Our Conflicts of Interest (COI) Policy ensures that we meet the revised NHS England Managing Conflicts of Interest Statutory Guidance published in June 2016.
The COI Policy also forms part of our constitution.
How we manage conflicts of interest:
A conflict of interest happens when a person’s ability to make unbiased decisions or their position may be impaired due to a clash between personal or professional interests and responsibilities.
The COI Policy enables NHS Cambridgeshire & Peterborough (our Integrated Care Board – or ICB), which is the legal NHS entity of Cambridgeshire & Peterborough ICS to demonstrate that it is acting fairly, transparently, and in the best interest of our patients and the local population. It is drafted to ensure that NHS Cambridgeshire & Peterborough operates within the legal framework, without being ruled by very strict rules that block innovation.
The Policy Aims to:
- Safeguard clinically-led commissioning, while ensuring objective investment decisions.
- Enable NHS Cambridgeshire & Peterborough to demonstrate that it is acting fairly and transparently and in the best interest of our patients and the local population.
- Uphold confidence and trust in the NHS.
- Support NHS Cambridgeshire & Peterborough to understand when conflicts (whether actual or potential) may arise and how to manage them if they do.
- Ensure that NHS Cambridgeshire & Peterborough operates within the legal framework.
Finally, it will uphold confidence and trust between GPs and their patients, in recognition that individual commissioners wish to operate ethically. However, at times, they may need support and training to better understand when conflicts (whether actual, potential or perceived) may arise and what is the best way to manage them if they do.
All NHS Cambridgeshire & Peterborough members and employees are required to declare any relevant and material personal or business interests and any relevant and material personal or business interest of their spouse; civil partner; cohabitee, family member or close friends which may influence or may be perceived to influence their judgement. Further detail is provided in the Policy and declarations are included in NHS Cambridgeshire & Peterborough's Registers of Interest.
Decision Making in Meetings:
When members of a decision-making group or who are participating in a meeting have a material interest, they will either be excluded from relevant parts of meetings or join in the discussion but not take part in any voting.
The Chair of a meeting has the responsibility for deciding whether there is a conflict of interest and the appropriate course of the corresponding action. All decisions, and details of how any conflicts of interest issue has been managed, should be recorded in the minutes of the meeting, and published in the registers. If the Chair of a meeting has a conflict of interest, it must be decided before the meeting is held, who will take the Chair’s role for discussions and decision-making, or how that will be decided at a meeting where that situation arises.
Hospitality and Commercial Sponsorship:
In line with NHS Cambridgeshire & Peterborough's Standards of Business Conduct and Commercial Sponsorship Policy, NHS Cambridgeshire & Peterborough keeps a Register of Gifts, Hospitality and Commercial Sponsorship. This complements the Conflicts of Interest Policy.
Breaches to the Policy:
NHS Cambridgeshire & Peterborough has a Register of Breaches, which sets out details of any breach, how it has been investigated and notification of the breach to NHS England. All breaches are reported to NHS Cambridgeshire & Peterborough's Audit Committee and to the Board via a standing item in the Audit Committee Overview Report. Anonymised details of breaches are published on this website for learning and development.
Further Information and Advice:
NHS Cambridgeshire & Peterborough has a Conflicts of Interest Guardian, whom:
- Acts as a connection for GP practice staff, members of the public and healthcare professionals who have concerns regarding conflicts of interest.
- Is a safe point of contact for employees or workers of NHS Cambridgeshire & Peterborough to raise any concerns regarding this policy.
- Supports the rigorous application of conflicts of interest principles and policies.
- Provides independent advice and judgment, where there is any doubt about how to apply conflicts of interest policies and principles in an individual situation.
- Provides advice on minimising the risks of conflicts of interest.
NHS Cambridgeshire & Peterborough's Guardian is an Independent Non-Executive Member, supported by our Chief of Staff. In the first instance, please contact firstname.lastname@example.org if you have any queries or concerns or want to seek advice on the Conflicts of Interests Policy.