Conflicts of interests

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?

Camden Clinical Commissioning Group (Camden CCG) is responsible for commissioning healthcare services to improve the health and wellbeing of people in the London Borough of Camden.  It decides which services the people of Camden 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 legal 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 Camden CCG manage conflicts of interest?

Camden CCG takes its responsibility to manage conflicts of interest seriously and has a Conflict of Interest Policy.

What does the policy require individuals to do?

The Policy sets out how Camden CCG Governing Body members, officers, staff, members and clinical leads should behave in their role at Camden CCG.  It also sets out the steps and measures that Camden 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.

Common types of conflicts of interest

The most common types of conflicts of interest include:

  • Direct financial interests;
  • Indirect financial interests;
  • Non-financial personal interests;
  • Conflicts of loyalty.

 See common types of conflicts of interest for an explanation of each of the types listed above.

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.

In most instances the individual with a conflict of interest will be removed from decision making on that particular issue.  In the rare instance that this is not possible, the CCG manages the risk of improper or undue influence carefully. This includes documenting how the conflict of interest has been assessed, controlled and managed.

CCG staff members are also required to tell their line manager and governance team about any conflict of interest they have or think they may have. To find out how the CCG manages conflicts of interest, read these potential conflict of interest scenarios.

Where can I find Camden CCG’s conflicts of interest information?

We are required to publish all conflicts of interests, available in the downloads section.

If you have any questions about our Conflicts of Interest Policy please email Kofo Abayomi, Board Secretary, at kofo.abayomi@nhs.net

New NCL Conflicts of Interest Policy

The NCL Audit Committee in Common approved the new NCL Conflicts of Interest Policy on 27th March 2019.  Key amendments to the policy include:

  • Policy update to reflect NHS England Best Practice guidance on gifts, hospitality and sponsorship - February 2019;
  • Streamlining of Gifts, Hospitality and Sponsorship policies into one place across NCL;
  • Strengthens guidance on conflicts of interest for collaborative decision making with partners and through the commissioning cycle; and
  • Minor amendments to the wording to make the policy easier to read and apply.

New NCL Standards of Business Conduct Policy

The NCL Audit Committee in Common approved the new NCL Standards of Business Conduct Policy on 27th March 2019.  Key highlights include:

  • Sets out expected Standards of Business Conduct;
  • Cross-references to existing policies for ease of reference and use;
  • Practical guidance relating to Charitable Collections, Political activity, and personal conduct; and
  • Robust raising concerns and breaches of policy protocol.