Conflicts of Interest

What is a conflict of interest?

A conflict of interest is a situation where an individual’s ability to apply judgment or act in delivering, commissioning, or assuring taxpayer-funded health and care services is impaired or influenced by another interest they hold. This includes potential competing interests and perceptions of impaired judgment.

How do we manage conflicts of interest?

The ICB aims to foster collaboration among local partners, to benefit the local population.  These partnerships offer numerous benefits and help ensure that public money is spent efficiently and wisely.

Despite the potential for conflicts of interest, the ICB emphasises the importance of managing these conflicts to maintain the advantages of partnership working.  The ICB 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 the ICB will be taken, and be seen to be taken, uninfluenced by external or private interests.

Conflict of Interest Policy

The ICB has an approved Conflicts of Interest Policy; developed in accordance with managing conflicts of interest in the NHS guidance.

This policy applies to all ICB members, committees, sub-committees, sub-groups, and employees. It describes how the ICB will manage conflicts arising in meetings and wider activities.

The policy also sets out the ICB’s arrangements for managing gifts and hospitality, outside employment, sponsorship and other situations where a conflict might arise.

The policy can be found here.

In addition to the arrangements set out in this policy, the ICB will embody public service values and principles in all its business transactions as outlined in the Code of Conduct and Behaviours (Standards of Business Conduct Policy); details can be found here.

Conflict of Interest Guardian

The ICB’s Non-Executive Director for Audit, who is also the Audit Committee Chair, is appointed as the Conflict of Interest Guardian with specific responsibilities as set out in the policy.

Conflict of Interest Register

The ICB is required to publish all declarations of interest for individuals deemed as ‘decision makers’ at least annually. ICB declarations of interest register is published here.

Raising concerns and investigating breaches

It is the duty of everyone to speak up about genuine concerns in relation to the administration of the ICB’s policy on Conflicts of Interest management. If an individual has any such concerns, they should not ignore such suspicions or investigate the matter themselves.

Any NHS Humber and North Yorkshire ICB employee, ICB member, committee or sub-committee member should also refer to the ICB’s  Freedom to Speak Up Policy details which can be found here.

All suspected or known breaches must be reported in the first instance in accordance with the process outlined in the Conflicts of Interest Policy.  All such notifications will always be treated with appropriate confidentiality in accordance with the ICB’s policies. An anonymised record of any breaches of the Conflicts of Interest policy will be made available on the ICB’s website. There are currently no breaches to report; details will be reported here when available.

Gifts Hospitality, Sponsorship

The ICB maintains a register of gifts, hospitality and sponsorship as set out in the conflict of interest policy, to ensure individuals do not accept gifts, hospitality, and sponsorship or other benefits which might reasonably be seen to compromise their professional judgement or integrity.

Click here for the NHS Humber and North Yorkshire ICB gifts and hospitality register.

Declarations in relation to Procurement

The ICB ensures decisions about services procured are made without questioning the motives behind the procurement decision. The procedure for managing conflicts of interest during procurements is set out in the ICB’s Procurement Policy full details can be found here.

The ICB is prohibited by law from awarding any contract where the integrity of the procurement process or the award has been, or appears to have been, affected by a conflict of interest.

The ICB maintains a register of procurement decisions, please see linked documents below:

• Procurement Register – (1 July 2022 – 31 December 2023)
• Procurement Register – Healthcare Services (from 1 January 2024 – 31 March 2025)
• Procurement Register – Outside scope of PSR (from 1 January 2024 – 31 March 2025)
• Procurement Register – Healthcare Service (from 1 April 2025 onwards)
• Procurement Register – Outside scope of PSR (from 1 April 2025 onwards)