Avoiding Conflicts of Interest

What is a conflict of interest?

A conflict of interest is circumstances that risk someone’s ability to apply judgement or act in one role being impaired or influenced by another interest they have.

There is potential for conflicts of interest in both the public (like the NHS and Council) and private sectors (businesses).  While it may not be reasonable or efficient to remove the risk of conflicts of interest entirely,  we have to recognise the risks and put measures in place to identify and manage conflicts if they arise.

Because they are also providers of local clinical services, GP commissioners are likely to have potential conflicts of interest.

All local GP practices are members of the CCG. Some GPs, along with other clinical experts, CCG officials and lay members, are members of our governing body. This means there is the potential for some GPs and their colleagues to make commissioning decisions about services they provide, or in which they have an interest. Where this is the case, there is a risk that commissioners could put, or people might think they put, personal interests ahead of patients’ interests.

Conflicts of interest are inevitable, but in most cases it is possible to handle them with integrity and probity by ensuring they are identified, declared and managed in an open and transparent way.

The CCG has put in place robust arrangements to seek to manage conflicts when making commissioning decisions. These measures are outlined in our Standards of Business Conduct and Management of Conflict of Interest Policy. These measures aim to ensure decisions made by the CCG will be taken, and seen to be taken, uninfluenced by external or private interests.

To further strengthen scrutiny and transparency of CCG’s decision-making processes the CCG has an appointed Conflict of Interest Guardian.  This role is undertaken by the CCG’s Integrated Governance & Audit Chair

You can find our Declaration of Interests & Gifts & Hospitality register  here. 

There have been no reported gifts/hospitality at during 2016/17

Declaration of interest records will be retained and disposed of appropriately and securely as specified in the CCG Corporate Records Management Standards and Procedural Policy.   Any request for historical information must be submitted to the CCG’s Chief Finance Officer.

The CCG is required to publish any breaches in relation to the CCG’s Conflicts of Interest Policy. There have been no reported breaches during 2016/17.

Our Bribery Act statement can be found here.

The CCG’s Contract Database can be viewed here.

References & Guidance