I am informed by NAMA that all of its officers are provided with a copy of the Code of Practice – Conduct of Officers of NAMA when they are assigned to NAMA and they are required to sign an undertaking that they have read, understood and will comply with it. This document, which is published on www.nama.ie, sets out in detail the obligations of officers of NAMA with respect to confidentiality and conflicts of interest including statutory obligations regarding confidentiality and use of information including their obligation under the Official Secrets Act 1963. The document is reviewed annually by the Board of NAMA and circulated annually to officers of NAMA, who are required to sign an undertaking on each occasion that they have read, understood and will comply with it.
The Code was first approved by the Minister for Finance on 5 July 2010 and any changes made as a result of the Board's annual review are also subject to the Minister's approval. In addition, those officers of NAMA who are holders of designated positions of employment under the Ethics in Public Office Act 1995 as amended by the Standards in Public Office Act 2001 ("the Ethics Acts") are notified in January each year of their obligations under the Ethics Acts. NAMA requires its entire staff to complete a disclosure under Section 42 of the NAMA Act outlining all assets, liabilities and interests which they hold. Each employee is also required to inform the CEO of NAMA of any changes to their disclosure and to immediately inform the CEO of any matter that could raise a question about their suitability to act (or continue to act) as an officer of NAMA or that could result in an actual or potential conflict of interest with respect to their duties or obligations as an officer of NAMA.
