Declarations of Interest

The ICB has agreed policies and procedures for the identification and management of conflicts of interest (including gifts and hospitality) and these are published in the governance handbook. 

The policy provides guidance on the declaration, consideration, management and publication of any conflicts of interests (including gifts and hospitality) and is summarised below:

  • Financial interests – where an individual may get a direct financial benefit from the consequence of a decision they are involved in making
  • Non-financial professional interests – where an individual may obtain a non-financial professional benefit from the consequence of a decision they are involved in making.
  • Non-financial personal interests – 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 – 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 and could stand to benefit from a decision they are involved in making.

All relevant and material interests should be declared in the following circumstances:

  • On appointment the ICB.
  • Annually (ICB led review for confirmation of no changes).
  • When staff move to a new role, or their responsibilities change significantly.
  • At the beginning of a new project or piece of work.
  • As soon as circumstances change and new interests arise (for instance, in a meeting when interests staff hold are relevant to the matters in discussion).

There is also a requirement to notify any change to your declaration at the earliest opportunity (and in any event within 28 days after the interest arises). 

The ICB maintains a register of gifts and hospitality.  The overarching principles include the following:

Gifts

  • Staff should not accept gifts that may affect, or be seen to affect, their professional judgement;
  • Any personal gifts of cash or cash equivalents (eg: vouchers, tokens, offers of remuneration to attend meetings) must always be declined
  • Gifts from suppliers or contractors should be declined unless of small value (low cost branded promotional aid such as pens or post it notes under £6)
  • Modest gifts under the value of £50 may be accepted from patients, families and service users and do not need to be declared
  • Gifts valued at over £50 should be treated with caution and only accepted on behalf of an organisation and not in a personal capacity and must be declared  

Hospitality

  • Staff should not accept hospitality that may affect or be seen to affect their professional judgement
  • Hospitality must only be accepted when there is a legitimate business reason and is proportionate to the nature and purpose of the event
  • Hospitality under the value of £25 may be accepted and need not be declared. 
  • Of a value between £25 and £75 may be accepted and must be declared. 
  • Of a value over £75 should be refused (unless in exceptional circumstances) and senior approval is given. 
  • A clear reason for accepting should be recorded on the Register.

Offers of gifts and hospitality that have been accepted or declined should be recorded on the gifts and hospitality and register.

If you need to declare a declaration or receipt or offers of any gifts or hospitality, forms can be obtained from Claire Moore via lscicb.governanceteam@nhs.net.

If you are unsure about whether to declare an interest or gift/hospitality, please contact Claire Moore via lscicb.governanceteam@nhs.net or the ICB’s conflict of interest guardian:

Jim.birrell@nhs.net  (audit committee chair)

For information, the conflict of interest policy is available here.

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