1. Employees
Standards of Business Conduct - incorporating statutory guidance on conflicts of interest
How does it affect me?
This document is intended to be a brief overview of the Standards of Business Conduct. It is not a substitute for reading the full policy
September 2016

2. Employees This brief is relevant to: Full and part time staff
Any staff on sessional or short term contracts
Students, trainees and apprentices
Agency staff
Seconded staff
Self-employed consultants or other individuals working for the CCG under a contract for services
September 2016

3. Employees – what it means for you Declaring interests
You must declare any interest that may be perceived as a conflict with your work for the CCG.
You need to complete a declaration of interests form and submit to Rod While This form must be completed, even if you have no interests to declare.
After this if there are any changes in your circumstances, you should complete a new form and send to the Head of Corporate Governance as soon as possible.
Every six months you will be asked to confirm that the details we have on file are correct and up to date.
If you are in doubt as to whether to declare an interest, please discuss with your manager or Rod While. As a general rule if you are in doubt, it is better to declare than not to.
The CCG is required to publish a register of all declarations of interest in order be transparent about its business.
September 2016

4. Employees – what it means for you Conflicts of Interest Guardian
The CCG must have a Conflicts of Interest Guardian in place as a safe point of contact for people to raise any concerns about conflicts of interest.
Herts Valleys CCG’s Conflicts of Interest Guardian is Paul Smith, Board lay member and chair of the Audit Committee.
Paul can be contacted at
September 2016

5. Employees – what it means for you Secondary employment
Staff must make the CCG aware if they are employed or engaged in, or wish to be employed or engage in, any employment or consultancy work in addition to their work with the CCG. If you are undertaking consultancy or other work in your own time, you must make the CCG aware of this.
This is in order to make sure that the CCG is aware of and can manage any conflicts of interest.
You must obtain prior permission from a director to engage in secondary employment, and the CCG reserves the right to refuse permission where it believes a conflict will arise which cannot be effectively managed.
September 2016

6. Employees – what it means for you Gifts
There are a number changes to the conditions on which gifts should be accepted or declined
You should not accept gifts from providers / contractors or those attempting to gain business from the CCG. You should declare the offer, even though you have not accepted it. Forms should be sent to Rod While.
However it is OK to accept a small (value of less than £10) gift of stationary such as a pen or calendar at a meeting and there is no need to declare this.
It is also OK to accept a small gift (value of less than £10) as a token of appreciation from staff or a patient and there is no need to declare this.
Any personal gift of cash or vouchers whilst in a capacity of working for or representing the CCG must always be declined and declared. If this is sent in the post and you wish to donate to charity, this is possible but please discuss with Rod While.
September 2016

7. Employees – what it means for you Hospitality
Modest hospitality provided in normal and reasonable circumstances is OK, but it should be on a similar scale to that which the CCG might offer in similar circumstances
Hospitality offered by suppliers or contractors linked (currently or prospectively) to the CCG’s business (whether or not accepted) should be declared and recorded.
In the case of modest hospitality offered by pharmaceutical companies, the CCG requires clarity on what products are to be promoted. If the product(s) has been refused for use in west Herts, the offer should be declined. Advice should be sought from the Pharmacy and Medicines Optimisation Team where appropriate.
Offers of hospitality which go beyond modest or of a type that the CCG itself might offer, should be politely refused.
An example is where the value of hospitality is clearly more than £25 per head
Another example is offers of overseas travel and accommodation
Even though these offers should be declined, you should declare the offer
September 2016

8. Employees – what it means for you Commercial sponsorship
All offers of commercial sponsorship should only be accepted with the approval of a director
Commercial sponsorship includes sponsorship for courses, conferences, post/project funding, meetings and publications.
Advice on whether to accept commercial sponsorship can be provided by Rod While
Whether accepted or declined, all offers must be declared
The CCG is required to publish registers of gifts, hospital and commercial sponsorship on its website
September 2016

9. Employees – what it means for you Procurement and contract monitoring
If you are involved in procurement you need to keep detail records of how conflicts of interest have been managed throughout the process
You must ask for declarations from all bidders
You must retain an internal audit trail of how the conflict or perceived conflict was dealt with to allow the provision of information at a later date if required
You will need to utilise a procurement template (contained in the policy) which sets out factors that the CCG will address when drawing up their plans to commission general practice services.
The template must be used for all procurements, including the multi-provider pathway collaborative approach.
The CCG will maintain a register of procurement decisions taken, either for the procurement of a new service or any extension or material variation of a current contract.
Any contract monitoring meeting needs to consider conflicts of interest as part of the process. The chair of a contract management meeting should invite declarations of interests; record any declared interests in the minutes of the meeting; and manage any conflicts appropriately and in line with this policy.
The individuals involved in the monitoring of a contract should not have any direct or indirect financial, professional or personal interest in the incumbent provider or in any other provider
September 2016

10. Employees – what it means for you Training
You will need to undertake an annual online conflicts of interest training module
This is current being developed by NHS England and is likely to be available in October / November 2016.
You will need to complete the module by January 31 every year.
September 2016

11. Employees – what it means for you Breaches of policy
We are required to investigate any potential breaches of the policy and publish the anonymised outcomes of any actual breaches on our website.
This means for example, if you have failed to declare a particular interest conflicts with your work, this may result in disciplinary action or may even lead to criminal proceedings including for offences such as fraud, bribery and corruption.
September 2016