conflict of interest policy - greenwich ccg · 2013-11-19 · june 2016 review body the governing...

$: Conflict of Interest Policy - Greenwich CCG · 2013-11-19 · June 2016 Review Body The Governing Body or GCCG Executive Policy Reference Number 011 . Page 2 of 22 N:\Policies$
N:\Policies&Procedures\Policies\Conflict of Interest 1

Conflict of Interest Policy

Author(s)

Director of Integrated Governance

Version

2.3

Version Date

26 June 2013

Implementation/Approval Date

Review Date

June 2016

Review Body The Governing Body or GCCG Executive

Policy Reference Number 011

Page 2 of 22 N:\Policies&Procedures\Policies\Conflict of Interest

Version Author Date Reason for review

1.0 Nicola Havutcu

Director of Integrated

Governance

July 2012 Inaugural Governing Body Policy

– Statutory requirement

2.0 Colin Nash CCG

Coordinator

May 2013 To ensure policy complied with

NHS Greenwich CCG Constitution

and Managing conflicts of interest: guidance

for clinical commissioning groups

(NHS England March 2013)

2.1 Angelique Kempton,

Executive Manager

June 2013

Amendments to Version 2.0

2.2 Maggie Aiken,

Associate Director,

Governance and Quality

June 2013 Amendments to Version 2.1

2.3 Colin Nash June 2013 Amendments to Version 2.2 following

consultation with Lay Member for Governance

and Director of Integrated Governance


Contents

1.0 Summary .................................................................................................................. 4

2.0 Introduction and Objectives ...................................................................................... 4

3.0 Scope ....................................................................................................................... 5

4.0 Roles and Responsibilities ........................................................................................ 6

5.0 The Declaration of Interests ...................................................................................... 7

6.0 Standards of Business Conduct and Managing Conflicts of Interest ......................... 9

7. Breaches of this policy .............................................................................................. 14

8. Training and awareness ........................................................................................... 14

9. Further advice and guidance .................................................................................... 15

10. Equality Impact Assessment ................................................................................... 16

11. Review .................................................................................................................... 16

12. Monitoring/Audit ...................................................................................................... 16

Appendix 1: Declaration Form ...................................................................................... 20

Appendix 2: Equility and Equity Impact Assessment ChecklistError! Bookmark not defined.


1.0 Summary

This policy sets out how the NHS Greenwich Clinical Commissioning Group (CCG) will manage conflicts of interest arising from the operation of the CCG. Separate policies cover Gifts & Hospitality, attendance at conferences and sponsorship, anti-bribery and

the Procurement Framework.

This policy complies with the standards of business conduct and managing conflicts of

interest as set out in the NHS Greenwich CCG Constitution (Section 8).

All employees and appointees of the CCG are required to observe the principles of

good governance in the way it conducts its business. These include:

The highest standards of propriety involving impartiality, integrity and objectivity

in relation to the stewardship of public funds, the management of the

organisation and the conduct of business;

The Good Governance Standards for Public Services;

The standards of behaviour published by the Committee on Standards in public

Life (1995) known as the Nolan Principles (detailed in 7.1. above);

The seven key principles of the NHS Constitution;

The Equality Act 2010;

That all publically funded commissioners of healthcare including the CCG and

local authority consider the wider effect of commissioning outside the NHS on the

long-term viability of public providers;

The code of conduct : Managing conflicts of interest where GP practices are

potential providers of CCG commissioned services.

2.0 Introduction and Objectives

The Governing Body has ultimate responsibility for all actions carried out by staff and committees throughout the Governing Body‟s activities. This responsibility includes the stewardship of significant public resources and the commissioning of healthcare to the community. The Governing Body is therefore determined to ensure the organisation inspires confidence and trust amongst its patients, members, staff, partners, stakeholders, funders and suppliers by demonstrating integrity and avoiding any potential or real situations of undue bias or influence in the decision-making of the Governing Body.

This Conflict of Interest Policy respects the seven principles of public life promulgated

by the Nolan Committee1. The seven principles are:

1. Selflessness: Holders of public office should act solely in terms of the public interest. They should not do so in order to gain financial or other benefits for themselves, their family or their friends.


2. Integrity: Holders of public office should not place themselves under any financial or other obligation to outside individuals or organisations that might seek to influence them in the performance of their official duties.

3. Objectivity: In carrying out public business, including making public appointments, awarding contracts, or recommending individuals for rewards and benefits, holders of public office should make choices on merit.

4. Accountability: Holders of public office are accountable for their decisions and actions to the public and must submit themselves to whatever scrutiny is appropriate to their office.

5. Openness: Holders of Public Office should be as open as possible about all the decisions and actions that they take. They should give reasons for their decisions and restrict information only when the wider public interest clearly demands.

6. Honesty: Holders of Public Office have a duty to declare any private interests relating to their public duties and to take steps to resolve any conflicts arising in a way that protects the public interest.

7. Leadership: Holders of Public Office should promote and support these principles by leadership and example.

The Governing Body has a legal obligation to act in the best interests of GCCG, and in accordance with the Governing Body‟s Constitution and Terms of Establishment, created by the NHS Commissioning Board, and to avoid or appropriately manage situations where there may be a potential conflict of interest.

Conflicts of interest may arise where an individual‟s personal interests, or a connected person‟s interests and/or loyalties, conflict with those of the CCG. Such conflicts may

create problems such as inhibiting free discussion which could:

result in decisions or actions that are not in the interest of the CCG and the public it was established to serve

risk the impression that the Governing Body has acted improperly

It is not possible, or desirable, to define all instances in which an interest may be a real or perceived conflict. In line with the Nolan principles, NHS Greenwich CCG promotes transparency in this respect. It is for each individual to exercise their judgment in deciding whether to register any interests that may be construed as a conflict. Individuals can seek guidance from their line manager or the Executive

Manager, Director of Governance or the Lay person with responsibility for Governance.

The aim of this policy is to protect both the organisation and the individuals involved from any appearance of impropriety and demonstrate transparency to the public and

other interested parties.

3.0 Scope

This policy applies to the CCG membership and staff and those serving on the Governing Body and CCG Committees.


4.0 Roles and Responsibilities

4.1 Chief Accountable Officer/Director of Integrated Governance

The Chief Accountable Officer has overall responsibility for ensuring the Governing Body has appropriate governance policies and procedures in place to ensure the Governing Body works to best practice and complies with all relevant legislation, and this is delegated to the Director of Integrated Governance. They also have responsibility for ensuring the Governing Body applies the principles of this policy and that there are suitable resources to support its implementation and ensure new members receive guidance on the organisation‟s approach to the management of Conflict of Interest.

The CAO/Director of integrated governance should be informed within 28 days of a member taking office of any interests requiring registrations, or within 28 days of any

changes to a member‟s register of interest.

4.2 The Role of the Chair of the Governing Body

The Chair has a key role in overseeing governance and particularly ensuring that the Governing Body and the wider CCG behaves with the utmost transparency and responsiveness at all times and in line with National Guidance and professional codes of conduct. The Chair is able to give an unbiased view on possible internal conflicts of interest. The Chair takes the lead, particularly at meetings, in ensuring that board members and staff follow the policy. The Chair may wish to consult the lay member /Guardian for CoI to advise. All decisions should be recorded in the minutes of the meeting.

4.3 Lay member for Governance

The lay member with responsibility for audit remuneration and conflicts of interest is strategic and impartial. Duties include overseeing the management of conflicts of

interest and advising on particular cases when requested to do so.

The Governing Body has appointed one of the Lay Members (with a lead role in Governance) to act as “Conflict of Interest Guardian”. The Lay Member has no provider interest, is not a medical doctor or a healthcare provider and is therefore independent and impartial.

The Lay member can act as a conduit for members of the public who have any concerns in regard to CoI

The Lay Member is responsible for ensuring that the CCG applies CoI principles and policies rigorously and provides the CCG with independent advice and judgment where there is any doubt about how to apply them to individual cases.

The lay member will have a lead role in ensuring that the Governing Body and the wider CCG behaves with the utmost probity at all times and be able to give an independent view on possible internal conflicts of interest.

The scope of the CoI guardian‟s work is twofold: a. To judge whether there is a risk of a CoI arising b. To advise how this risk should be minimised


The CoI guardian operates in two modes: a. Reactively, when the CCG as a whole or individual GP members seek advice

on a specific issue b. Proactively when a potential CoI risk is identified and acts on it. The CoI

guardian is a voting member and is familiar with the work of the organisation and the roles of the GP leads. The CoI Guardian is therefore in an informed position to identify such risks when they arise.

In either mode the CoI guardian discusses the issue with the GPs involved and any other relevant party and issues written advice or judgement for the Governing Body. The members of the Governing Body, its committees and sub-committees have agreed that they will accept the advice or judgement of the CoI guardian in such cases.

4.4 Executive Manager

The Executive Manager is responsible for maintaining the Conflicts of Interest Register and ensuring a copy is available for Governing Body and Committee meetings. The Executive Manager will ensure that Conflicts of Interests is a standard agenda item for all Committee and Sub-Committee meetings. In the event of withdrawal of a conflicted member, it is the responsibility of the Executive Manager, or person acting as secretary to the meeting, to monitor quorum and advise the Chair accordingly. The Executive Manager will compile and maintain details of conflicts, how these have been managed and recorded. The Executive Manager will ensure the Register of Interest is available for public scrutiny and is on the public website. The Register of Interest is also published within the NHS Greenwich CCG annual report. The Executive Manager will ensure the corporate office holds detail of each query in regard to Conflict of Interest that provides an audit trail on each query and action taken.

4.5 Other Governing Body Members The Secondary Care Doctor on the Governing Body should have no conflicts of interest i.e. they should not be employed by any organisation from which the CCG secures any significant volume of provision. The Registered Nurse on the Governing Body should have no conflicts of interest i.e. they should not be employed by any organisation from which the CCG secures any significant volume of provision.

5.0 The Declaration of Interests

Employees, members, committee and sub-committee members of the Group and members of the Governing Body (and its committees) are required to declare any

relevant and material interests.

Interests that may impact on the work of the CCG and should be declared include:

any directorships of companies likely to be engaged with the business of the

Governing Body


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 shareholdings2 and beneficial interests

gifts or hospitality offered by external bodies and whether this was declined or

accepted in the last twelve months

personal business contacts and family members with a relationship to any of the above

any other conflicts that are not covered by the above

A Declaration of Interests Form (see Appendix 1) is provided for this purpose, listing the

types of interest that should be declared.

To be effective, the Declaration of Interests Form must be completed prior to becoming an employee, member, committee or sub-committee member or member of the Governing Body (and its committees), as part of the appointments process and annually

thereafter and when any material changes occur.

The Governing Body will determine whether any applicant with over a 5% capital shareholding of a conflicted organisation would be so significantly in conflict that that individual should be precluded from membership of the Governing Body.

Governing Body Members are reminded that there is a distinction between the material interests they are required to declare in the CCG Annual Report and other interests to

be declared in the Register of Interests.

Definition of an interest

A conflict of interest has been defined as:

„A conflict between the private interests and the official responsibilities of a person in a position of trust‟


„A set of conditions in which a professional judgement concerning a primary interest [such as patients‟ welfare or the validity of research] tends to be unduly influenced by a secondary interest [such as financial gain]‟

„The creation of a set of circumstances where one party is favoured over another by an inadvertent preferential interest‟

5.1 Data protection

The information provided will be processed in accordance with data protection principles as set out in the Data Protection Act 1998. Data will be processed only to ensure that the Governing Body and Committee Members act in the best interests of the Governing Body and the public and patients the group was established to serve. The information

provided will not be used for any other purpose.

Signing the declaration form will also signify that you consent to your data being processed for the purposes set out in this policy.

6.0 Standards of Business Conduct and Managing Conflicts of Interest

6.1 Standards of Business Conduct

6.1.1 Employees, members, committee and sub-committee members of the Group and members of the Governing Body (and its committees) will at all times comply with this Constitution and be aware of their responsibilities as outlined in it. They should act in good faith and in the interests of the Group and should follow the Seven Principles of Public Life, set out by the Committee on Standards in Public Life (the Nolan Principles) The Nolan Principles are

incorporated into this Constitution at Appendix F.

6.1.2 They must comply with the Group‟s policy on business conduct, including the requirements set out in the policy for managing conflicts of interest. This policy will be available on the Group‟s website, and on request from the Associate

Director of Membership Development.

6.1.3 Individuals contracted to work on behalf of the Group or otherwise providing services or facilities to the Group will be made aware of their obligation with regard to declaring conflicts or potential conflicts of interest. This requirement

will be written into their contract for services.

6.2 Conflicts of Interest

6.2.1 As required by Section 140 of the 2006 Act, as inserted by Section 25 of the 2012 Act, the Group has made arrangements to manage conflicts and potential conflicts of interest to ensure that decisions made by the Group will be taken and seen to be taken without any possibility of the influence of external or

private interest.


6.2.2 A conflict of interest will include:

a) a direct pecuniary interest: where an individual may financially benefit from the consequences of a commissioning decision (for example, as a

provider of services);

b) an indirect pecuniary interest: for example, where an individual is a partner, member or shareholder in an organisation that will benefit financially

from the consequences of a commissioning decision;

c) a non-pecuniary interest: where an individual holds a non-remunerative or not-for profit interest in an organisation, that will benefit from the consequences of a commissioning decision (for example, where an individual is a trustee of a voluntary provider that is bidding for a

contract);

d) a non-pecuniary personal benefit: where an individual may enjoy a qualitative benefit from the consequence of a commissioning decision which cannot be given a monetary value (for example, a reconfiguration of hospital services which might result in the closure of a busy clinic next door to an individual‟s house);

e) where an individual is closely related to, or in a relationship, including

friendship, with an individual in the above categories.

6.2.3 Where an individual, i.e. an employee, Group member, member of the Governing Body, or a member of a committee or a sub-committee of the Group or the Governing Body has an interest, or becomes aware of an interest which could lead to a conflict of interest in the event of the Group considering an action or decision in relation to that interest, that must be considered as a potential conflict, and is subject to the provisions of this Constitution.

6.2.4 If in doubt, the individual concerned should assume that a potential conflict of

interest exists.

6.2.5 Where a conflict of interest would preclude a Governing Body member, or Members, with essential skills or knowledge, from contributing to business, provision is made for the Governing Body to appoint special advisors, with similar skills or knowledge, to assist them. These advisors would not be

members of the Governing Body and have no voting rights

6.3 Interests which are relevant and material

6.3.1 Interests which should be regarded as relevant and material include:

a) Directorships, including non-executive directorships held in private companies or public limited companies („plcs‟) (with the exception of directorships of dormant companies);

b) Ownership or part-ownership of private companies, businesses or consultancies likely or possibly seeking to do business with the Group;


c) Majority or controlling share holdings in organisations likely or possibly seeking to do business with the Group;

d) A position of authority in a charity or voluntary organisation in the field of health and social care;

e) Any connection with a voluntary or other organisation contracting for services being tendered by the Group.

f) Research funding/grants that may be received by an individual or their department

within the Group.

6.4 Declaring and Registering Interests

6.4.1 The Group will maintain one or more registers of the interests of:

a) the members of the Group;

b) the members of the Governing Body;

c) the members of its committees or sub-committees and the committees or

sub-committees of the Governing Body; and

d) its employees.

6.4.2 The registers will be published on the Group‟s website.

6.4.3 Individuals will declare any interest that they have, in relation to a decision to be made in the exercise of the commissioning functions of the Group, in writing to the Governing Body, as soon as they are aware of it and in any event no later

than 28 days after becoming aware.

6.4.4 Where an individual is unable to provide a declaration in writing, for example, if a conflict becomes apparent in the course of a meeting, they will make an oral declaration before witnesses, and provide a written declaration as soon as

possible thereafter to the Governing Body.

6.4.5 The Governing Body will ensure that the register(s) of interest is reviewed regularly, and updated as necessary.

6.4.6 The lay member of the Governing Body, with particular responsibility for governance, will make themselves available to provide advice to any individual

who believes they have, or may have, a conflict of interest.

6.4.7 The Governing Body will take such steps as it deems appropriate, and request information it deems appropriate from individuals, to ensure that all conflicts of

interest and potential conflicts of interest are declared.

6.5 Managing Conflicts of Interest: general

6.5.1 Where an interest has been declared, either in writing or by oral declaration, the declarer will ensure that before participating in any activity connected with the


Group‟s exercise of its commissioning functions, they have received confirmation of the arrangements to manage the conflict of interest or potential

conflict of interest from the Governing Body.

6.5.2 The Governing Body will ensure that for every interest declared, either in writing or by oral declaration, arrangements are in place to manage the conflict of interests or potential conflict of interests, to ensure the integrity of the Group‟s decision making processes. Arrangements for the Governing Body are set out below.

6.5.3 Arrangements for the management of conflicts of interest are to be determined by the Governing Body and will include the requirement to put in writing to the relevant individual arrangements for managing the conflict of interests or potential conflicts of interests, within a week of declaration.

6.5.4 The arrangements will confirm the following:

a) when an individual should withdraw from specified activity, on a temporary

or permanent basis;

b) monitoring of the specified activity undertaken by the individual, either by a

line manager, colleague or other designated individual.

6.5.5 In any meeting where an individual is aware of an interest, previously declared or otherwise, in relation to the scheduled or likely business of the meeting, the individual concerned will bring this to the attention of the chair, together with details of arrangements which have been confirmed by the Governing Body for the management of the conflict of interests or potential conflict of interests. Where no arrangements have been confirmed, the chair may require the

individual to withdraw from the meeting or part of it.

6.5.6 Where the chair of any meeting of the Group, including committees, sub-committees, or the Governing Body, has a personal interest, previously declared or otherwise, in relation to the scheduled or likely business of the meeting, they must make a declaration and the deputy chair will act as chair for the relevant part of the meeting. Where arrangements have been confirmed with the Governing Body for the management of the conflict of interests or potential conflicts of interests in relation to the chair, the meeting must ensure these are followed. Where no arrangements have been confirmed, the deputy chair may require the chair to withdraw from the meeting or part of it. Where

there is no deputy chair, the members of the meeting will select one.

6.5.7 Any declarations of interests, and arrangements agreed in any meeting of the Group, committees, sub-committees, or the Governing Body, will be recorded

in the minutes.

6.5.8 In any transaction undertaken in support of the Group‟s exercise of its commissioning functions (including conversations between two or more individuals, e-mails, correspondence and other communications), individuals must ensure, where they are aware of an interest, that they conform to the arrangements confirmed for the management of that interest. Where an individual has not had confirmation of arrangements for managing the interest,


they must declare their interest at the earliest possible opportunity in the course of that transaction, and declare that interest as soon as possible thereafter. The individual must also inform either their line manager (in the case of employees), or the Governing Body, of the transaction.

6.6 Managing Conflicts of Interest: Governing Body

6.6.1 Individual members of the Governing Body will comply with the arrangements determined by the Governing Body for managing conflicts or potential conflicts

of interest.

6.6.2 Where a Governing Body member is aware of an interest which has not been declared, either in the register or orally to the Governing Body, they will declare this at the start of the meeting. The Governing Body will then determine how this should be managed and inform the member of their decision. The member will then comply with these arrangements, which must be recorded in the

minutes of the meeting.

6.6.3 Where more than 50% of the members of the Governing Body are required to withdraw from a meeting or part of it, owing to the arrangements agreed by the Governing Body for the management of conflicts of interests or potential conflicts of interests, the remaining Chair will determine whether or not the

discussion can proceed.

6.6.4 In making this decision the Chair will consider whether the meeting is quorate, in accordance with the number and balance of membership set out in the Group‟s standing orders. Where the meeting is not quorate, owing to the absence of certain members, the discussion will be deferred until such time as a quorum can be convened. Where a quorum cannot be convened from the membership of the Governing Body, owing to the arrangements for managing conflicts of interest or potential conflicts of interests, the Chair may invite on a temporary basis one or more of the following to make up the quorum so that the Group

can progress the item of business:

a) a member of the Group who is an individual;

b) an individual appointed by a member to act on its behalf in the dealings

between it and the Group;

c) a member of a relevant Health and Wellbeing Board;

d) a member of a Governing Body of another clinical commissioning group; provided that following such invitation a majority of those comprising the

quorum are affiliated with the CCG.

6.6.5 The arrangements made pursuant to the provisions of Section 8.6.4 must be

recorded in the minutes.

6.6.6 The degree to which a conflict of interest might fetter the ability of an individual to make a full and proper contribution to the Governing Body will be taken into account

when considering appointments and elections to the Governing Body.


6.7 Managing Conflicts of Interest: Contractors

6.7.1 Anyone seeking information in relation to a procurement, or participating in a procurement, or otherwise engaging with the Group in relation to the potential provision of services or facilities to the Group, will be required to make a declaration of interest.

6.7.2 Anyone contracted to provide services or facilities directly to the Group will be subject to the same provisions of this Constitution in relation to managing conflicts of interests. This requirement will be set out in the contract for their services.

6.8 Transparency in Procuring Services

6.8.1 The Group recognises the importance in making decisions about the services it procures in a way that does not call into question the motives behind the procurement decision that has been made. The Group will procure services in a manner that is open, transparent, non-discriminatory and fair to all potential

providers.

6.8.2 The Group will publish a Procurement Framework approved by the Governing

Body which will ensure that:

a) all relevant clinicians (not just members of the Group) and potential providers, together with local members of the public, are engaged in

the decision-making processes used to procure services;

b) service redesign and procurement processes are conducted in an open,

transparent, non-discriminatory and fair way.

6.8.3 Copies of this Procurement Framework will be available on the Group‟s website.

7. Breaches of this policy

Breaches of the policy may result in an individual being removed from office in line with the Governing Body‟s Constitution and or subject to the disciplinary procedures of the

CCG .

8. Training and awareness

The Governing Body is committed to ensure appropriate training takes place on this subject for all staff and member practices

The content of such training includes helping to develop a clear, corporate view about the organisations appetite for risk in this area.

The content of such training will adopt best practice from national guidance and learning from other CCGs/public bodies.


CoI training will be provided annually for the Governing Body as part of its development, ensuring that all clinical commissioners are trained in good governance.

Dissemination of learning from these events will be shared with all staff.

CoI will be included in the induction programme and induction pack for new board/governing body members/new members of staff.

Awareness of this policy will be raised through the following:

GCCG Intranet and internet sites o incorporated into training programmes for the Governing Body and o members of key Committees of the Governing Body.

by sharing with potential members as part of the appointment process

being part of the local induction process

being referred to as part of the procurement process as well as referenced in the Procurement Framework

awareness will be raised at the Committee of the Greenwich Clinical Commissioning Group, sub-committee and other relevant meetings

9. Further advice and guidance

Appendix 5 of Managing Conflicts of Interest: Guidance for Clinical Commissioning Groups, NHS England, March 2013 sets out conflict of interest discussion scenarios which may be helpful in considering particular cases.

Code of Conduct for NHS Managers, Department of Health, (Oct 2002)

Code of Conduct in the NHS, page 2, Department of Health/Appointments

Commission (2004)

The Healthy NHS Board: Principles for Good Governance, page 31,

NHS National Leadership Council (2010)

Good Medical Practice, GMC, Sec 73/74/ 75 & 76 (2006)

The code of conduct : Managing conflicts of interest where GP practices are

potential providers of CCG commissioned services (July 2012)

In the event that further clarification or advice is required in respect of this policy, please refer to the Executive Manager or the Director of Integrated Governance.


10. Equality Impact Assessment

The CoI Policy supports the three main principles of procurement law, namely equal

treatment, non-discrimination and transparency. The organisation is committed to

equality of opportunity for it employees and does not unlawfully discrimination on the

basis of their “protected characteristics” as defined in the Equality Act 2010 - age,

disability, gender reassignment, marriage and civil partnership, pregnancy and

maternity, race, religion or belief, sex and sexual orientation.

An Equality Impact Assessment has been carried out on this policy. The results indicated that the policy was not likely to impact on the Governing Body‟s duties under its equalities schemes.

If you have any concerns or issues with the contents of this policy or have difficulty understanding how this policy relates to you or your role, please contact the Executive

Manager [email protected].

11. Review

This policy will be reviewed in 3 years time unless earlier review is indicated. This Policy

should be kept under review in the light of changing circumstances and requirements.

12. Monitoring/Audit

The processes for monitoring compliance with this procedure are outlined in the table below:

Measurable Policy Objective

Monitoring/Audit

Frequency of monitoring

Responsibility for performing the monitoring

Monitoring reported to which groups/committees, including responsibility for reviewing action plans

Conflicts of Interests will be registered.

Audit of Register of Interests

Yearly Internal Audit The Governing Body

Declared conflicts of interest are minuted

Audit of minutes

Yearly Internal Audit The Governing Body

https://web.nhs.net/owa/redir.aspx?C=aetMVOUkXUKllrwS-qeyLE8YGbkJP9BIIjjLi1SUWoQiUKTH0Zm6842wtXB-o--KwtJ6IlVUOgs.&URL=mailto%3aakempton2%40nhs.net


Appendix 1: Declaration Form

NHS Greenwich Clinical Commissioning Group

Member / employee/ Governing Body member / committee or sub-committee member (including committees and sub-committees of the Governing Body)

declaration form: financial and other interests

This form is required to be completed in accordance with the CCG‟s Constitution (Section 8) and the guidance issued by NHS England, to meet the requirements of section 14O of The National Health Service Act 2006.

Notes:

Each CCG must make arrangements to ensure that the persons mentioned above declare any interest which may lead to a conflict with the interests of the CCG and the public for whom they commission services in relation to a decision to be made by

the CCG.

A declaration must be made of any interest likely to lead to a conflict or potential

conflict as soon as the individual becomes aware of it, and within 28 days.

If any assistance is required in order to complete this form, then the individual should contact Ms Angelique Kempton, Executive Manager at [email protected]. She may in turn seek advice from Mr Jim Wintour, Lay

Member of the Governing Body.

The completed form should be sent by both email and signed hard copy to

Ms Angelique Kempton,

Executive Manager,


31-37 Greenwich Park Street

Greenwich SE10 9LR

Email: [email protected]

Any changes to interests declared must also be registered within 28 days by completing and submitting a new declaration form.

The register will be published on the NHS Greenwich Clinical Commissioning Group

website. Paper copies can be obtained from Ms Kempton at the above address.

Any individual – and in particular members and employees of the CCG - must provide sufficient detail of the interest, and the potential for conflict with the interests

https://web.nhs.net/owa/redir.aspx?C=aetMVOUkXUKllrwS-qeyLE8YGbkJP9BIIjjLi1SUWoQiUKTH0Zm6842wtXB-o--KwtJ6IlVUOgs.&URL=mailto%3aakempton2%40nhs.net

https://web.nhs.net/owa/redir.aspx?C=aetMVOUkXUKllrwS-qeyLE8YGbkJP9BIIjjLi1SUWoQiUKTH0Zm6842wtXB-o--KwtJ6IlVUOgs.&URL=mailto%3aakempton2%40nhs.n


of the CCG and the public for whom they commission services, to enable a lay

person to understand the implications and why the interest needs to be registered.

If there is any doubt as to whether or not a conflict of interests could arise, a

declaration of the interest must be made.

Interests that must be declared (whether such interests are those of the individual themselves or of a family member, close friend or other acquaintance of the individual)

include:

roles and responsibilities held within member practices;

directorships, including non-executive directorships, held in private companies or

PLCs;

ownership or part-ownership of private companies, businesses or consultancies likely or possibly seeking to do business with the CCG;

shareholdings (more than 5%) of companies in the field of health and social care;

a position of authority in an organisation (e.g. charity or voluntary organisation) in

the field of health and social care;

any connection with a voluntary or other organisation contracting for NHS

services;

research funding/grants that may be received by the individual or any organisation in which they have an interest or role;

any other role or relationship which the public could perceive would impair or

otherwise influence the individual‟s judgment or actions in their role within the CCG.

If there is any doubt as to whether or not an interest is relevant, a declaration of the

interest must be made.


Declaration:

Name (Please print):

Position within or

relationship with, the

CCG:

INTERESTS

Type of Interest Details Personal

interest or that

of a family

member, close

friend or other

acquaintance?

Roles and responsibilities

held within member

practices

Directorships, including

non-executive

directorships, held in

private companies or

PLCs

Ownership or part-

ownership of private

companies, businesses or

consultancies likely or

possibly seeking to do

business with the CCG

Shareholdings (more than

5%) of companies in the

field of health and social

care

Positions of authority in

an organisation (e.g.

charity or voluntary

organisation) in the field

of health and social care

Any connection with a

voluntary or other

organisation contracting

for NHS services


Research funding/grants

that may be received by

the individual or any

organisation they have an

interest or role in

Other specific interests?

e.g.Personal healthcare

needs, media appearances

where members appear in

the capacity of a health

professional and

involvement in service

redesign.

Any other role or

relationship which the

public could perceive

would impair or otherwise

influence the individual’s

judgement or actions in

their role within the CCG

To the best of my knowledge and belief, the above information is complete and correct. I

undertake to update as necessary the information provided and to review the accuracy of the

information provided regularly and no longer than annually. I give my consent for the information

to be used for the purposes described in the CCG‟s Constitution and published accordingly.

Signed: ______________________________________________________

Date: _________________________

The completed form should be sent by both email and signed hard copy to

Ms Angelique Kempton,

Executive Manager,


31-37 Greenwich Park Street

Greenwich SE10 9LR

Email: [email protected]

https://web.nhs.net/owa/redir.aspx?C=aetMVOUkXUKllrwS-qeyLE8YGbkJP9BIIjjLi1SUWoQiUKTH0Zm6842wtXB-o--KwtJ6IlVUOgs.&URL=mailto%3aakempton2%40nhs.n


Appendix 2 - Equality & Equity Impact Assessment Checklist

This is a checklist to ensure relevant equality and equity aspects of proposals have been addressed either in the main body of the document or in a separate equality & equity impact assessment (EEIA)/ equality analysis. It is not a substitute for an EEIA which is required unless it can be shown that a proposal has no capacity to influence equality. The checklist is to enable the policy lead and the relevant committee to see whether an EEIA is required and to give assurance that the proposals will be legal, fair and equitable.

The word proposal is a generic term for any policy, procedure or strategy that requires assessment.

Challenge questions Yes/No What positive or negative impact do

you assess there may be?

1. Does the proposal affect one group more or less favourably

than another on the basis of:

Race

Pregnancy and Maternity

Sex

Gender and Gender Re-Assignment

Marriage or Civil Partnership

Religion or belief

Sexual orientation (including lesbian, gay bisexual and transgender people)

Age

Disability (including learning disabilities, physical disability, sensory impairment and mental health problems)

2. Will the proposal have an impact on lifestyle?

(e.g. diet and nutrition, exercise, physical activity, substance

use, risk taking behaviour, education and learning)

3. Will the proposal have an impact on social environment?

(e.g. social status, employment (whether paid or not),

social/family support, stress, income)

4. Will the proposal have an impact on physical environment?

(e.g. living conditions, working conditions, pollution or

climate change, accidental injury, public safety,

transmission of infectious disease)

5. Will the proposal affect access to or experience of services?

(e.g. Health Care, Transport, Social Services, Housing

Services, Education)

Policy Author Date Signature:

Equalities Lead (Carol Berry) Date Signature:

conflict of interest policy - greenwich ccg · 2013-11-19 · june 2016 review body the governing...

Documents