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30 March 2020
fyi-request-12397-2cff [email address]
Kia ora Matthew The information you requested - CAS-117010-C7J4X1
Thank you for your email dated 6 March 2020 requesting information about Sir Michael Cullen.
I have attached a copy of AT’s Declaration of Interest Policy. This policy applies to AT Directors
and employees and representatives. The policy outlines AT’s expectations and how AT manages
conflicts of interest. Conflicts of interest are recorded in the Register. During AT Board or
Commit ee discussions, where conflicts arise, Directors raise these and excuse themselves from
the discussion or remove themselves from the decision-making process as appropriate.
Directors are not provided formal training in identification and managing conflicts of interest.
However, a review of the Directors’ Interest Register is a standing agenda item at each Board and
Commit ee meeting and Directors are expected, and do, provide updates on any conflicts of
interest that are then recorded in the Register.
On 23 October 2018, Sir Michael disclosed his role as an informal advisor on the Light Rail Project
at the Customer & Innovation Commit ee Meeting and this is recorded in the minutes for that
The Directors’ Interests Register was updated to reflect this interest, and this was recorded in:
• the Register for the meeting of the Finance, Capital and Risk Commit ee on 6 November 2018
• the Auckland Transport (AT) Board meeting on 13 November 2018
• at each Board or Commit ee meeting onwards from 13 November 2018
On 19 November 2019 Sir Michael notified the Customer and Innovation Commit ee that his role
as an informal advisor had ceased and this is recorded in the minutes of that meeting.
Your request for an opinion regarding whether ‘such activity constitute a conflict of interest with
their roles at AT and/or CRLL?’ is refused under section 17 (e) of the Local Government and
Official Information and Meetings Act 1987 (LGOIMA) as the information doesn’t exist. As
explained in our email dated 20 March 2020 there is no obligation under LGOIMA to create
information that doesn’t exist.
Should you believe that we have not dealt with your request appropriately, you are able to make a
complaint to the Office of the Ombudsman and seek an investigation and review in regard to this
Andrew Downie Governance Lead