22

We asked the Department how it manages the risk of fraud when its commercial staff...

Conclusion
We asked the Department how it manages the risk of fraud when its commercial staff move to roles with its suppliers.59 The Department explained it follows best government practice around business appointment rules. This includes conflict of interest declarations and periods where staff are ‘debarred’ from taking jobs with suppliers.60 It also told us that officials taking jobs with suppliers can help to keep valuable skills within the supply chain, which the Department will need to achieve the Defence Industrial Strategy.61 The NAO has previously reported that there are inconsistencies in how different parts of the Department manage conflicts of interest, for example not all areas require annual disclosures for all staff or have an easily accessible central disclosure system.62 59 Q 47 60 Qq 47-48 61 Q 47 62 C&AG’s Report , Managing conflicts of interest, Session 2024–25, HC 307, 22 November 2024, Figure 4 and pp 26-27 15 3 Counter-fraud structure and capability Siloed counter-fraud and police teams