Conflicts of Interest Management and Standards of Business Conduct

Conflicts of Interest Management and Standards of Business Conduct image

Home » About Us » Governance » Conflicts of Interest Management and Standards of Business Conduct

Conflicts of Interest Management and Standards of Business Conduct

As part of our commitment to openness and transparency, we maintain and publish:

  • comprehensive lists of procurement decisions;
  • registers of declared interests;
  • details of any gifts and hospitality received; and
  • -details of any expenditure over £25k. 

These can be found in the relevant sections below.

  • Conflicts of Interest

    Conflicts of Interest

    A ‘conflict of interest’ is: “a set of circumstances by which a reasonable person would consider that an individual’s ability to apply judgement or act, in the context of delivering, commissioning, or assuring taxpayer funded health and care services is, or could be, impaired or influenced by another interest they hold.”

    A conflict of interest may be:

    • Actual - there is a material conflict between one or more interests;
    • Potential – there is the possibility of a material conflict between one or more interests in the future; or
    • Perceived – where an observer could reasonably suspect there to be a conflict of interest regardless of whether there is one or not. Individuals may hold interests for which they cannot see potential conflict. However, caution is always advisable because others may view it differently and perceived conflicts of interest can be damaging. All interests should be declared where there is a risk of perceived improper conduct.

    For information on how the ICB manages conflicts of interest please view our Conflicts of Interest Management & Standards of Business Conduct Policy which can be found here

    A copy of our Declaration of Interest Form can be found here

    Register of Interests

    We have clear processes in place on how we manage potential Conflicts of Interest and we maintain a register of interests which can be found here

    Conflicts of Interest Breaches

    There have been no breaches reported regarding interests so far in the 2022-23 financial year (since becoming an ICB on 1 July 2022).

    Conflict of Interest Guardians

    The Chair of the Audit & Risk Assurance Committee (Andrew Blakeman) is the ICB’s Conflict of Interest Guardian. In collaboration with the Head of Governance, their role is to:

    1. Act as a conduit for members of the public who have any concerns with regards to conflicts of interests;
    2. Be a safe point of contact for employees, workers, or members of the ICB to raise any concerns in relation to conflicts of interests;
    3. Support the rigorous application of conflict of interest principles and policies;
    4. 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
    5. 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 Andrew.blakeman@nhs.net

  • Gifts and Hospitality

    Gifts and Hospitality

    A '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.

    For information on how the ICB manages conflicts of interest please view our Conflicts of Interest Management & Standards of Business Conduct Policy which can be found here

    A copy of our Declaration of Gifts & Hospitality can be found here

    No gifts or hospitality have been declared so far in the 2022-23 financial year (since becoming an ICB on 1 July 2022).

  • Procurement Decisions & Contracts Awarded

    Procurement Decisions & Contracts Awarded

  • Expenditure Spend over £25k’

    Expenditure Spend over £25k’