Conflicts of Interest Management and Standards of Business Conduct
For information on how the ICB manages conflicts of interest please view our Conflicts of Interest Management & Standards of Business Conduct Policy
As part of our commitment to openness and transparency, we maintain and publish:
- comprehensive lists of procurement decisions;
- a Register of Interests;
- a Gifts, Hospitality & Sponsorship Register; and
- details of any expenditure over £25k.
These can be found in the relevant sections below.
The Register of Interests is published under the “Conflicts of Interest” section below, each month.
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Conflicts of Interest
Conflicts of Interest
Register of Interests
The full Register of Interests is published on a monthly basis.
BLMK ICB Register of Interests as at 09.07.2025
Breaches
As part of openness and transparency we publish details of any breaches of the Conflict of Interest Management and Standards of Business Conduct Policy.
In 2024/25 there was a minor breach of the policy (failure to declare the offer of hospitality within 28 days of the offer being made). Actions were taken to reinforce this requirement of the policy.
To date, no breaches have occurred during 2025/26.
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Gifts, Hospitality & Sponsorship
Gifts, Hospitality & Sponsorship
'Gift' is defined as any item of cash or goods, or any service, which is provided for personal benefit, free of charge or at less than its commercial value.
‘Hospitality’ means offers of meals, refreshments, travel, accommodation, and other expenses in relation to attendance at meetings, conferences, education and training events etc.
The Conflicts of Interest Management & Standards of Business Conduct Policy specifies the criteria for the 'sponsorship' of events, research and posts that are to be managed and declared.
To date, no offers of gifts, hospitality or sponsorship have been recieved.
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Procurement Decisions & Contracts Awarded
Procurement Decisions & Contracts Awarded
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Expenditure Spend over £25k’
Expenditure Spend over £25k’
Expenditure Over £25k M03 June 2022
Expenditure Over £25k M04 July 2022
Expenditure Over £25k M05 August 2022
Expenditure Over £25k M06 September 2022
Expenditure Over £25k M07 October 2022
Expenditure Over £25k M08 November 2022
Expenditure Over £25k M09 December 2022
Expenditure Over £25k M10 January 2022/23
Expenditure Over £25k M11 February 2022/23
Expenditure Over £25k M12 March 2022/23
Expenditure Over £25k M01 April 2023/24
Expenditure Over £25k M02 May 2023/24
Expenditure Over £25k M03 June 2023/24
Expenditure Over £25K M04 July 2023/24
Expenditure Over £25k M05 August 2023/24
Expenditure Over £25k M06 September 2023/24
Expenditure Over £25k M07 October 2023/24
Expenditure Over £25k M08 November 2023/24
Expenditure Over £25k M09 December 2023/24
Expenditure Over £25K M10 January 2023/24
Expenditure Over £25K M11 February 2023/24
Expenditure Over £25K M12 March 2023/24
Expenditure Over £25K M01 April 2024/25
Expenditure Over £25K M02 May 2024/25
Expenditure Over £25k M04 June 2024/25
Expenditure Over £25k M04 July 2024/25
Expenditure Over £25k M05 August 2024/25
Expenditure Over £25k M06 September 2024/25
Expenditure Over £25k M07 October 2024/25
Expenditure Over £25k M08 November 2024/25
Expenditure Over £25k M09 December 2024/25
Expenditure Over £25k M10 January 2024/25
Expenditure Over £25k M11 February 2024/25
Expenditure Over £25k M12 March 2024/25
Expenditure Over £25k M01 April 2025/26
Expenditure Over £25k M02 May 2025/26
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Conflict of Interest Guardians
Conflict of Interest Guardians
The Chair of the Audit & Risk Assurance Committee, Vineeta Manchanda is the ICB’s Conflict of Interest Guardian. In collaboration with the Head of Governance, their role is to:
- Act as a conduit for members of the public who have any concerns with regards to conflicts of interests;
- Be a safe point of contact for employees, workers, or members of the ICB to raise any concerns in relation to conflicts of interests;
- Support the rigorous application of conflict of interest principles and policies;
- Provide independent advice and judgment to staff and members where there is any doubt about how to apply the Conflict of Interest Policy and principles in an individual situation; and
- Provide advice on minimising the risks of conflicts of interests.
The Conflict of Interest Guardian can be contacted by emailing blmkicb.contactus@nhs.net or vineeta.manchanda2@nhs.net