Conflicts of Interest

What is a conflict of interest?

The NHS England “Managing Conflicts of Interest: Revised Statutory Guidance for CCGs” June 2017 Guidance on Managing Conflicts of Interest states that : “A conflict of interest is defined as ‘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 potential for competing interests and / or a perception of impaired judgement or undue influence can also be a conflict of interest.

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

CHCP CIC recognises that conflicts of interest are unavoidable and therefore has in place arrangements to seek to manage them. The measures outlined in our policy are aimed at ensuring that decisions made by CHCP CIC will be taken, and be seen to be taken, uninfluenced by external or private interests.

Gifts and Hospitality

CHCP CIC maintains a register of gifts and hospitality and robust processes are in place to ensure individuals do not accept gifts, hospitality or other benefits which might reasonably be seen to compromise their professional judgment or integrity. The register will be reviewed by the Audit Committee at least annually with an assurance report provided annually to CHCP CIC. All individuals need to consider the risks associated with accepting gifts, hospitality, or other benefits, particularly during procurement exercises. The acceptance of gifts could give rise to real or perceived conflicts of interests or accusations of unfair influence, collusion, or canvassing.

Conflict of Interest Register

CHCP CIC is required to publish all declarations of interest for individuals deemed as ‘decision makers’ at least annually. Information about CHCP CIC staff’s declarations of interest are published here.