Code of Business Conduct

This Code of Conduct should be read in conjunction with existing legislation, policies, procedures and guidelines including but not limited to:

• The Sea Fisheries and Maritime Jurisdiction Act 2006
• Department of Finance Public Procurement Guidelines 2004
• Guidelines on Ethics in Public Office
• The Civil Service Code of Standards and Behaviour Circular 16/36
• Civil Servants and Outside Occupations Circular 20/28
• Bankruptcy or Insolvency of Civil Servants Circular 17/32
• Use of Influence of Civil Servants
• Ethics in Public Office Acts 1995-2001
• Data Protection Acts 1988-2003
• Freedom of Information Act 2014
• Protected Disclosures Act 2014

It should also be read alongside SFPA policies and procedures generally, and in particular: 

• The SFPA Policy on Hospitality & Minor Gratuities
• The SFPA Protected Disclosures Guidance Documents
• The SFPA Policy on Confidentiality

It is the intention of this policy to give clear guidance to all; however, should any individual within SFPA require clarity on any particulars they should seek advice from SFPA senior managers or Authority Members.

The objectives of this Code of Conduct are:

• To set out an agreed set of ethical principles for Authority Members and employees of the Sea-Fisheries Protection Authority (SFPA).
• To promote and maintain confidence and trust in the SFPA.
• To prevent the development or acceptance of unethical practices within the SFPA

The Authority Members of the SFPA shall ensure that the core values of integrity, probity, transparency, accountability, and fairness are adhered to within the organisation.

1. Members of the Authority shall disclose outside business or employment interests which they consider may be in conflict or potential conflict with the business of SFPA
2. Members of the Authority shall comply with the requirements of the Ethics in Public Office Acts and associated regulations
3. Employees of SFPA shall not involve themselves in outside business/employment interests that would be in conflict or potential conflict with the business of the SFPA 
4. SFPA Authority Members and employees shall not accept or give gifts, services, hospitality, preferential treatment or benefits that could affect or be perceived to affect the ability of the donor or recipient to make independent, impartial judgements
5. The SFPA shall conduct its procurement activities in accordance with best business practice and public policy
6. The SFPA shall ensure that its accounts accurately reflect financial performance and are not misleading or designed to be misleading
7. SFPA Authority Members and employees shall claim expenses only as appropriate to business needs and in accordance with good practice in the public sector generally.
8. SFPA Authority Members and employees shall not use their position or SFPA reputation or resources (including time) to benefit themselves or others with whom they have family, business or other ties
9. SFPA Authority Members and employees shall not use knowledge acquired in the performance of, or as a result of, their official duties to benefit themselves or others with whom they have family, business or other ties
10. SFPA Authority Members and staff shall not acquire information or business secrets by improper means
11. The acceptance of further employment where the potential for conflict of interest arises should be avoided during a reasonable period of time after the exercise of employment of the SFPA

1.  SFPA Authority Members and employees shall provide access to information on its activities in a way that is open and enhances our accountability to the general public

2.  Save as otherwise provided by law, SFPA Authority Members and employees shall protect the confidentiality of all sensitive and personal information held by the organisation, this includes all material such as:

• Information that has been expressed to be confidential by the Authority under Section 58 of the Sea Fisheries and Maritime Jurisdiction Act 2006

• Commercially sensitive information (including but not limited to future plans or details of major organisational or other changes such as restructuring)
• Information received in confidence by the public body

3.  The requirements of non-disclosure of privileged or confidential information continues to apply to all Authority Members and employees post-retirement or resignation from the SFPA

4. SFPA Authority Members and employees shall observe appropriate prior consultation procedures with third parties when, exceptionally, it is proposed to release sensitive information in the public interest

4. SFPA Authority Members and employees shall comply with relevant statutory provisions including data protection and freedom of information legislation

5.  SFPA Authority Members and employees will observe the requirements of non-disclosure of privileged or confidential information to any third party. This continues to apply where their appointment with the SFPA has ended

1. SFPA Authority Members and employees shall fulfil all regulatory and statutory obligations to which it is subject
2. The SFPA shall comply with detailed tendering and purchasing procedures as well as complying with prescribed levels of authority for sanctioning any relevant expenditure
3. SFPA Authority members shall introduce controls to prevent fraud, including adequate controls to ensure compliance with prescribed procedures in relation to claiming of expenses for business travel
4. SFPA Authority Members and employees shall comply with internal audit and the internal audit process
5. SFPA Authority Members shall use all reasonable endeavours to attend all SFPA Authority meetings. 

The SFPA recognises that the acceptance of positions following employment and/or engagement by a State body can give rise to the potential for conflicts of interest and to confidentiality concerns. SFPA Authority Members will consider any cases in which such conflicts of interest or confidentiality concerns come to their attention and will take appropriate steps to deal with such matters in an effective manner. SFPA Authority Members will ensure that any procedures it may put in place in this regard are monitored and enforced.

SFPA Authority Members and employees acknowledge their responsibility to be loyal and fully committed to the SFPA whilst acknowledging the duty of all Authority Members and employees to conform to the highest standards of business and professional ethics.

1. SFPA Authority Members shall ensure compliance with employment equality and equal status legislation
2. SFPA Authority Members and employees shall operate fairly in all business dealings 
3. SFPA Authority Members and employees shall value and treat all customers equally

1. SFPA Authority Members shall promote the development of a culture of ‘speaking up’ whereby workers can raise concerns regarding serious wrongdoing in the workplace without fear of reprisal
2. SFPA Authority Members place the highest priority on promoting the health and safety of employees
3. SFPA Authority Members and employees shall ensure that community concerns are given due regard
4. SFPA Authority Members and employees shall have regard to the potential environmental impact of its operations on the environment

1. This Code of Business Conduct and the SFPA's Protected Disclosures, Guidance Document No 1: SFPA Employees shall be provided to all employees of SFPA, who are required to retain them
2. SFPA employees are also required to ensure their understanding of the provisions contained in these policies. Therefore, should any employee have any questions with regard to their understanding of these documents, or any other ethical considerations, they should raise their queries with the SFPA Authority Members who will provide practical guidance and direction as requested

SFPA Authority Members shall ensure periodic review of this Code.