I think the fundamental issue here is this. It's very important—and, as I said, this is genuinely a general point and in no way aimed at any particular incident—that we don't stop public officials who have acquired particular knowledge of particular things from deploying that in the public service. One of the requirements is for people to be able to understand that if I may have acquired knowledge in a private capacity, I should not hold back from deploying that knowledge for a public service.
What I have to remember all the time in terms of conflict of interest is that I must be using that in the public service and not using it to advance a private interest of mine or of somebody with whom I'm connected. If there's an example of a particular action that has troubled you, what you have to do is say to yourself, “What am I troubled about? Is it that I think a person was not serving the public and they were acting in a way that would serve themselves, or is it a bit more amorphous? Is it just that I think the boundaries may not be clear to observers?”
In chapter 2 of our code of conduct, we have a principle in relation to relevance that looks at whether a reasonable observer might perceive that you are actuated by a particular interest. Again, with the kind of example that you've raised, I would expect that to be a relevant principles-based factor: Maybe you don't have an interest, but might a reasonable observer be perturbed to think that you might have an interest?
Have I helped you at all, despite not answering exactly what you wanted me to?
