The Trust’s Standards of Business Conduct policy describes the business conduct behaviour required by all staff who potentially may benefit as the recipient of gifts, hospitality or sponsorship arrangements. The policy serves as an important defence against any actions brought under the 2010 Bribery Act. The policy will help staff manage conflicts of interest risks effectively by:

 

  • Introducing consistent principles and rules
  • Supporting good judgement about how to approach and manage interests
  • Providing advice about what to do in common situations, such as: conflicts of interests; offers of gifts and hospitality, alternative employment, patents, loyalty interests, donations, sponsorship of events, sponsored research.

Whilst this policy applies to all staff there is a requirement for all Trust staff at Agenda for Change Band 7 and above, all consultants, speciality and associate speciality doctors, and those senior members of staff on local Trust terms and conditions, to provide an annual return via a positive or nil return for declarations of interest, gifts, hospitality or sponsorship to the value of £25 and over that they either receive or decline.   Declarations of interest should be discussed with line managers so actions can be agreed to mitigate any risk to the individual and the organisation.

 

The policy complies with the requirements of NHS England’s Managing Conflicts of Interests in the NHS. 

 

The policy can be found below along along with a user guide for recording declarations on ESR.  

 

Standards of Business Conduct Policy (includes declaration of interests, gifts, sponsorship and hospitality)

Recording Declaration and Interests Using ESR

 

 

 

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