Published on: 17 May 2023

The Trust’s Standards for 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 and should include any interest that could conflict with the impartial discharge of their duties and which could cause conflict between their private interests and their NHS duties. The policy serves as an important defence against any actions brought under the 2010 Bribery Act.  

 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, must provide an annual return for declarations of interest, as described below.  Declarations of interest should be discussed with line managers so actions can be agreed to mitigate any risk to the individual and the organisation. 

 Staff must now record any declarations of interests (including gifts and hospitality) using ESR.  This must be completed detailing any declaration or indicating notification of a nil return by Friday 26 May 2023.  A paper will then be presented Executive Committee, before the report is published on the Trust's website.

A full guide on how to record any declarations can be viewed here: Using_ESR_for_Declarations.pdf (stsft.nhs.uk).

If you have any queries, please contact Joanne Williamson, Assistant Trust Secretary, on ext 2171 or via email to joannewilliamson3@nhs.net. 

Guidance - Band 7 staff and above: 

 Interests which are regarded as ‘relevant and material’ are: 

a)      Directorships, including non-executive directorships held in private companies or PLCs (with the exception of those of dormant companies)

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

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

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 NHS services 

 Financial interests - This is where an individual may get direct financial benefits from the consequences of a decision they are involved in making. 

 Private Clinical Practice - Any interests relating to clinical private practice must be fully declared. 

 Non-financial professional interests - This is where an individual may obtain a non-financial professional benefit from the consequences of a decision they are involved in making, such as increasing their professional reputation or status or promoting their professional career. 

 Non-financial personal interests - This is where an individual may benefit personally in ways which are not directly linked to their professional career and do not give rise to a direct financial benefit, because of decisions they are involved in making in their professional career. 

 Indirect interests - This is where an individual has a close association with another individual who has a financial interest, a non-financial professional interest or a non-financial personal interest who would stand to benefit from a decision they are involved in making  

 A benefit may arise from either a gain or avoidance of a loss.  

 Further details are available in the Standards for Business Conduct policy which can be viewed here: 

STS-CA3.SBC.V1.9_-_Standards_for_Business_Conduct_Policy_-_November_2019_updated_Nov_21_Jan_22_and_Feb_22.pdf (stsft.nhs.uk)

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