In Episode 1, we set out what a conflict of interest is, and why perception matters as much as formal compliance.
This second article looks at a specific case, not to reach conclusions, but to set out a clear and verifiable timeline of events.
Election and Initial PeriodCouncillor Sally Tomlinson was elected in May 2024. Under the Localism Act 2011, Disclosable Pecuniary Interests (DPIs) must be registered within 28 days of election.
No declaration relating to Council contracts was registered within that 28-day period. The interest was subsequently registered on 11 November 2024.
Governance: Foundation or Ceiling? A Disclosable Pecuniary Interest must be registered within 28 days of election. In this case, no such interest relating to Council contracts was registered within that period. The interest was subsequently registered on 11 November 2024. The question this raises is not simply whether the legal requirement was eventually met, but whether governance is being treated as:
a minimum threshold to be reached, or
a foundation on which higher standards of transparency are expected
Nature of the Interest Councillor Tomlinson is Chair and Trustee of Age Concern Solihull Ltd, which trades publicly as Age UK Solihull. The organisation holds two contracts with Solihull Metropolitan Borough Council:
Community Advice Hubs – £679,402 per annum
Older People’s Specialist Provision – £150,053 per annum
Both contracts ran until 31 March 2026.Now September.
These arrangements place the councillor in a position where a Disclosable Pecuniary Interest arises in relation to a provider delivering Council-commissioned services.
Scrutiny Context At the Health and Adult Social Care Scrutiny Board of which (not withstanding the Adult Social Care requrements of the contacts) Ciir Tomlinson is a member meeting on 16 September 2025, the matter was raised through a deputation. During that meeting, it was confirmed that the Disclosable Pecuniary Interest had been declared and registered. It was also stated that a declaration does not need to be made at every meeting unless a matter directly relates to that interest. The minutes further record that the councillor did not consider any agenda items at that meeting to be affected in a way that required a declaration or withdrawal.
Observations The timeline above raises a number of points which are matters of public record:
A declaration was not registered within the statutory 28-day period following election
The declaration was subsequently made
The councillor holds a governance role in an organisation delivering Council-funded services
A position has been set out in Scrutiny regarding when declarations are considered necessary
These are not conclusions, but contextual facts.
Why This Matters Conflicts of interest are not solely about whether a rule has been followed. They are also about:
transparency
consistency
and public confidence in decision-making
Even where formal requirements are met, the way interests are declared and discussed can influence how decisions are perceived.
Open Invitation This article is intended to present a factual timeline in the interests of transparency. If Councillor Tomlinson, or any Council officer, wishes to provide clarification or additional context, that response will be published in full.
Episode 3 will look at how declarations of interest are advised, interpreted, and applied in practice.
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