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 Norwich 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 Norwich 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
How does Norwich CCG manage conflicts of interest?
Norwich CCG takes its responsibility to manage conflicts of interest seriously and has a pdf Conflict of Interest Policy (522 KB). This policy sets out how Norwich CCG Governing Body members, officers, staff, members and clinical leads should behave in their role at Norwich 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:
- Direct financial interests
- Indirect financial interests
- Non-financial personal interests
- Conflicts of loyalty
The CCG has appointed a Conflicts of Interest Guardian, the Governing Body Lay Member for Governance & Audit, Paul Fisher. It is the duty of every CCG employee, Governing Body member, Committee or Sub-Committee member and GP practice member to speak up about genuine concerns in relation to the conflicts of interest management, and to report these concerns to the Conflicts of Interest Guardian.
A copy of the Register of Interests will also be made available upon request for inspection at NHS Norwich CCG’s headquarters at City Hall, Norwich.
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. 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. We also publish our procurement decisions in a Procurement Register.
CCGs also need to ensure that robust processes are in place to ensure that individuals do not accept gifts, hospitality or other benefits, which might reasonably be seen to compromise their professional judgement or integrity. All CCG employees and Committee Members therefore should make a declaration of interest in accordance with national guidance. We also publish our pdf Register of Gifts and Hospitality (187 KB).