Pan-Island Commissioner for Standards Annual Report 2025

Commissioner for Standards Annual Report 2025, Jersey

R.22/2026

Contents

 1  Introduction................................................................................................................................. 3

2. Functions of the Commissioner.............................................................................................. 3
3. Complaints overview................................................................................................................ 4
4. Investigation Reports................................................................................................................5
5. Other work...................................................................................................................................6
6. Resources.....................................................................................................................................7
7. Acknowledgements ..................................................................................................................7

1 Introduction

1. This  is  my  third  report  since  taking  up  the  role  of  Pan-Island  Commissioner  for Standards in March 2023.
2. This report is submitted in accordance with Part 3 Paragraph 12 of the Commissioner for Standards (Jersey) Law 2017. It provides information on complaints received in Jersey from 1st January 2025 to 31st December 2025 including analysis of the number  of complaints, summary of completed investigations, resources associated with the Office and other work carried out during this year.

2 Functions of the Commissioner

1. The functions of the Commissioner are set out in Part 3 Paragraph 9 of the Commissioner for Standards (Jersey) Law 2017 and may be summarised as follows:

to investigate a complaint to the Commissioner that, at a relevant time, a breach of a code as in force at that time occurred;

to initiate an investigation if the Commissioner believes that, at a relevant time, a breach of a code as in force at that time may have occurred;

to report to the PPC on the outcome of any investigation;

on the Commissioner's own initiative or, if requested by the PPC, to give advice on any matter relating to standards of conduct of elected members of the States or standards of conduct and practice of Ministers and Assistant Ministers, including proposals to change a code;

if requested by the Chief Minister, to give advice on any matter relating to standards of conduct and practice of Ministers and Assistant Ministers, including proposals to change the code referred to in paragraph (b) of the definition "code".

2. Part 3 Paragraph 11 of the Commissioner for Standards (Jersey) Law 2017 states that "The Commissioner shall make and publish a statement of the manner in which he or she proposes to discharge his or her functions under this Law and any other enactment".
3. In accordance with the 2017 legislation, all investigations are carried out in accordance with the processes contained in the Statement.

3 Complaints Overview

1. A total of 19 complaints were received during the 2025 reporting period up to 31 December 2025. Of the 19 complaints received, 6 were admissible (32%), while 13 complaints were inadmissible (68%).

Table 1. Complaints overview 2025

2. Of the 19 complaints received, 95% were submitted by members of the public against Members or Ministers. One complaint (5%) was submitted by a Member against another Member.
3. In total, I considered 95 allegations contained within the 19 complaints received. Of these,  4  complaints  were  against  Ministers  (comprising  8  allegations)  and  16 complaints were against Members (comprising 87 allegations).
4. One  investigation  was  temporarily  suspended.  An  update  will  be  presented,  in summary form, in next year's Annual Report.
5. I  successfully  carried  out  preliminary  assessments  of  all  complaints  and  full investigations through remote interviewing, obtaining legal advice where necessary.

4

4 Investigation Report Summaries

1. I conducted 3 investigations this year resulting in 2 reports with one ongoing. One report related to four complaints into the same matter made against Deputy Philip Ozouf . One report was related to a complaint made by a Member ( Deputy Mézec ) against another Member ( Deputy Warr ), and one has been suspended and will be included in next year's report.
2. Deputy Philip Ozouf

Four complaints I received concerned a traffic incident on 2 November 2024, when Deputy Ozouf was stopped by police for driving at 31mph in a 15mph zone and without displaying a valid motor insurance disc. He was issued with three summonses to attend a Parish Hall Enquiry,  which  he  failed  to  attend,  and  the  matter  was  subsequently  referred  to  the Magistrate's Court. On 11 February 2025, he was fined £575.

Complaints were made alleging breaches of paragraphs 2, 3, 4 and 5 of the Code of Conduct. Following an initial lack of engagement, an investigation commenced in March 2025, and Deputy Ozouf was interviewed in May 2025. He did not dispute the facts, acknowledged  his  failures,  and  offered  apologies  to  both  the  court  and  the  States Assembly.

While Deputy Ozouf cited mitigating personal circumstances, elected Members remain accountable for complying with the law and engaging appropriately with formal processes. On the evidence, it was concluded that Deputy Ozouf breached paragraphs 2, 3, 4 and 5 of the Code of Conduct

3. Deputy David Warr This report concerns an investigation into a complaint made by Deputy Sam Mézec on 12 August  2025  against   Deputy  David   Warr .  The  complaint  alleged  that   Deputy   Warr

breached Parts 3 and 5 of the Code of Conduct by publishing statements said to be untrue and by making repeated claims about Deputy Mézec 's voting record that were alleged to be disrespectful and damaging to his reputation.

Deputy Warr stated that he believed his comments to be accurate and explained that his LinkedIn post was intended to highlight what he saw as a change in Deputy Mézec 's position during the Bridging Island Plan debates in 2021–22, particularly in relation to rezoning greenfield sites.

The investigation concluded that Deputy Warr 's comments amounted to political discourse rather than knowingly false statements. In light of the enhanced protection afforded to political expression under Article 10 of the European Convention on Human Rights, and noting that the wording was amended following challenge and that both Members had equal opportunity to respond, it was determined that the Code of Conduct had not been breached. Accordingly, it was found that Deputy Warr did not breach Parts 3 or 5 of the Code of Conduct.

5 Other Work

1. In addition to considering all in-year complaints and carrying out investigations, I also  attended  meetings,  provided  advice  to  members  when  requested  and contributed to internal and external consultations.
2. In  May  2025,  I  contributed  to  the  PPC's  Code  of  Conduct  review  and  attended sessions in Jersey with Members and the States Greffier.
3. Throughout the year, I complied with the Code governing my conduct and registered all relevant financial and other interests and all hospitality received.
4. I was provided funding through Jersey and Guernsey to undertake the executive LSE course: AI: Law, Policy and Governance.

Overview and relevance of AI: Law, Policy and Governance course

5. The  LSE  course  is  relevant  to  the  Commissioner  for  Standards  role  as  artificial intelligence  is  increasingly  shaping  how  public  officeholders  communicate,  make decisions,  and  discharge  their  responsibilities.  As  AI-enabled  tools  are  adopted across  the  public  sector,  questions  of  accountability,  transparency,  and  ethical judgment  which  are  core  to  standards  oversight  are  becoming  more complex. Drawing on international frameworks such as the OECD AI Principles and developments under the EU AI Act, it supports alignment with global best practice.
6. Existing Codes of Conduct were largely developed for human decision-making and do not yet fully address the ethical risks associated with automated or AI-assisted systems, including opacity, bias, scale of harm, and the delegation of judgment. The course  helps  to  equip  a  Commissioner  with  the  conceptual  and  regulatory frameworks needed to interpret and apply established principles such as integrity, accountability, openness, and leadership in an AI-mediated context, and to advise on proportionate updates to standards frameworks.
7. AI also presents new challenges for standards investigations, including assessing the authenticity  of  evidence,  determining  authorship  and  intent,  and  distinguishing between negligence, recklessness, and misuse where AI tools are involved.
8. The  course  strengthens  the  ability  of  the  Commissioner  to  evaluate  AI-related evidence fairly, safeguard procedural justice, and maintain confidence in investigative findings.

6 Resources

6.1 The Commissioner is paid a daily rate of £500 per day. Table 2 shows a breakdown of the costs for 2025.

Table 2. Commissioner's Pay Jersey 2025

6.3

Total cost for investigation, casework and report writing was £13,000. 6.4

The Commissioner's pay in 2025 was similar to the previous year. 6.5

Administrative  costs  relate  to  general  meetings,  letters  of  advice,  emails,  responding  to consultations,  website,  WorkPro  (complaints  software),  and  other  administrative  issues arising.

7 Acknowledgements

I  am  grateful  to  all  of  those  who  have  provided  me  with  assistance  and  support  over  the past  year  including  Lisa   Hart ,  Will   Millow ,  Casey  Tucker  and  Eva  Patterson.  I  have  also been  fortunate  to  have  had  support  from  Standards  Commissioners  across  the  UK  for which I am extremely grateful.

Dr Melissa McCullough Pan-Island Commissioner for Standards 30 January 2026

Commissioner for Standards Annual Report, Jersey 2025

The Commissioner for Standards can be contacted by email at: [email protected]