July 2025
1.1 This policy is aimed at:
1.2 For the remainder of this policy the above will be referred to as “our people.”
1.3 We are a Registered Social Landlord (RSL) and a Scottish Charity. We are part of a sector that has a strong reputation for integrity and accountability: to the people we exist to help our Regulators, partners and funders. We must ensure that our organisation upholds its reputation and that of the sector. Our people cannot benefit inappropriately from their connection to us.
1.4 This policy describes the entitlements, payments and benefits that our people are able to receive. It also describes what is not permitted and the arrangements that we have in place to ensure that the requirements of this policy are observed.
1.5 Our Rules require that we have a policy dealing with payments and benefits (1). The Scottish Housing Regulator (SHR) requires us to have a policy that sets out what payments and benefits we permit and to ensure that these arrangements demonstrate transparency, honesty and propriety (2). We must ensure there is no justifiable public perception of impropriety. This policy is based on the SFHA’s Model Entitlements Payments and Benefits Policy, which the SHR have confirmed meets their regulatory requirements.
1.6 As we are a Scottish Charity, all of our Board Members must also ensure that they comply with the Office of the Scottish Charity Regulator (OSCR) guidance to Charity Trustees3 and charity legislation.
1.7 This Policy is intended to be a practical document that supports us in meeting all of the above requirements, ensuring that none of our people benefits (or is seen to benefit) improperly or inappropriately from their involvement with us, but also that they are not unfairly disadvantaged. We expect our people to act in good faith, and in applying the terms of the policy we will always take this into account.
1.8 As someone who is affected by this policy, you are personally responsible for ensuring that you are familiar with and comply with its terms (4).
1.9 At all times, we expect a common-sense approach to be applied to the interpretation and application of this policy. If you are unsure about anything relating to entitlements, payments and benefits you should consult with the Chair or Managing Director (if you are a member of the Board) or with your line manager (if you are a member of staff).
1.10 This policy covers:
1.11 The Code of Conduct is linked to this policy. Failure to comply with the terms of this policy may be regarded as a breach of the Code of Conduct.
1.12 You are also required to be familiar with and observe the terms of our Anti- Bribery and Corruption policy. We prohibit any attempt to induce the organisation or our people to offer preferential services or business terms and we will at all times comply with the Bribery Act 2010.
1.13 Our policies relating to the following are also relevant to this document and must be complied with at all times:
1 SFHA (2020) Charitable Model Rules, Rule 38
2 Scottish Housing Regulator (February 2019) Regulatory Framework Standard 5.4
3 Office of the Scottish Charity Regulator (2017) Guidance for Charity Trustees
4 Code of Conduct for [Board/Committee] Members; Code of Conduct for Staff
Please note that this list is not exhaustive and you are required to comply with all of our policies and procedures.
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2.1 In order to protect our reputation and demonstrate that we conduct our affairs with openness, honesty and integrity, we maintain a Register of Interests. You must record in this register any interests that you or someone connected to you (see Section 3) has which are relevant to our business and /or our activities. You will be required to maintain the accuracy of the interests you declare and to confirm annually that your entry is accurate and up to date.
2.2 Where you have an interest in any matter that is being discussed or considered, including at a meeting, you must declare your interest and play no part in the consideration, discussion and decision-making; you must withdraw from any part of a meeting where the interest arises and play no part in the discussion. Our Rules require that any Board member who has an interest in a matter that is being considered withdraws from all discussions and plays no part in decision-making (5).
2.3 The Codes of Conduct which our Board and Committee Members and staff are required to uphold contain requirements about Declaring Interests that you should comply with at all times.
2.4 An annual report will be made to our Board on the entitlements, payments, benefits that have been recorded in the Register(s) by our people.
2.5 The following are examples of the kind of interest that you must declare. Please note that this list is not exhaustive, and there may be other interests that you should also declare.
2.6 You should note that in some circumstances, declaration of an interest may not be sufficient, and that it may be necessary for the organisation to take additional measures to deal satisfactorily with the situation so as to protect the probity and reputations of both yourself and the organisation.
2.7 Many of the interests you will be required to declare can be classed as entitlements, payments or benefits.
2.8 As one of our people, you potentially could be offered benefits over and above that to which you are entitled (as a result of policy or contractual terms), such as gifts or hospitality from external parties. Such offers would be as a direct result of you being one of our people and cannot always be accepted. We require that any such offers are managed and recorded very carefully to ensure the highest levels of probity in our organisation. Our people should not benefit – or be seen to benefit – inappropriately from their involvement with us.
2.9 Apart from payments that our people are entitled to by contract, statute, policy or other agreement (e.g. salary, expenses), we will only make a payment to, or accept a payment from, someone affected by this policy in exceptional circumstances. Appendix A explains the payments we can and cannot make in more detail.
2.10 As we contribute to the economy(ies) of the area(s) we work in and we have commercial and business relationships with many different companies, contractors, suppliers and service providers, you must ensure that we are fully aware of any connection that you or someone you are close to (see section 3) has with any of these businesses or organisations.
2.11 Some entitlements, payments and benefits we can never permit, and others we have additional requirements or conditions that must be met before we can permit.
2.12 Appendix A lists the entitlements, payments and benefits that fall under this policy, and states:
5 SFHA (2020) Charitable Model Rules 2020 Rule 38
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3.1 Someone ‘closely connected’ to you includes members of your household, family members and other relatives and your friends.
3.2 As well as considering your own actions, you must be aware of the potential risk created by the actions of people to whom you are closely connected. Who you should consider, and our expectations of you to identify and declare such actions are outlined in Table A on page 7. If you are in any doubt about whether or not a declaration is required, you should consult the Chair, Managing Director or, for staff, your line manager.
Group | Required Response |
| We expect you to be aware of and declare any relevant actions of all people in your household. You must take steps to identify, declare and manage these. |
2. Partner, Relatives and friends This includes:
|
Where you have a close connection and are in regular contact with anyone within this group, we expect you to be aware of and declare any relevant actions. Under these circumstances, you must take steps to identify, declare and manage these actions.
Where you do not have a close connection and regular contact with someone in this group, we do not expect you to be aware of or to go to unreasonable lengths to identify any relevant actions. However, if you happen to become aware of relevant actions by such individuals, then these should be declared and managed as soon as possible. |
3.3 The following are the relevant actions /involvement by those to whom you are closely connected that you should consider, declare and manage as per our expectations outlined in Table A (please be aware that this list is not exhaustive or exclusive):
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4.1 In order to help us maintain our excellent reputation, where possible you should avoid using the organisation’s contractors/suppliers for your own personal purposes. We have made a list available to all of our people which outlines the contractors and suppliers that fall under the terms of this policy. This is included at Appendix B.
4.2 We recognise that there could be certain circumstances where it might not be possible for you to avoid the use of all the contractors/suppliers on this list, such as where market conditions in your local area make it difficult to obtain a reasonable selection of potential contractors or suppliers. Under such circumstances you could be permitted to use those contractors/suppliers
outlined at Appendix B, provided you are able to demonstrate that you received no preferential treatment in terms of price, quality or any other aspect of service delivery due to your involvement with us.
4.3 Approval to use those contractors listed at Appendix B is at the discretion of the approving officer (in accordance with our scheme of delegation). In order to be granted approval, you will be required to demonstrate that there is no reasonable alternative contractor/supplier providing the service required in your local area, and that you will receive no preferential treatment in terms of service or cost (which you will be required to demonstrate through quotations and receipts)
4.4 If you are looking to purchase goods or services from any contractor/supplier on this list then you must make a declaration in the register outlining:
4.5 Any contractor/supplier not included on the list at Appendix B can be used without the need for any declaration/further action. Appendix B represents the majority of the contractors/suppliers that we use, but does not include any of our contractors/suppliers that:
4.6 The approving officer will have an appropriate level of seniority, in accordance with our scheme of delegation. In making their decision, the approving officer will consider the level of potential reputational risk or any potential conflicts of interest that may arise by granting approval and, if granting approval, consider the steps required to mitigate against future conflicts of interest. This includes ensuring that the individual is not involved in any transactions with or decisions about the contractor/supplier in question on behalf of the organisation.
4.7 Riverside Scotland will maintain a clear audit trail of every approval to use any of our contractors listed at Appendix B. The total number of our people to use contractors and suppliers, including the reasons for approval, and confirmation that no advantage was gained due to an individual’s role within the organisation - will be formally reported annually to our Board.
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5.1 Our Rules require the Board to set our policy on payments and benefits and keep it under review. This policy has been approved by our Board and is based on the Model published by the SFHA. It is consistent with the requirements of our Codes of Conduct for Board and Committee members and for Staff. These Codes have been confirmed by the Scottish Housing Regulator as meeting their regulatory requirements.
5.2 This policy was adopted by our Board in July 2025. It will be reviewed not later than every 3 years.
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EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
HUMAN RESOURCES AND RECRUITMENT | ||
All entitlements arising from your contract of employment with us or one of our subsidiaries, including (but not restricted to):
| Yes | Any entitlement in the terms of your contract is always permitted without the need to record in the register of interests. There are Human Resource processes in place for this purpose. |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
Payment to a member of the [BOARD/COMMITTEE] for their role as a [BOARD/COMMITTEE] member, in accordance with the terms of their letter of appointment | No | [Such payments will only be permitted if they are in accordance with the conditions set out in Section 67(3) of the Charities and Trustees Investment (Scotland) Act 2005 (6)
The payment must be recorded in the register of interests within five days of the appointment being confirmed and the register must be kept up to date] |
All payments made in accordance with the terms of our expenses policy including:
| Yes | Entitlements in connection with your role as one of our people set out in our expenses policy are always permitted and do not need to be declared provided claims are made in accordance with our procedures. |
Provision of a loan by the organisation to one of our people | No | This is not permitted unless in connection with the contractual terms of employment. We cannot make any other loans to individuals. |
Redundancy or Voluntary severance payment to an employee | Yes | We can make redundancy payments to an employee in line with terms their contract Or We can make a voluntary severance payment to an employee which is outside the terms of their contract of employment provided:
|
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
An offer of employment (temporary or permanent) to someone who is closely connected to a member of staff | Yes | This is permitted as long as:
|
The offer of employment or contract for the provision of services (e.g. specialist advice) to someone who is, or has been in the last twelve months, a member of our Board or to anyone who is related to a member of the Board | No | This cannot be permitted. |
Appointment of one of our staff members to the Board | No | This cannot be permitted in accordance with the Rules of the organisation. |
Nominations to join the Board from people who are connected to a serving member. | No | This cannot be permitted in accordance with the Rules of the organisation. |
OUR PEOPLE AS TENANTS OR SERVICE USERS | ||
The offer of a tenancy or lease in one of our or any of our subsidiaries’ properties to one of our people or to someone closely connected to them. | Yes | This is permitted as long as
|
Where one of our people (or someone connected to one of our people) is a tenant and receives a repair, improvement or adaptation to their home | Yes | Repairs carried out in accordance with our policy do not need to be recorded. Adaptations must comply with our policy and be approved by the Managing Director. The adaptation should be recorded in the register of interests within five days of approval. Improvements must be carried out as part of an approved programme and in accordance with our policy. The person affected should declare their interest if/when the programme is being discussed and the improvement recorded in the register of interests within five days of completion |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
Where one of our people (or someone connected to one of our people) is a tenant and receives payment of a decoration allowance, tenant reward/incentive as part of an agreed scheme or prize. | Yes | Payment of decoration allowances or incentive/reward payments must be made in accordance with our policies and procedures and recorded in the register within five days of receipt. Prizes or awards in competitions open to all tenants in the same community (e.g. garden competitions) can only be given if the selection process for giving the award/prize has been carried out by someone who is independent. Receipt of the award and the circumstances surrounding it must be recorded in the register within five days of receipt. |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
TRAINING AND EVENTS | ||
Attendance at training events or seminars (e.g. SFHA Conferences) or openings/similar events hosted by other RSLs | Yes | There is no requirement to declare and record in the register of interests. |
The organisation paying for accommodation in connection with attendance at relevant conferences or events that you are attending on behalf of or in connection with your role with us or our subsidiaries | Yes | Accommodation that is part of a conference or training package does not need to be recorded in the register, but attendance will be recorded on the relevant individual training plan. Residential conferences are important in ensuring that our people have the necessary skills, knowledge and experience to make an effective contribution to our activities. |
Attendance by you at events to mark awards, achievements or other significant milestones relevant to our business. | Yes (where total cost does not exceed £500) | The Manging Director or Chair must approve attendance in advance, and subsequently reported to Board and will only do so if:
Where we ask you to represent us at such an event, this should be recorded in the register along with any associated costs (including travel, accommodation and the costs of attendance at the event) within five days of attendance. The total cost should not exceed £500 per person and we will make all arrangements in advance. Where costs would exceed £500, you will not be permitted to attend unless there is a clear, viable business case for attending. In such a case, specific approval of the Board would be required. |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
GIFTS AND HOSPITALITY | ||
Gifts received from tenants and external sources | Yes (not exceeding a value of £60) | Small gifts (e.g. a box of chocolates, pens, folders, paperweights, flowers) can be accepted if:
You should not normally accept other gifts and should decline any gifts with a value of more than £60 unless to do so would cause offence or otherwise damage our reputation. In these cases you must:
You should not regularly accept gifts from the same source and never more than twice from the same source within a 12 month period. The total cumulative value of gifts received from the same source over the course of a year must never exceed £60. You should also record any offers that you decline and the reasons for this, in the register within five days. |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
Cash received from tenants and external sources | No | You should not accept cash and should decline any gift of cash from a customer or other external source. In these cases you must: * Advise the donor that you are unable to accept a cash gift * Record the offer of gift and the action taken in the register within five days |
Gifts given from us to one of our people or received by one of our people from external sources to mark special occasions. | Yes (not exceeding a value of £100) | Gifts from the organisation to our people can be permitted in cases where it is to mark a special occasion or significant events including:
These must be recorded in the relevant register and the value of such gifts will not normally exceed £100. Please note, that this does not include collections by our people using their own personal funds to mark special occasions. These are always permitted with no requirement to declare. For staff, contractual terms may be in place that dictate the value of any gift upon retirement/long service. |
Hospitality associated with our business and that of its partners | Yes (when not exceeding a value of £60) | Modest hospitality, such as a sandwich lunch or networking event, is permitted and does not need to be recorded All other hospitality up to a value of £60 is permitted but must be recorded in the register, along with an estimation of the value of hospitality received, within five days of attendance. You should not accept invitations with a value that is greater than £60, unless you have prior approval from the MD or Board. The type of hospitality offered will also be taken into consideration, e.g. we will not normally accept invitations to sporting events, concerts, golf tournaments etc. In this case, the reason for acceptance must also be included in the register and countersigned by the Chair |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
Our people seeking donations from our contractors/suppliers when fundraising for charity | Yes | This is permitted provided:
We recognise our social responsibility and promote charity fundraising by the organisation and our people. We have a separate policy that sets out our approach to supporting other charities. |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
PROCURING GOODS/SERVICES | ||
Sale of our interest (whole or part) in a property to someone affected by this policy via LIFT, HomeBuy; Help to Buy or other LCHO scheme | Yes | This is permitted, provided:
|
The organisation entering into a contract with an organisation where one of our people, or someone connected to them, has significant control. | No (in almost all cases) | This is not permitted in almost all circumstances. We could only consider this where:
In such rare circumstances, the appointment would be recorded in the register along with details of the process followed. |
The purchase of land or other assets from anyone who is, or has been in the last twelve months, one of our people or who is connected to one of our people | No (in almost all cases) | This cannot be permitted in almost all cases. The only exception would be if you were referred to us under the Scottish Government’s Mortgage to Rent scheme, where this would be permitted provided:
|
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
The purchase of goods/services from our suppliers/contractors by one of our people | Yes | This should normally be avoided, and will only be potentially permitted if the procedure identified in Section 4 is followed |
6 Legislation.Gov.Uk (2005) Charities and Trustees Investment (Scotland) Act 2005 Section 67 (3)
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Information about how we procure works, goods and services, and our contracts with external providers can be found on our website; an up-to-date list of suppliers and contractors used by the organisation is published on our Freedom of Information pages quarterly.
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1.1 This policy is aimed at:
1.2 For the remainder of this policy the above will be referred to as “our people.”
1.3 We are a Registered Social Landlord (RSL) and a Scottish Charity. We are part of a sector that has a strong reputation for integrity and accountability: to the people we exist to help our Regulators, partners and funders. We must ensure that our organisation upholds its reputation and that of the sector. Our people cannot benefit inappropriately from their connection to us.
1.4 This policy describes the entitlements, payments and benefits that our people are able to receive. It also describes what is not permitted and the arrangements that we have in place to ensure that the requirements of this policy are observed.
1.5 Our Rules require that we have a policy dealing with payments and benefits (1). The Scottish Housing Regulator (SHR) requires us to have a policy that sets out what payments and benefits we permit and to ensure that these arrangements demonstrate transparency, honesty and propriety (2). We must ensure there is no justifiable public perception of impropriety. This policy is based on the SFHA’s Model Entitlements Payments and Benefits Policy, which the SHR have confirmed meets their regulatory requirements.
1.6 As we are a Scottish Charity, all of our Board Members must also ensure that they comply with the Office of the Scottish Charity Regulator (OSCR) guidance to Charity Trustees3 and charity legislation.
1.7 This Policy is intended to be a practical document that supports us in meeting all of the above requirements, ensuring that none of our people benefits (or is seen to benefit) improperly or inappropriately from their involvement with us, but also that they are not unfairly disadvantaged. We expect our people to act in good faith, and in applying the terms of the policy we will always take this into account.
1.8 As someone who is affected by this policy, you are personally responsible for ensuring that you are familiar with and comply with its terms (4).
1.9 At all times, we expect a common-sense approach to be applied to the interpretation and application of this policy. If you are unsure about anything relating to entitlements, payments and benefits you should consult with the Chair or Managing Director (if you are a member of the Board) or with your line manager (if you are a member of staff).
1.10 This policy covers:
1.11 The Code of Conduct is linked to this policy. Failure to comply with the terms of this policy may be regarded as a breach of the Code of Conduct.
1.12 You are also required to be familiar with and observe the terms of our Anti- Bribery and Corruption policy. We prohibit any attempt to induce the organisation or our people to offer preferential services or business terms and we will at all times comply with the Bribery Act 2010.
1.13 Our policies relating to the following are also relevant to this document and must be complied with at all times:
1 SFHA (2020) Charitable Model Rules, Rule 38
2 Scottish Housing Regulator (February 2019) Regulatory Framework Standard 5.4
3 Office of the Scottish Charity Regulator (2017) Guidance for Charity Trustees
4 Code of Conduct for [Board/Committee] Members; Code of Conduct for Staff
Please note that this list is not exhaustive and you are required to comply with all of our policies and procedures.
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2.1 In order to protect our reputation and demonstrate that we conduct our affairs with openness, honesty and integrity, we maintain a Register of Interests. You must record in this register any interests that you or someone connected to you (see Section 3) has which are relevant to our business and /or our activities. You will be required to maintain the accuracy of the interests you declare and to confirm annually that your entry is accurate and up to date.
2.2 Where you have an interest in any matter that is being discussed or considered, including at a meeting, you must declare your interest and play no part in the consideration, discussion and decision-making; you must withdraw from any part of a meeting where the interest arises and play no part in the discussion. Our Rules require that any Board member who has an interest in a matter that is being considered withdraws from all discussions and plays no part in decision-making (5).
2.3 The Codes of Conduct which our Board and Committee Members and staff are required to uphold contain requirements about Declaring Interests that you should comply with at all times.
2.4 An annual report will be made to our Board on the entitlements, payments, benefits that have been recorded in the Register(s) by our people.
2.5 The following are examples of the kind of interest that you must declare. Please note that this list is not exhaustive, and there may be other interests that you should also declare.
2.6 You should note that in some circumstances, declaration of an interest may not be sufficient, and that it may be necessary for the organisation to take additional measures to deal satisfactorily with the situation so as to protect the probity and reputations of both yourself and the organisation.
2.7 Many of the interests you will be required to declare can be classed as entitlements, payments or benefits.
2.8 As one of our people, you potentially could be offered benefits over and above that to which you are entitled (as a result of policy or contractual terms), such as gifts or hospitality from external parties. Such offers would be as a direct result of you being one of our people and cannot always be accepted. We require that any such offers are managed and recorded very carefully to ensure the highest levels of probity in our organisation. Our people should not benefit – or be seen to benefit – inappropriately from their involvement with us.
2.9 Apart from payments that our people are entitled to by contract, statute, policy or other agreement (e.g. salary, expenses), we will only make a payment to, or accept a payment from, someone affected by this policy in exceptional circumstances. Appendix A explains the payments we can and cannot make in more detail.
2.10 As we contribute to the economy(ies) of the area(s) we work in and we have commercial and business relationships with many different companies, contractors, suppliers and service providers, you must ensure that we are fully aware of any connection that you or someone you are close to (see section 3) has with any of these businesses or organisations.
2.11 Some entitlements, payments and benefits we can never permit, and others we have additional requirements or conditions that must be met before we can permit.
2.12 Appendix A lists the entitlements, payments and benefits that fall under this policy, and states:
5 SFHA (2020) Charitable Model Rules 2020 Rule 38
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3.1 Someone ‘closely connected’ to you includes members of your household, family members and other relatives and your friends.
3.2 As well as considering your own actions, you must be aware of the potential risk created by the actions of people to whom you are closely connected. Who you should consider, and our expectations of you to identify and declare such actions are outlined in Table A on page 7. If you are in any doubt about whether or not a declaration is required, you should consult the Chair, Managing Director or, for staff, your line manager.
Group | Required Response |
| We expect you to be aware of and declare any relevant actions of all people in your household. You must take steps to identify, declare and manage these. |
2. Partner, Relatives and friends This includes:
|
Where you have a close connection and are in regular contact with anyone within this group, we expect you to be aware of and declare any relevant actions. Under these circumstances, you must take steps to identify, declare and manage these actions.
Where you do not have a close connection and regular contact with someone in this group, we do not expect you to be aware of or to go to unreasonable lengths to identify any relevant actions. However, if you happen to become aware of relevant actions by such individuals, then these should be declared and managed as soon as possible. |
3.3 The following are the relevant actions /involvement by those to whom you are closely connected that you should consider, declare and manage as per our expectations outlined in Table A (please be aware that this list is not exhaustive or exclusive):
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4.1 In order to help us maintain our excellent reputation, where possible you should avoid using the organisation’s contractors/suppliers for your own personal purposes. We have made a list available to all of our people which outlines the contractors and suppliers that fall under the terms of this policy. This is included at Appendix B.
4.2 We recognise that there could be certain circumstances where it might not be possible for you to avoid the use of all the contractors/suppliers on this list, such as where market conditions in your local area make it difficult to obtain a reasonable selection of potential contractors or suppliers. Under such circumstances you could be permitted to use those contractors/suppliers
outlined at Appendix B, provided you are able to demonstrate that you received no preferential treatment in terms of price, quality or any other aspect of service delivery due to your involvement with us.
4.3 Approval to use those contractors listed at Appendix B is at the discretion of the approving officer (in accordance with our scheme of delegation). In order to be granted approval, you will be required to demonstrate that there is no reasonable alternative contractor/supplier providing the service required in your local area, and that you will receive no preferential treatment in terms of service or cost (which you will be required to demonstrate through quotations and receipts)
4.4 If you are looking to purchase goods or services from any contractor/supplier on this list then you must make a declaration in the register outlining:
4.5 Any contractor/supplier not included on the list at Appendix B can be used without the need for any declaration/further action. Appendix B represents the majority of the contractors/suppliers that we use, but does not include any of our contractors/suppliers that:
4.6 The approving officer will have an appropriate level of seniority, in accordance with our scheme of delegation. In making their decision, the approving officer will consider the level of potential reputational risk or any potential conflicts of interest that may arise by granting approval and, if granting approval, consider the steps required to mitigate against future conflicts of interest. This includes ensuring that the individual is not involved in any transactions with or decisions about the contractor/supplier in question on behalf of the organisation.
4.7 Riverside Scotland will maintain a clear audit trail of every approval to use any of our contractors listed at Appendix B. The total number of our people to use contractors and suppliers, including the reasons for approval, and confirmation that no advantage was gained due to an individual’s role within the organisation - will be formally reported annually to our Board.
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5.1 Our Rules require the Board to set our policy on payments and benefits and keep it under review. This policy has been approved by our Board and is based on the Model published by the SFHA. It is consistent with the requirements of our Codes of Conduct for Board and Committee members and for Staff. These Codes have been confirmed by the Scottish Housing Regulator as meeting their regulatory requirements.
5.2 This policy was adopted by our Board in July 2025. It will be reviewed not later than every 3 years.
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EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
HUMAN RESOURCES AND RECRUITMENT | ||
All entitlements arising from your contract of employment with us or one of our subsidiaries, including (but not restricted to):
| Yes | Any entitlement in the terms of your contract is always permitted without the need to record in the register of interests. There are Human Resource processes in place for this purpose. |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
Payment to a member of the [BOARD/COMMITTEE] for their role as a [BOARD/COMMITTEE] member, in accordance with the terms of their letter of appointment | No | [Such payments will only be permitted if they are in accordance with the conditions set out in Section 67(3) of the Charities and Trustees Investment (Scotland) Act 2005 (6)
The payment must be recorded in the register of interests within five days of the appointment being confirmed and the register must be kept up to date] |
All payments made in accordance with the terms of our expenses policy including:
| Yes | Entitlements in connection with your role as one of our people set out in our expenses policy are always permitted and do not need to be declared provided claims are made in accordance with our procedures. |
Provision of a loan by the organisation to one of our people | No | This is not permitted unless in connection with the contractual terms of employment. We cannot make any other loans to individuals. |
Redundancy or Voluntary severance payment to an employee | Yes | We can make redundancy payments to an employee in line with terms their contract Or We can make a voluntary severance payment to an employee which is outside the terms of their contract of employment provided:
|
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
An offer of employment (temporary or permanent) to someone who is closely connected to a member of staff | Yes | This is permitted as long as:
|
The offer of employment or contract for the provision of services (e.g. specialist advice) to someone who is, or has been in the last twelve months, a member of our Board or to anyone who is related to a member of the Board | No | This cannot be permitted. |
Appointment of one of our staff members to the Board | No | This cannot be permitted in accordance with the Rules of the organisation. |
Nominations to join the Board from people who are connected to a serving member. | No | This cannot be permitted in accordance with the Rules of the organisation. |
OUR PEOPLE AS TENANTS OR SERVICE USERS | ||
The offer of a tenancy or lease in one of our or any of our subsidiaries’ properties to one of our people or to someone closely connected to them. | Yes | This is permitted as long as
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Where one of our people (or someone connected to one of our people) is a tenant and receives a repair, improvement or adaptation to their home | Yes | Repairs carried out in accordance with our policy do not need to be recorded. Adaptations must comply with our policy and be approved by the Managing Director. The adaptation should be recorded in the register of interests within five days of approval. Improvements must be carried out as part of an approved programme and in accordance with our policy. The person affected should declare their interest if/when the programme is being discussed and the improvement recorded in the register of interests within five days of completion |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
Where one of our people (or someone connected to one of our people) is a tenant and receives payment of a decoration allowance, tenant reward/incentive as part of an agreed scheme or prize. | Yes | Payment of decoration allowances or incentive/reward payments must be made in accordance with our policies and procedures and recorded in the register within five days of receipt. Prizes or awards in competitions open to all tenants in the same community (e.g. garden competitions) can only be given if the selection process for giving the award/prize has been carried out by someone who is independent. Receipt of the award and the circumstances surrounding it must be recorded in the register within five days of receipt. |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
TRAINING AND EVENTS | ||
Attendance at training events or seminars (e.g. SFHA Conferences) or openings/similar events hosted by other RSLs | Yes | There is no requirement to declare and record in the register of interests. |
The organisation paying for accommodation in connection with attendance at relevant conferences or events that you are attending on behalf of or in connection with your role with us or our subsidiaries | Yes | Accommodation that is part of a conference or training package does not need to be recorded in the register, but attendance will be recorded on the relevant individual training plan. Residential conferences are important in ensuring that our people have the necessary skills, knowledge and experience to make an effective contribution to our activities. |
Attendance by you at events to mark awards, achievements or other significant milestones relevant to our business. | Yes (where total cost does not exceed £500) | The Manging Director or Chair must approve attendance in advance, and subsequently reported to Board and will only do so if:
Where we ask you to represent us at such an event, this should be recorded in the register along with any associated costs (including travel, accommodation and the costs of attendance at the event) within five days of attendance. The total cost should not exceed £500 per person and we will make all arrangements in advance. Where costs would exceed £500, you will not be permitted to attend unless there is a clear, viable business case for attending. In such a case, specific approval of the Board would be required. |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
GIFTS AND HOSPITALITY | ||
Gifts received from tenants and external sources | Yes (not exceeding a value of £60) | Small gifts (e.g. a box of chocolates, pens, folders, paperweights, flowers) can be accepted if:
You should not normally accept other gifts and should decline any gifts with a value of more than £60 unless to do so would cause offence or otherwise damage our reputation. In these cases you must:
You should not regularly accept gifts from the same source and never more than twice from the same source within a 12 month period. The total cumulative value of gifts received from the same source over the course of a year must never exceed £60. You should also record any offers that you decline and the reasons for this, in the register within five days. |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
Cash received from tenants and external sources | No | You should not accept cash and should decline any gift of cash from a customer or other external source. In these cases you must: * Advise the donor that you are unable to accept a cash gift * Record the offer of gift and the action taken in the register within five days |
Gifts given from us to one of our people or received by one of our people from external sources to mark special occasions. | Yes (not exceeding a value of £100) | Gifts from the organisation to our people can be permitted in cases where it is to mark a special occasion or significant events including:
These must be recorded in the relevant register and the value of such gifts will not normally exceed £100. Please note, that this does not include collections by our people using their own personal funds to mark special occasions. These are always permitted with no requirement to declare. For staff, contractual terms may be in place that dictate the value of any gift upon retirement/long service. |
Hospitality associated with our business and that of its partners | Yes (when not exceeding a value of £60) | Modest hospitality, such as a sandwich lunch or networking event, is permitted and does not need to be recorded All other hospitality up to a value of £60 is permitted but must be recorded in the register, along with an estimation of the value of hospitality received, within five days of attendance. You should not accept invitations with a value that is greater than £60, unless you have prior approval from the MD or Board. The type of hospitality offered will also be taken into consideration, e.g. we will not normally accept invitations to sporting events, concerts, golf tournaments etc. In this case, the reason for acceptance must also be included in the register and countersigned by the Chair |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
Our people seeking donations from our contractors/suppliers when fundraising for charity | Yes | This is permitted provided:
We recognise our social responsibility and promote charity fundraising by the organisation and our people. We have a separate policy that sets out our approach to supporting other charities. |
EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
PROCURING GOODS/SERVICES | ||
Sale of our interest (whole or part) in a property to someone affected by this policy via LIFT, HomeBuy; Help to Buy or other LCHO scheme | Yes | This is permitted, provided:
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The organisation entering into a contract with an organisation where one of our people, or someone connected to them, has significant control. | No (in almost all cases) | This is not permitted in almost all circumstances. We could only consider this where:
In such rare circumstances, the appointment would be recorded in the register along with details of the process followed. |
The purchase of land or other assets from anyone who is, or has been in the last twelve months, one of our people or who is connected to one of our people | No (in almost all cases) | This cannot be permitted in almost all cases. The only exception would be if you were referred to us under the Scottish Government’s Mortgage to Rent scheme, where this would be permitted provided:
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EXAMPLE | CAN THIS BE PERMITTED? | FURTHER ACTION NECESSARY BEFORE THIS WILL BE PERMITTED? |
The purchase of goods/services from our suppliers/contractors by one of our people | Yes | This should normally be avoided, and will only be potentially permitted if the procedure identified in Section 4 is followed |
6 Legislation.Gov.Uk (2005) Charities and Trustees Investment (Scotland) Act 2005 Section 67 (3)
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Information about how we procure works, goods and services, and our contracts with external providers can be found on our website; an up-to-date list of suppliers and contractors used by the organisation is published on our Freedom of Information pages quarterly.
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