Our register of interests policy

Our policy provides advice and information around our duty to declare our "Register of Interests" as VisitScotland employees and Board Members.

1. Introduction

The public has a high expectation of the people who work for VisitScotland or serve on its Board. We each have a personal responsibility to uphold the highest standards.

It is important that VisitScotland, its employees and Board members, are seen to be without reproach where outside interests may influence our judgement, discussions and decision making or, importantly, as might be perceived by a member of the public to do so. 

As a public body, we are committed to adhering to the established "Principles of Public Life" which set out how business should be carried out in the public interest.

All our actions must be able to withstand scrutiny, be in the public interest, the interest of VisitScotland, the wider public sector, and where any personal interest exists:

it must be declared
it must demonstrably not influence the decision(s) being made.

VisitScotland employees and Board members have a duty to declare any private interests and VisitScotland has a duty to publish a list of relevant interests. This is called a "Register of Interests".

The Ethical Standards in Public Life etc. (Scotland) Act 2000 (Register of Interests) Regulations requires devolved public bodies in Scotland to maintain a public Register of Interests.

This policy covers the details of why, when and how you should submit an entry for the Register of Interests.

The behaviour and actions of public sector employees are routinely scrutinised by and published in the media. If you are in any doubt about an interest, consider whether you would be embarrassed, or criticised in any way, or VisitScotland’s reputation harmed, if your behaviour or actions were made public. 

Therefore, it is your personal responsibility to ensure you understand this policy and make a declaration, if appropriate. Failure to declare an interest or allow an interest to affect your actions as a VisitScotland employee, off-payroll worker or Board member, may result in disciplinary action being taken.

2. Definitions

The legislation, and this policy, relate to all VisitScotland employees, off-payroll workers and Board members.

It is important to note that the legislation specifically mentions "close family". Where a close family member has a relevant interest, this should also be declared. The legislation provides limited details in this regard, but for the purposes of this policy we will mean all the people you live with (including family and friends) and may include people who live elsewhere, specifically:

Non-cohabiting partner, husband, wife, parent, parent in-law, son, son in-law, daughter, daughter in-law, step-parent, stepson, stepdaughter, brother, sister and if any of those listed has a partner, that partner.

You should also consider if you have other relationships that you need to make VisitScotland aware of. This may include friendships within organisations that VisitScotland works closely with.

If you have any questions about your specific situation, please contact the Chief People and Culture Officer or the Risk and Governance Manager.

For yourself and any of the aforementioned people, where there may be an interest, the legislation specifically details interests per this table. You should make a declaration in respect of any and all of these.

Registerable interest	Description of interest
Remuneration	A description of: (a) remuneration received by virtue of being: (i) employed or self-employed (ii) the holder of an office (iii) a director of an undertaking (iv) a partner in a firm and (v) involved in undertaking a trade, profession, vocation or any other work (b) any allowance received in relation to membership of any organisation (c) the name, and registered name if different, and nature of any applicable employer, self-employment, business, undertaking or organisation (d) the nature and regularity of the work that is remunerated and (e) the name of the directorship and the nature of the applicable business.
Related undertakings	A description of a directorship that is not itself remunerated but is of a company or undertaking which is a parent or subsidiary of a company or undertaking which pays remuneration.
Contracts	A description of the nature and duration, but not the price of, a contract which is not fully implemented where: (a) goods and services are to be provided to, or works are to be executed for, the devolved public body and (b) any responsible person has a direct interest, or an indirect interest as a partner, owner or shareholder, director or officer of a business or undertaking, in such goods or services.
Houses, land and buildings	A description of any rights of ownership or other interests that may be significant to, of relevance to, or bear upon, the work or operation of the devolved public body.
Interest in shares	A description, but not the value, of shares in a company or other body where: (a) the responsible person’s interest in the shares may be significant to, of relevance to, or bear upon, the work or operation of the devolved public body and (b) the nominal value of the shares is greater than: (i) 1% of the issued share capital of the company or other body or (ii) £25,000.
Gifts and hospitality	A description of any gifts or hospitality received, except: (a) isolated gifts of a trivial character, the value of which must not exceed £50 (b) normal hospitality associated with the responsible person’s duties, and which would reasonably be regarded as appropriate; or (c) gifts received on behalf of the devolved public body.
Non-financial interests	A description of such interests as may be significant to, of relevance to, or bear upon, the work or operation of the devolved public body, including without prejudice to that generality membership of or office in: (a) other public bodies (b) clubs, societies and organisations^#1 (c) trade unions ^#2 (d) voluntary organisations

Notes

#1 - you may also need to declare your work here under the terms of the Volunteering Policy. Please contact your HR Business Partner or the Risk and Governance Manager, if you have any questions.
#2 - if you are simply and only a member of a trade union, you do not need to make a declaration about that membership. The reference in (c) above relates only to management or shop steward type roles.

Close relatives and friends

There is a section in the declaration form which asks about the interests of a close relative (definition). You should give a full declaration where there may an interest, or a perceived interest. This should include where you have a close relative who is a supplier to, or has a contract with, VisitScotland. This may also include close friendships.

If you have any doubts about the interests of a close relative, please ask a question or make a declaration, VisitScotland management will determine whether there is an interest or not. Where there is no interest, no information will be made public.

3. What you need to do

It is the personal responsibility of all those detailed in this section to make a declaration. Failure to make a declaration may be a disciplinary matter.

The online declaration form should be completed and submitted within one month of identification of an interest, or a change in an interest.

Directors, Chief Officers, members of the Executive Leadership Group and Board members

Directors, Chief Officers, members of the Executive Leadership Group and Board members will be requested to verify their Register of Interests form every six months to ensure we have the most accurate and up to date information.

Where a new interest arises, or an existing interest changes, the individual should complete a new form within one month of the change. This is in addition to the six-monthly verification requests.

The content from these forms will be published on VisitScotland.org.

This aligns with our reporting obligations in the Annual Report and Accounts.

Heads of department, employees with procurement, event and funding responsibilities

All heads of department and employees working in the Procurement Department, Events Department or those involved in the provision of funding, will be requested to verify their Register of Interests form every six months.

Where a new interest arises, or an existing interest changes, the employees should complete a new form within one month of the change. This is in addition to the six-monthly verification requests.

The content of these forms will not be automatically published on VisitScotland.org but will be subject to any relevant Freedom of Information requests.

The Chief Executive may choose to publish a specific interest where it feels it is important to do so. The employee would be advised of the intention to publish the interest.

All other employees

All other employees, who have an interest, should declare that interest by the completion and submission of a form within one month of the commencement of the interest. Forms will be reviewed by management.

The content of these forms will not be automatically published on VisitScotland.org but will be subject to any relevant Freedom of Information requests.

The Chief Executive may choose to publish a specific interest where they feel it is important to do so. The employee would be advised of the intention to publish the interest.

New employees

New employees are expected to have discussed or provided any relevant information during the recruitment and offer process. A full written declaration should be submitted within one month of starting with the organisation, where there is an interest.

The Chief Executive may choose to publish a specific interest where they feel it is important to do so. The employee would be advised of the intention to publish the interest.

Employees undertaking procurement assessments

Any employees involved in undertaking assessments for the procurement of goods or services, will be asked to complete a separate declaration of their interests. Employees will be expected to complete a declaration for each set of assessments they are involved in.

This process will be managed by the Procurement department and will relate to each specific procurement assessment taking place.

Gifts and hospitality

There is a specific Gifts and Hospitality Policy and associated declaration process via the completion and approval of a separate online form.

All employees are expected to read and understand the policy and their obligations with respect to the giving and receipt of gifts and hospitality.

Our gifts and hospitality policy

4. Register of Interests process

There is an associated and documented Register of Interests process that details how VisitScotland will examine all interests that are registered.

The process document details the following:

Evaluation of the interest by management
Escalation of the interest to the Chief Executive, if relevant
Proposed publication of the interest
Remedial action or measures to be put in place to remove any conflicts of interest, including employee role adjustments or removal from decision making situations
Whether external legal advice is required.

There is a separate process for the declaration of interests related to employees undertaking procurement assessments, this is managed by the Procurement Department, who have authority on this matter.

5. Relationship to other policies and related documents

6. Reporting, publishing, monitoring and reviewing

This policy will be reviewed every three years or at such time as there are legislative changes, other legal advice or advice from government.

7. Further information

Why have a Register of Interests? | The Standards Commission for Scotland

Model Code of Conduct | The Standards Commission for Scotland

If an employee has any questions about this policy or their declaration, they should contact the Chief People and Culture Officer, Head of Corporate Governance and Performance, or the Risk and Governance Manager directly.

Appendix - The Principles of Public Life

In 1995, the Committee on Standards in Public Life (the Nolan Committee) identified seven principles of conduct underpinning public life "for the benefit of those who serve the public in any way" and recommended that public bodies should draw up Codes of Conduct incorporating these principles.

VisitScotland is committed to the original seven principles of public life, and the two additional principles added to by the Scottish Government when it took the Nolan Committee recommendations one step further with the introduction of the Ethical Standards in Public Life etc. (Scotland) Act 2000. This brought in a statutory Code of Conduct for Board Members of Devolved Public Bodies and set up a Standards Commission for Scotland to oversee the ethical standards framework.

These are the original seven principles:

Selflessness - Holders of public office should take decisions solely in terms of the public interest. They should not do so in order to gain financial or other material benefits for themselves, their family, or other friends.

Integrity - Holders of public office should not place themselves under any financial or other obligation to outside individuals or organisations that might influence them in the performance of their official duties.

Objectivity - In carrying out public business, including making public appointments, awarding contracts, or recommending individuals for rewards and benefits, holders of public office should make choices on merit.

Accountability - Holders of public office are accountable for their decisions and actions to the public and must submit themselves to whatever scrutiny is appropriate to their office.

Openness - Holders of public office should be as open as possible about all the decisions and actions that they take. They should give reasons for their decisions and restrict information only when the wider public interest clearly demands.

Honesty - Holders of public office have a duty to declare any private interests relating to their public duties and to take steps to resolve any conflicts arising in a way that protects the public interest.

Leadership - Holders of public office should promote and support these principles by leadership and example.

The Scottish Government identified two additional principles:

Public Service - Holders of public office have a duty to act in the interests of the public body of which they are a Board member and to act in accordance with the core tasks of the body.

Respect - Holders of public office must respect fellow members of their public body and employees of the body and the role they play, treating them with courtesy at all times.

VisitScotland Register of Interests

Register of Interests - April 2026

Published May 2026

Download (573Kb)

Our register of interests policy

1. Introduction

In this article: