Standards of Business Conduct and Registers of Interest

Conflicts of Interest

What is a conflict of interest?

A conflict of interest could be defined as any situation in which an individual’s personal interests or responsibilities may, or may appear to, influence their decision-making.

Why is it important to manage conflicts of interest?

NHS West Norfolk CCG is responsible for commissioning healthcare services to improve the health and wellbeing of people who live here. It decides which services the people of West Norfolk most need and pays local hospitals and other healthcare providers to provide these services. In addition, it holds the healthcare providers to account to ensure that they provide the services paid for. Therefore, is important to manage conflicts of interest to:

  • Protect the integrity of the CCG’s decision-making processes and decisions
  • Avoid improper influence and prevent fraud
  • Ensure decisions are legal and can be defended in the case of a  challenge
  • Fulfil its duty to look after public money
  • Ensure honesty, fairness, transparency and equality in the way we spend money
  • Ensure our patients receive the best possible care

The WNCCG managing conflicts of interest policy can be found within the Standards of Behaviour Policy

How does West Norfolk CCG manage conflicts of interest?

West Norfolk CCG takes its responsibility to manage conflicts of interest seriously and detials the conflict of interests policy within the Standards of Business Conduct. This policy sets out how West Norfolk CCG Governing Body members, officers, staff, members and clinical leads should behave in their role at West Norfolk CCG. It also sets out the steps and measures that the CCG takes to manage conflicts of interest. An example of this is that the policy requires those people referred to above to declare any and all interests which may be, or may lead to, a conflict of interest.

The most common types of conflicts of interest include:

  • Financial interests - where an individual may get a direct financial benefit from the consequences of a commissioning decision

  • Non-financial professional interests - where an individual may obtain professional benefit from the consequences of a commissioning decision

  • Non-financial personal interests - where and individual may benefit personally in ways which are not directly linked to their professional career and do not give rise to a direct financial benefit.

  • Indirect interests - where an individual has a close association with an individual who has one of the three interests listed above.

 

Conflict of Interest Guardian

To ensure compliance with the CCG’s Conflict of Interest responsibilities Hilary De Lyon  has the additional role of Conflict of Interests Guardian. This role is to further strengthen scrutiny and transparency of CCGs’ decision-making processes, supported by Heather Farley, Head of Corporate Affairs, who has responsibility for the day-to-day management of conflicts of interest matters and queries.

 The Conflicts of Interest Guardian role includes:

  • Acting as a conduit for GP practice staff, members of the public and healthcare professionals who have any concerns with regards to conflicts of interest;
  • Being a safe point of contact for employees or workers of the CCG to raise any concerns in relation to this policy;
  • Supporting the rigorous application of conflict of interest principles and policies;
  • Providing independent advice and judgment where there is any doubt about how to apply conflicts of interest policies and principles in an individual situation;
  • Providing advice on minimising the risks of conflicts of interest.

 Hilary De Lyon can be contacted via the following email address hilary.delyon [at] nhs.net (hilary.delyon [at] nhs.net)

 

What happens when a conflict of interest is identified?

When a conflict of interest is identified it should always be disclosed, as openness and transparency allows for conflicts and potential conflicts of interest to be assessed and managed. This includes publishing all conflicts of interest on a Register of Interests (see below). The CCG manages the risk of improper or undue influence carefully in a variety of ways, including excluding that person from any decision-making in relation to their conflict. All documents on this page are available on request from the WNCCG office. There have been no breaches of the CCG's policy on conflicts of interest management.

Procurement Register

Procurement decisions can be viewed in the WNCCG Procurement Register.

Gifts and Hospitality Register 

Gifts and Hospitality declarations can be viewed at: 

WNCCG Gifts and Hospitality Register 2016-2017

WNCCG Gifts and Hospitality Regsiter 2017-2018 

West Norfolk CCG Registers of Interests