hospitality, or such categories of gifts as determined by written instruction of the Department’s Accountable Officer, that meet the above description, with an estimated value up to £20, do not need to be entered into the Register.

PSG Division Declarations of Conflict of Interests and Gifts/Rewards V1.0 March 2023

7 Appendix 1

List of Department of Education, Sport & Culture Budget Areas and Budget Holders

Budget Area Budget Holder Culture Division Head of Culture & Arts Villa Marina & Gaiety Theatre Head of Culture & Arts Kensington Arts Centre & Soundcheck Arts Development Manager Arts Council Arts Development Manager

Budget Area Budget Holder Sport, Recreation & Youth Services Division Head of Sport, Recreation & Youth Services National Sports Centre NSC General Manager Sports Facilities Sports Development Unit Head of Sport, Recreation & Youth Services IoM Sports Sports Development Officer Youth Services Principal Youth Officer Activ8 Health & Wellbeing Programmes Health & Wellbeing Manager

Budget Area
Budget Holder Education Advice & Support Division Director of Strategic Advice for Education Pathways for Children PCI Service Manager EAS – Strategic – Early Years EY Lead EAS – Strategic – PSAC Head of PSAC EAS – Strategic – Manx Language Head of Manx Language Unit EAS – Strategic – Santon CPD Primary Lead EAS – Strategic – Initiatives Director of Strategic Advice for Education EAS – Strategic – Teacher Train Director of Strategic Advice for Education EAS – Strategic – Careers Employability Lead EAS – Strategic – Manx Culture Manx Curriculum Advisory Teacher EAS – Support – AEN Services SEN Manager EAS – AEN Services – SEN

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