Close Personal Associations and Relationships Guidance - June 2026

2. Scope

This policy covers all employees including centrally employed teachers but excludes staff on the complement of locally managed schools for whom a separate policy applies. In the absence of a policy agreed locally by individual schools the principles of this policy should be followed.

3. Principals

To avoid any accusation of bias, employees must not be involved in the recruitment procedure where they are a relative or partner of or have a close personal association / relationship with the individual being considered for appointment. Similarly, employees must not be involved in decisions relating to discipline, dismissal, grievance, and promotion or pay adjustments for that employee.

The aim is to build an organisation that is committed to maintaining high standards of conduct in the area of close personal associations/relationships at work.

This will be achieved by:

• Promoting high standards of conduct and integrity amongst the authority’s employees.

• Not interfering unduly in employees’ private lives but taking legitimate action when close personal associations / relationships at work have an actual or potential impact on the authority’s services.

• Managing issues involving close personal associations / relationships at work promptly, effectively, fairly and lawfully.

• Describing the types of close personal associations / relationships at work that the authority considers inappropriate.

This guidance is produced to support the Employee Code of Conduct and Employee Declarations procedure along with the Codes of Practice and professional standards relating to specific occupations.

This guidance is not designed to deal with issues of misconduct or grievance relating to close personal associations / relationships. These should be dealt with in accordance with the Disciplinary Policy and Procedure, and Grievance Policy and Procedure.

4. Roles and Responsibilities

Line Managers will:

• Deal promptly and sensitively with issues involving close personal associations / relationships at work.

• Conduct matters involving close personal associations / relationships at work in a fair and reasonable way.

• Maintain confidentiality where possible.

• Deal with any matter requiring formal disciplinary action using the Disciplinary Procedure.

Employees will:

• Ensure that any close personal associations / relationships at work do not interfere with or prejudice their employment.

• If a close personal association / relationship at work interferes with or prejudices their employment s/he will co-operate under this procedure to resolve the situation.

• Ensure that the declaration form is completed where appropriate (Appendix 1).

• Raise concerns with their line manager promptly.

HR Teams will:

• Provide advice and guidance to Managers and employees relating to close personal associations / relationships at work.

• Ensure consistency in the application of this policy and procedure.

• Maintain confidential records in accordance with Data Protection Principles.

5. Definition of Close Personal Associations / Relationships

When considering whether to declare a close personal association the employee should consider whether there could be any perceived influence or bias. Close personal associations / relationships within this guidance are defined as employees who are:

• Married, Civil Partners, in a Partnership or Co-habiting arrangement.

• Immediate family members of the applicant or employee e.g. Parents, Son / Daughter, Brother / Sister, Grandparent / Grandchild.

• Other relations of the applicant or employee e.g. extended family such as Aunts/Uncles/Cousins/Nieces/Nephews and any other individuals with who there is a close personal association e.g. close friendships or relationships, business associates (outside the authority). It also includes a previous association e.g. former spouse, where there could be a degree of bias.

• A child / young person or vulnerable adult /client whom an employee meets as a result of their employment.

• A person with whom you are/have been in conflict or dispute.

In accordance with the Employee Declaration Procedure, where any employee is uncertain about whether an association should or should not be declared then they should err on the side of caution and declare it. The key test is whether such an association could be seen to affect an individual’s personal judgement.

6. Defining a Relevant Team or Establishment or Work Area

What constitutes a team, establishment or work area for these purposes will usually be self-evident, i.e. involves working under the same direct line management arrangement. For the purposes of this guidance an establishment is usually defined as a single location or workplace

There will, however, be occasions, where the association involves a senior manager within the authority and the definition and potential for conflict of interest will be wider e.g. across a service, or where a Head of Service has an association with a Councillor who has specific responsibility for their service group

Conflict could also arise where one of the parties is employed by the authority and the other is either a volunteer or employed by an organisation with which the authority has a contractual or partnership agreement, i.e. partnership working (Please refer to Employee Code of Conduct).

7. Recruitment and Appointment of Employees

To avoid any accusation of bias, in accordance with the Code of Conduct for Employees, an employee (or Councillor) must not be involved in any appointment process where they are related or have a close personal association / relationship outside work with the individual being considered for appointment.

8. Requirement to Disclose a Close Personal Association

All applicants are required to disclose on the authority’s recruitment application if they are related to a councillor, school governor or senior employee of the authority.

Applicants are asked to state the name of the person and the relationship. Failure to disclose such a relationship may disqualify the applicant from the recruitment process for that post. Any applicant who directly or indirectly seeks the support of a manager or Councillor for any appointment within the authority will be disqualified from continuing the recruitment process for that post.

9. Where there is a Relationship Between Applicant and Manager or Team Colleagues

Where the applicant, if appointed, would work in the same team or establishment with an employee with whom they have a close personal association the implications of this should be considered and discussed at the end of the selection process. This is to ensure that, assuming they are otherwise the most suitable candidate for the job, the appointment would also be appropriate considering operational issues and standards.

The type of issues that should be explored could include:

• General operational issues relating to shift or working patterns, annual leave requirements etc. The applicant would need to be clear as to the operational requirements of the job which may involve different shift patterns or working times to their partner and no guarantee that leave could always be authorised to coincide.

• More specific operational issues e.g. in relation to finance and procurement roles and responsibilities within a job which are governed by Financial Regulations.

• Potential conflict of interest and confidentiality issues including the impact on the perceptions and employee relations within the team.

• Impact on service users or the general public, including issues relating to trust and confidence and the public image of the authority¹.

¹ Please refer to safeguarding procedures for children and vulnerable adults and code of professional practice for social care and the Authority’s Code of Conduct.

10. Authority to Appoint

Where, following consideration of all the factors in the above, the appointing manager considers that a candidate could properly be appointed despite a declared relevant close personal association, they must clear that appointment with their Director or Head of Service or a nominated officer.

To avoid questions arising later, the appointing manager is required to make a written record of the fact that the decision to appoint despite a declared relationship was made with appropriate authority. This record should be kept with the candidate’s original application form on their personnel file held by Human Resources.

Where a close personal association involves a manager and a team member, the appropriate senior manager for the team or service area, in consultation with the HR Team, should in discussion with both employees:

• Make alternative supervision / line management arrangement of the team member for issues involving a potential conflict of interest. These include matters related to pay, promotion, job opportunity and discipline issues. This will normally mean a change to this aspect of the line management arrangement whereby the team member is supervised by another manager² but management of work-related functions remains unaltered.

• Consider any other operational issues that might occur and how these might be managed. Specific operational issues in relation to financial responsibilities that need to be considered are the separation of duties, probity, and other financial safeguards within the Financial Procedure Rules. More general issues may include cover, particularly in small teams.

• Assess any impact on service users and the general public, including issues relating to trust and confidence and the public image of the authority.

• Consider if it is appropriate to communicate such agreed adjustments etc to other colleagues in the team/workplace to manage any concerns.

Expectations should be clearly defined and managed as appropriate. Refer to form Appendix 2; this should be used to record the agreed protocol between the manager and team member.

Example:

Situation

Because of certain behaviour between them that she has witnessed, Mary has reason to believe that Michael, one of the team leaders whom she manages has begun a romantic relationship with one of his colleagues (who he directly line manages) Clare.

Manager’s response

Mary calls a separate private meeting with Michael and Clare, states her observations to them, and asks whether or not they are, in fact, involved romantically. Both parties declare they are in a romantic relationship, and Mary provides them with the Code of conduct declaration of personal interests to complete and return. Mary works though the relationship protocol with both parties, and this is agreed and signed.

² Please note that changes to line management responsibility may result in a re-evaluation of the manager’s post and could impact on the grade.

11. When Issues Cannot be Managed Effectively

Where any issues identified cannot be managed effectively there will be the need to explore, in discussion with both employees, whether a move to another team, establishment or location might be the most appropriate way forward. Managers should seek advice from the HR Team prior to discussing a move with an employee.

When discussing such an issue there should be no assumptions made, on gender, status / grade etc. as to who might be the most appropriate employee to move. Care should be taken to avoid discrimination and ensure that the views of the individuals involved are considered, balancing this with the needs of the service and the issues that present themselves.

In the event that no agreement is reached with the parties to move to another team, establishment or work area, careful consideration will need to be given to whether or not it is reasonable for the Authority to determine that a transfer of one or both of the parties must take place. Advice must be sought from HR in such circumstances.

12. When a Relationship Breaks Down

There may be occasions when a close personal association breaks down and the individuals concerned remain in the same team, establishment, or work area with a potential impact on team relationships and service delivery. In such cases use of the authority’s Occupational Health service may be appropriate. The line manager should also consider the Authority’s Behavioural Standards Guidance. This may apply where an employee raises concerns relating to the perceived inappropriate behaviour of another member of the team.

There may be cases where professional mediation is the most appropriate and effective route to rebuild the relationship. Mediation is not however a universal remedy and as such advice should be sought from HR before discussion with the parties involved to assess whether this is the appropriate course of action.

Advice from the HR team can assist with this process where required. This may ultimately involve exploring with the parties whether a move to another team, establishment or location might be the most appropriate way forward. Managers should seek advice from the HR Team prior to discussing a move with an employee.

13. Conduct or Performance Issues

As with any employee, significant conduct or performance issues may need to be dealt with, where appropriate, under the Authority’s Disciplinary or Capability procedures. Much would depend on the nature and degree of the issue concerned or whether alternative approaches as outlined in this policy would be more appropriate or effective.

14. Close Personal Associations between an Employee and a Child / Young Person or Vulnerable Adult

If this type of relationship exists/develops, the authority’s separate adult/child protection procedures will apply. Where there is an abuse of the employee’s position of trust, a breach of the standards of propriety expected in the post, a compromise of professional standards and/or conflict of interests. Refer to the HR Team for further guidance.

15. Colleagues Affected by a Close Personal Association

Employees who feel they are affected by a close personal association at work involving other colleagues, should at all times feel that they can approach without prejudice, their line/senior manager and/or HR Team to explain their concerns.

16. Provision of References

When providing references, the individual providing the reference should make clear if it is a personal reference they are providing on behalf of a colleague or formally on behalf of the authority, in line with the Authority’s Reference Guidance, available here Recruitment.

If you are not providing a reference in your capacity as a line manager i.e. formally on behalf of the authority, then the reference should not be produced on the authority’s headed stationery.

17. Financial Regulations

Where a close personal association might exist between two individuals involved in financial transactions the Authority’s Financial Procedure Rules should be followed to ensure the appropriate separation of duties, probity and other financial safeguards are followed.

18. Associations with Contractors or Potential Contractors

In accordance with the Code of Conduct for Employees no special favour should be shown in the tendering process to businesses run by, for example, friends, partners, or relatives. Employees who engage or supervise contractors or have any other work relationship with contractors and have previously had or currently have a close personal association with someone who works for contractors, must declare that relationship to their Head of Service or their line manager if they are themselves are a Head of Service.

All employees involved in procurement within the authority are required to comply with the Financial Procedure Rules.

19. Failure to Disclose a Close Personal Association

Failure to disclose a close personal association could leave an employee open to allegations of misconduct should subsequent issues arise. This could result in formal disciplinary action in accordance with the Disciplinary Policy and procedure.

20. Ensuring Equality of Opportunity

Everyone must adopt a positive, open and fair approach and ensure the Authority’s Equality and Diversity Policy is adhered to and applied consistently to all irrespective of race, colour, nationality, ethnic or national origins, language, disability, religion and belief or non-belief, age, sex, gender reassignment, gender identity or expression, sexual orientation, maternity, parental, marital or civil partnership status.

If you have any equality and diversity concerns in relation to the application of this policy and procedure, please contact a member of the People Management Team who will, if necessary, ensure the policy/procedure is reviewed accordingly.

If you require this publication in an alternative format, please contact People Services by emailing CHR@carmarthenshire.gov.uk

Appendix 1 - Officers' Declaration of Personal Interests

Please refer to the procedure for full details here Appendix 1 - Officers' Declaration of Personal Interests

Appendix 2 - Relationship Protocol

Please refer to the procedure for full details here  Appendix 2 - Relationship Protocol