Conflicts of Interest

Dealing properly with conflicts of interest is vital to securing public confidence in GP commissioning.  The consequences of failing to do so could have significant implications for clinical commissioning groups.  The Hillingdon CCG Conflicts Of Interest Policy sets out the issues surrounding this.

The key stages of dealing with conflicts of interest are:

Recognising when conflicts of interest arise

Conflicts of interest may arise where an individual’s (or a connected person’s) personal interests and/or loyalties conflict with those of the CCG.  It is for each individual to exercise their judgement in deciding whether to declare any interests that may be construed as a conflict. Individuals can seek guidance from the Company Secretary about when to do so, but it is always best to declare an interest if in doubt.

Declaring conflicts of interest 

All Governing Body members and senior managers are required to declare any relevant and material interests, using this form. Interests to be declared include:

  • Any directorships of companies likely to be engaged with the business of the CCG;
  • Previous or current employment or consultancy positions;
  • Voluntary or remunerated positions, such as trusteeship, local authority positions, other public positions;
  • Membership of professional bodies or mutual support organisations;
  • Investments in unlisted companies, partnerships and other forms of business, major shareholdings and beneficial interests;
  • Gifts or hospitality offered by external bodies and whether this was declined or accepted in the last twelve months.

The declaration of interests form must be completed prior to appointment, then updated at least annually and when any material changes occur.

Each CCG maintains a register of interests.

Acting appropriately in response to conflicts of interest

Visibility of interests is vital.  Once an interest is out in the open, others can give a perspective to the significance of the issue.  Declaration by itself shows good faith and therefore serves to protect the person declaring it.  However declaring an interest either by entering it on the register or announcing it in a meeting will often not be sufficient.  There remains an on-going responsibility for any decision-maker to consider issues as they come up and to decide whether they present them with a conflict.  Details of how to respond to conflicts are included in the policy.

Gifts, Hospitality and the Bribery Act

The CCG’s policy is that any gift or offer of a gift/hospitality which is perceived to exceed £25 must be declared and entered onto the Gifts and Hospitality Register.  Any gift or offer of a gift which is perceived to exceed £100 can only be accepted if prior authorisation has been received from the Chair or the Accountable Officer.

Gifts or hospitality can be perceived as being a bribe.  Under the Bribery Act it is a criminal offence to pay or to receive bribes.  Gifts or hospitality are unlikely to breach the Act if they are:

  • Reasonable and proportionate;
  • Have a bona fide business purpose;
  • Are not intended to influence.

However, unduly lavish hospitality could give rise to inference of impropriety.

For more information about Conflicts of Interest or Gifts/Hospitality please contact Mel Brown, Head of Governance on mel.brown2@nhs.net

Policies

Conflict of interest policy: download

Gifts policy: download