Business Interest, Secondary Employment and Voluntary/Public Duties Policy

1. Statement of Policy

As well as working for Dyfed-Powys Police, staff and volunteers may wish to undertake a secondary employment, engage in a business interest or sporting interests. A Business Interest encompasses all activities where a police officer, member of staff or volunteer holds a position for hire, for gain or as a volunteer.

Dyfed-Powys Police do not wish to restrict officers, staff or volunteers from holding a business interest and seeks to provide a consistent approach to authorising only those business interests that do not conflict with policing, and which will not have an adverse effect on the reputation of the individual, Dyfed-Powys Police or the wider police service.

Applies (but not limited) to: All categories of Dyfed-Powys Police officers and staff, whether full-time, part-time, permanent, fixed term, temporary (including agency staff, associates and contractors), seconded staff and volunteers. Police Officers, staff and volunteers accessing and using Force assets and property must have due regard to the contents of this policy.

 

2. Policy Scope

Definition of a Business Interest

Regulation 7 of the Police Regulations 2003 defines a Business Interest and or secondary employment:

2.1 Being a member of a police force, the person holds any office or employment for hire or gain (otherwise than as a member of the force) or carries out any business.

2.2 (*Police Officer only) Being a member of a police force or a relative included in such a member’s family, the persons hold or possesses a pecuniary interest in a licence or permit granted in the pursuance of the law relating to alcohol licencing, refreshment houses or betting and gaming or regulating places of entertainment in the areas of the police force in question.

2.3 “Relative” is defined as:

• Spouse or civil partner who is not separated from the member
• Person living with the member as if they were a spouse or civil partner
• Parent, son, daughter, brother, or sister of the member
• Any other relative in law

2.4 The same definition of a business interest and relative applies to police staff and police support volunteers. The term “member” in this regard is used to refer to police officers, police staff, Special Constables and police support volunteers.

2.5 It is essential that the public have confidence in the integrity and impartiality of all those working within Dyfed-Powys Police and that all comply with the Standards of Professional Behaviour and the Code of Ethics.

2.6 The decision-making process must ensure that business interests and secondary employment  undertaken does not conflict with the work of Dyfed-Powys Police, that they would not undermine public confidence or adversely affect the reputation of an individual, the Force, or the wider police service.

2.7 The policy and procedure applies to police officers, police staff and volunteers.

2.8 Each application will be considered independently and impartially, on a case-by-case basis.

2.8 No police officer, police staff member or volunteer should commence or agree to commence any business interest or secondary employment  prior to formal approval being granted.

2.9 Applicants to Dyfed-Powys Police will be asked on their vetting form whether they intend to carry on a business interest. This policy will apply to those intending on joining the organisation and if a conflict is identified, this could affect a vetting decision.

2.10 Principles to Consider

Police Officers

• as a result of the interest in question whether the member’s conduct fails or would fail, to meet the appropriate standard set out in the Standards of Professional Behaviour, Schedule to the Police (Conduct) Regulations 2008 and Regulation 6, Schedule 1, The Police Regulations 2003.

 

• Schedule 1 provides that: ‘A member of a police force shall at all times abstain from any activity which is likely to interfere with the impartial discharge of his duties or which is likely to give rise to the impression amongst members of the public that it may so interfere. Reg. 6 (2) provides that, no restrictions other than those designed to secure the proper exercise of the functions of a constable shall be imposed by the local policing body or the chief officer on the private life of members or a police force.

Police Staff

• whether the proposed secondary employment and or business interest would lead to a breach of the Police Staff Council Standards of Professional Behaviour. Police Staff must not engage in any other employment or business activity, honorary or otherwise, without the consent of Dyfed-Powys Police. If the member of police staff has or intends to engage in any other employment or business activity, they must make an application in line with this procedure.
• When considering the appropriateness of an application for a business interest or secondary employment, it should start from the premise that only those interests or employments that are compatible with the ethos and values of the police service will be permitted. Careful consideration will be given to the potential for adverse reputational damage to the service arising from any perception of any shortfall in the integrity of a member of a police force being associated with the prospective interest or secondary employment.

Working Time Directive

The Working Time Regulations 1998 contain provisions relating to hours of work, rest periods, night working and annual leave.

Although the Working Time Regulations 1998 do not contain specific provisions covering workers with more than one job, reg. 4(2) requires employers to take all reasonable steps, in keeping with the need to protect the health and safety of workers, to ensure that workers adhere to the 48-hour limit on weekly working hours.

Therefore to fulfil it’s obligations under the Working Time Regulations 1998 the Force requires staff who wish to engage in other employment or have any outside business interest to provide details on the ‘Application to Register a Business Interest or Secondary Employment Form’, of the number of hours that will be spent in the business interest or secondary employment, and when they are likely to be worked.

Conflict of Interest

2.11 A conflict of interest is any situation in which an officer, police staff, member of the Special Constabulary or volunteer with Dyfed-Powys Police or employee of the Office of the Police and Crime Commissioner (OPCC) has a competing interest or loyalty and where it is arguable that a fair-minded and informed observer, having considered the facts, would conclude that there was a real possibility that the relevant person could be biased.

2.12 A conflict of interest can exist in many guises, notably where an officer’s or staff member’s personal interest conflicts with their own professional position. All officers and staff are required to declare a conflict of interest to their Line Manager (but if not appropriate, another suitable Manager) as soon as this becomes apparent. Failure to report a conflict of interest may result in disciplinary proceedings being considered.

2.13 Each possible conflict of interest will be considered on a case-by-case basis, and it may be necessary for the appropriate manager to seek further guidance and advice in making a final decision.

Voluntary Sector Work

2.14  Dyfed-Powys Police sees the positive impact that voluntary work can have within the community. All voluntary sector work is considered as a business interest even if it is purely voluntary with zero pay or expenses covered.

2.15 To be clear, it is still a business interest if you are volunteering for a charitable organisation, or you volunteer for a private organisation.

Full details on Voluntary Sector work can be found within the Business Interest and Secondary Employment Procedure.

Public Duties

2.16 Police officers, staff and volunteers must seek approval via the Business Interest application process in order to take part in any public duties role. These duties must not be undertaken unless prior permission has been granted.

The force will require a minimum of 2 weeks notice to allow time off for this type of role.

If time off is approved it will be unpaid.

Police Officers and staff in ‘politically restricted’ roles cannot undertake the public positions of Magistrate or Councillor.

A list of public duty roles can be found within the associated Business Interest and Secondary Employment Procedure.

The force policy/procedure for Leave for Personal and Family Reasons plus other Special Leave also holds information about Public Duties

Armed Forces Reservists

2.17  Any reservist roles are defined as business interests and must be submitted for consideration.

2.18 Those wishing to engage in this secondary employment should read Dyfed-Powys Police’s Leave for Personal and Family Reasons and Other Special Leave policy and procedure for guidance on taking time off for any reservist deployments.

Landlords

2.19 Property rental includes (but not limited to): rental of single rooms, a flat in the family home, part-time rental of a holiday home, and full-time rental of a property at home or abroad.

2.20  Staff member landlords must also be aware of their responsibilities in respect of the Notifiable Association Guidance in respect of tenants and must cooperate with Police Forces, local authority and any other statutory bodies in the investigation of complaints of anti-social behaviour or criminal conduct against their tenants.

 

Career Break Scheme (Officers and Staff)

Full details on how the Career Break Scheme affects this policy can be found within the Business Interest and Secondary Employment Procedure.

Incompatible Business Interests

For details on examples of Incompatible Business Interests, please refer to the Business Interest and Secondary Employment Procedure.

 

Internet, Social Media and Streaming Platforms

Details on the internet, social media and streaming platforms can be found within the Business Interest and Secondary Employment Procedure.

 

3. Powers and Policy/Legal Requirements

• Regulation 7 of Police Regulations 2003
• Working Time Regulations 1998
• Data Protection Act 2018
• Freedom of Information Act 2000
• College of Policing - Code of Ethics
• Welsh Government Ethical Employment in Supply Chains Code of Practice.
• ACPO Guidelines on the Management of Business Interests & Additional Occupations for Police Officers & Police Staff 2012
• Police Staff Council Circular No 139 – Public Duties

Internal

• Dyfed-Powys Police Business Interest and Secondary Employment Procedure
• Dyfed-Powys Police Leave for Personal and Family Reasons plus Other Special Leave Policy and Procedure
• Dyfed-Powys Police Notifiable Associations Policy and Procedure
• Dyfed-Powys Police Career Break Policy and Procedure

 

4. Options and Contingencies

The Applicant

4.1 The applicant must ensure the nature of the business interest (BI) and/or activities involved are ethical and do not conflict with the requirements of the Force.  

4.2 The applicant is responsible for reporting any significant changes in the nature of the approved BI or any redeployment in their duties which may conflict with their BI.

4.3 The applicant must re-apply for continued permission to carry out the Business Interest on an annual basis.  

4.4 The applicant must not conduct their BI/secondary employment within duty time and at any time, must not use police equipment, police systems, materials, or intellectual property in connection with their BI.

4.5 The applicant must cease the conduct of their authorised BI, following 7 consecutive days of Sickness Absence, unless otherwise endorsed by their Line Manager and BCU Commander / Department Head.

 

Line Managers

4.6 Line Managers are expected to assess if the application is compatible with the expectations of Dyfed-Powys Police, taking the applicants sickness record over the last 3 years (Bradford Score) and performance over the last 12 months into consideration.  

4.7 Full details of the nature of the business interest must be known and discussed with the applicant.

BCU Commanders/Heads of Department

4.8 BCU Commanders/Heads of Department are expected to review the application and provide a decision to authorise or decline. Endorsement of the form should include any applicable caveats or conditions.

Professional Standards Department (PSD)

4.9 PSD will record and examine the application considering the applicants complaint and conduct records, Line Managers comments, and checks made with the Anti-Corruption Unit (ACU) and Vetting Unit. Force Intelligence Bureau (FIB) will be consulted to identify any business links of concern.

4.10 The Applicant will be provided with a right to appeal regarding the decisions made.

4.12 In the event that an application is declined, PSD/ACU will monitor activity to ensure compliance with the decision.

Whilst an application may be granted, supervisors retain the right to reconsider authorisation or re-assess any caveats should the Applicant’s performance, welfare or other impacting factors warrant a review.

The final decision will remain with the Applicant’s BCU Commander / Head of Department.

The Code of Ethics are relevant to this policy.

• Courage
• Respect and Empathy
• Public Service

 

5. Take action and review

This policy and the associated procedure document will be monitored to ensure that it is fit for purpose, any changes to national guidance or legislation or where there are any challenges made to the policy.

The policy will be reviewed by the Professional Standards Department and overseen by the Joint Negotiation and Consultative Committee.  

CODE OF ETHICS CERTIFICATE OF COMPLIANCE

This policy has been drafted in accordance with the Code of Ethics and has been reviewed on the basis of its content and the supporting evidence and it is deemed compliant with that Code and the principles underpinning it.

HUMAN RIGHTS ACT CERTIFICATE OF COMPLIANCE

This policy has been drafted in accordance with the Human Rights Act and has been reviewed on the basis of its content and the supporting evidence and it is deemed compliant with that Act and the principles underpinning it.

EQUALITY IMPACT ASSESSMENT

Section 4 of the Equality Act 2010 sets out the protected characteristics that qualify for protection under the Act as follows: Age; Disability; Gender Reassignment; Marriage and Civil Partnership; Pregnancy and Maternity; Race; Religion or Belief; Sex; Sexual Orientation.

The public sector equality duty places a proactive legal requirement on public bodies to have regard, in the exercise of their functions, to the need to:

• eliminate discrimination, harassment, victimisation, and any other conduct that is unlawful under the Act;
• advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;
• foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

The equality duty applies to all protected characteristics with the exception of Marriage and Civil Partnership, to which only the duty to have regard to the need to eliminate discrimination applies.

Carrying out an equality impact assessment involves systematically assessing the likely or actual effects of policies on people in respect of all the protected characteristics set out above. An equality impact assessment should be carried out on any policy that is relevant to the public sector equality duty. 

EQUALITY IMPACT ASSESSMENT COMPLETED: June 2025