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.
We are responsible for commissioning healthcare services to improve the health and wellbeing of people in Kent and Medway.
As a body, we decide which services the people of Kent and Medway most need and pay local hospitals and other healthcare providers to provide these services.
In addition, we hold healthcare providers to account to make sure they provide the services paid for.
Therefore, it is important to manage conflicts of interest to:
We take our responsibility to manage conflicts of interest seriously and have an approved standards of business conduct policy.
The policy sets out how board members, officers, staff, members and clinical leads should behave in their role.
It also sets out the steps and measures that we take to manage conflicts of interest.
An example of this is that the policy requires those people referred to above to declare any and all interests which may be, or may lead to, a conflict of interest.
The most common types of conflicts of interest include:
An explanation of each of the types of conflicts of interest listed above can be found in the standards of business conduct policy.
When a conflict of interest is identified it should always be disclosed, as openness and transparency allows for conflicts and potential conflicts of interest to be assessed and managed. This includes publishing all conflicts of interest.
In most instances the individual with a conflict of interest will be removed from decision making on that particular issue.
In the rare instance that this is not possible, we manage the risk of improper or undue influence carefully.
This includes documenting how the conflict of interest has been assessed, controlled and managed.
Staff members are also required to tell their line manager and the compliance team about any conflict of interest they have or think they may have.
Potential conflict of interest scenarios are:
To further strengthen scrutiny and transparency of decision-making processes, we have appointed a conflicts of interest guardian.
This role is carried by the Audit Committee chair.
The role of the conflicts of interest guardian is to work, in collaboration with the company secretary to:
Whilst the conflicts of interest guardian has an important role within the management of conflicts of interest, executive members of the organisation have an ongoing responsibility for providing robust management of conflicts of interest, and all employees, board and committee members continue to have individual responsibility in playing their part on an ongoing and daily basis.
To contact the conflicts of interest guardian, please mark your communication for the attention of Conflicts of interest guardian, and send by email to kmicb.generalenquiries@nhs.net or by post to:
NHS Kent and Medway
Kent House
81 Station Road
Ashford
TN23 1PP
As set out by NHS England, we are required to publish all conflicts of interest. The registers are published on this page of the website.
If you have any questions about ourstandards of business conduct policy please email kmicb.compliance@nhs.net.