Conflicts of Interest

What is a conflict of interest?

A conflict of interest occurs where an individual’s ability to exercise judgement, or act in a role, is or could be impaired or otherwise influenced by his or her involvement in another role or relationship.

Why does the CCG need to manage them?

NHS Shropshire, Telford and Wrekin Clinical Commissioning Group receives a significant amount of public funds to spend on healthcare for its population. We therefore have to ensure that individuals acting on behalf of the CCG, whether this is a board or committee member, GP, staff member or a contractor, act with impartiality when making decisions on how the CCG’s budget is spent, and they do not use their role in the CCG to further their own private interests or those of anyone known to them.

How does the CCG manage conflicts of interest?

Conflicts of interest are inevitable when commissioning services, so how we manage them is crucial. The CCG does this by:

• A Conflicts of Interest Policy and Declaration of Gifts, Hospitality & Sponsorship Policy and Procedure, which set out how the CCG wishes its GP membership, board and committee members, staff and contractors to behave and the measures the CCG will take to manage conflicts of interest;
• A Register of Interests for all our staff, GP member partners and other practice staff involved in CCG business, contractors and board and committee members, which clearly set out everyone’s interests so it is much easier to identify a conflict and manage it;
• A Register of Gifts, Hospitality and Sponsorship showing where offers of gifts, hospitality and sponsorship have been made and declined or accepted;
• A Register of Procurement Decisions to demonstrate how the CCG has managed conflicts of interest pertaining to procurement/contractual decisions made by the CCG;
• A Register of Conflicts of Interest Breaches to ensure that where there is a breach of the Conflicts of Interest Policy that this is captured and lessons learned are shared more widely.

To further strengthen our management of conflicts of interest, we have appointed the Chair of our Audit Committee as our Conflicts of Interest Guardian. This role, in collaboration with the Director of Corporate Affairs, should:

• Act as a conduit for GP practice staff, members of the public and healthcare professionals who have any concerns with regards to conflicts of interest;
• Be a safe point of contact for employees, contractors, board and committee members of the CCG to raise any concerns in relation to this policy;
• Support the rigorous application of conflict of interest principles and policies;
• Provide independent advice and judgement where there is any doubt about how to apply conflicts of interest policies and principles in an individual situation;
• Provide advice on minimising the risks of conflicts of interest.

More details on this role are contained in the Conflicts of Interest Policy.

Hard copies of all the registers are also available to view upon request at the CCG’s Headquarters.

Any suspicions or concerns of acts of fraud or bribery can be reported - see our Fraud Bribery and  Corruption Policy and  Anti-Fraud and Corruption information page, or report online via https://cfa.nhs.uk/reportfraud or via the NHS Fraud and Corruption Reporting Line on 0800 0284060 which provides a confidential route for reporting of genuine suspicions of fraud within or affecting the NHS. All calls are dealt with by experienced trained staff and any caller who wishes to remain anonymous may do so.