How we manage conflicts of interest (COI)

The NHS Thames Valley Board conflicts of interest policy ensures that we meet the revised NHS England Managing Conflicts of Interest Statutory Guidance published on 19 September 2024.

This policy applies to all NHS Thames Valley employees, Board members and members of Committees, as well as NHS Thames Valley partners including primary care, secondary care, and local authority staff members.

The conflicts of interest policy enables NHS Thames Valley to demonstrate that it is acting fairly and transparently and in the best interest of our patients and local population.

The policy aims to:

• Safeguard clinically-led commissioning, whilst ensuring objective investment decisions.
• Enable NHS Thames Valley to demonstrate that it is acting fairly and transparently and in the best interest of our patients and local population.
• Uphold confidence and trust in the NHS.
• Support NHS Thames Valley to understand when conflicts (whether actual or potential) may arise and how to manage them if they do.
• Ensure that NHS Thames Valley operates within the legal framework.

A conflict of interest occurs where an individual’s ability to exercise judgement, or act in a role is, could be, or is seen to be, impaired or otherwise influenced by his or her involvement in another role or relationship. In some circumstances, it could be reasonably considered that a conflict exists even when there is no actual conflict. In these cases, it is important to still manage these perceived conflicts in order to maintain public trust.

It is not possible, or desirable, to define all instances in which an interest may be a real or perceived conflict. It is for each Individual to exercise their judgment in deciding whether to register any interests that may be construed as a conflict. If any Individual is unsure as to whether an interest should be declared then he or she should seek guidance from the Governance Team or, if relevant, from the committee or sub- committee chair. Please view list of Conflicts of Interest Definitions.

All NHS Thames Valley members and employees are required to declare any relevant and material personal or business interests and any relevant and material personal or business interests of their spouse, civil partner, co-habitee, family member or close friend which may influence or may be perceived to influence their judgement.

The full register of declarations of interests for our Board is being developed following appointments of Board members and will be available here as soon as it has been completed.

Our register of declarations of interests for decision-making members of staff is being updated and will be available here as soon as it has been completed.

Our register of Gifts, Hospitalities and Commercial Sponsorships is being updated and will be available here as soon as it has been completed.

The Register of Procurement Decisions for NHS Thames Valley is being developed and will be published here when it becomes available.

A Register of Procurement Decisions for the ICB’s predecessor organisation – Buckinghamshire, Oxfordshire and Berkshire West Integrated Care Boad and NHS Frimley Integrated Care Board.

NHS Thames Valley further maintains a Register of Breaches of the Conflicts of Interest Policy (opens in PDF document) which sets out details of any breach, how it has been investigated and notification of the breach to NHS England. All breaches are reported to NHS Thames Valley's Audit Committee. Anonymised details of breaches are published for the purpose of learning and development.

To further strengthen scrutiny and transparency of NHS Thames Valley's decision-making processes, NHS Thames Valley has a Conflicts of Interest Guardian.

The Conflicts of Interest Guardian is normally the Non-Executive Member who has qualifications, expertise or experience to enable them to lead on finance and audit matters.

Further information and advice is available through NHS Thames Valley's Conflicts of Interest Guardian who:

• Acts as a conduit for GP practice staff, members of the public and healthcare professionals who have any concerns with regards to conflicts of interest.
• Is a safe point of contact for employees or workers of NHS Thames Valley to raise any concerns in relation to this policy.
• Supports the rigorous application of conflict-of-interest principles and policies.
• Provides independent advice and judgment where there is any doubt about how to apply conflicts of interest policies and principles in an individual situation.
• Provides advice on minimising the risks of conflicts of interest.