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SNIB refuses to disclose Conflicts of Interest Register


The Scottish National Investment Bank (SNIB) has refused to disclose its “Conflicts of Interest Register” as questions continued to be raised over whether the Bank is using taxpayers’ money in a transparent way.

Responding to a Freedom of Information request, the Bank said that “the register contains significant amounts of personal information provided by individuals which we feel should be withheld.”

“Some of the information contained in the conflicts register is also commercially sensitive to the Bank or to third parties and its publication could be commercially harmful should it be made public,” they added.

“Much of the information supplied by employees and directors in order for us to maintain the register effectively and efficiently manage actual or potential conflicts is provided on the basis that the confidentiality of the information will be maintained by the Bank and has been provided on the understanding that such private information will not be made public and in respect of which individuals may seek to enforce their right to privacy.”

“We believe that the publication of the conflicts register would undermine the free and frank exchange of information and views within the Bank and appropriate policies and measures to manage those conflicts which do arise,” the Bank’s Head of Compliance wrote. “Consequently, we believe that the publication of the conflict information would have a “chilling effect” upon this dialogue and therefore upon the formulation of appropriate mitigation.”

Disruption Banking has previously identified three separate occasions where the SNIB has invested taxpayers’ money – totalling £16.5 million – in companies where senior figures have served on Scottish Government advisory boards. The Bank has also invested £7.5 million in a firm run by an employee’s brother, and £5 million in a company partly owned by a SNIB director.

The Bank has consistently said in response to questions about these examples that whenever potential conflicts of interest arise, “mitigation and interest management measures are put in place, with a record maintained on a Conflicts of Interest Register.”

However, the Bank does not believe that it would be in the public interest for this register to be published openly.

Author: Harry Clynch

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