Standards of Business Conduct: Declaring Interests and Managing Conflicts in the NHS
To page will equip all NHS staff with practical guidance on identifying, declaring, and managing conflicts of interest. For more details on any specific aspect covered within this training, please refer to (add link to SG policy).
Learning Objectives
Learning Objectives
Section 1: Why Declarations Matter
One of our core values in the NHS is Openness, Honesty and Respect. Putting the interests of the public first, in how we care and how we use public resources, is at the heart of what we do.
There are times where we may need to consider potential conflicts of interest – this might relate to other jobs we have, connections through our families and friends, or gifts and hospitality.
It can be an actual conflict or a perceived conflict.
By applying the tools set out in this guide, you are helping to foster a culture of openness and compliance, and helping to reduce scope for fraud, bribery and corruption.
As NHS staff, it is important that we:
- Safeguard public trust and organisational integrity, which are core NHS principles.
- Act transparently, honestly, and ethically, especially when declaring interests and managing conflicts.
- Uphold the reputation of the NHS and the confidence the public can have that we put them first.
- Proactively identify and declare interests, including financial gain, voluntary roles, or benefits to friends/family which helps to prevent suspicion or accusations of impropriety.
- Protect our organisations from fraud and misconduct and reassure the public that NHS staff uphold the highest standards.
- Strengthen the NHS’s commitment to impartiality, compliance, and ethical conduct, maintaining public trust and organisational integrity.
The overarching message is that if you are in any doubt, declare. It’s better to declare something that does not need to be declared, rather than keep quiet where there may be a conflict.
Section 2: What do NHS Scotland staff need to consider in relation to conflicts of interest?
All NHS Scotland staff need to ensure that they:
- Put the interests of people in their care first before their own, or those of any colleague, business, organisation, close family member or friend.
- Maintain appropriate personal and professional boundaries with the people they provide care to and with others.
- Consider carefully where conflicts of interest may arise – or be perceived to arise – and seek advice if they are unsure how to handle this.
- Be open about any conflict of interest they face, declaring it formally when appropriate and as early as possible, in line with the policies of their employer or the organisation contracting their services.
- Ensure their professional judgement is not compromised by personal, financial, or commercial interests, incentives, targets, or similar measures.
- Refuse all but the most trivial gifts, favours or hospitality if accepting them could be interpreted as an attempt to gain preferential treatment or would contravene your professional code of practice.
- Where appropriate, ensure that patients have access to visible and easy-to-understand information on any fees and charging policies for which you are responsible
Section 3: Decision Tree
Use this decision tree to help you think through any actions you may need to take in relation to a conflict of interest.
- Questions to ask yourself to decide if you need to make a declaration:
- Does it involve money, gain, or avoiding loss?
- Is it a voluntary/advisory role or charity involvement?
- Does a friend/family member benefit?
- Is there a gift or hospitality involved?
- Outcome: Declare if any answer is “Yes”.
Section 4: Practical Scenarios
There are 4 categories of interest:
- Direct financial interests, which can include, shareholding or ownership interests, outside employment, patents or intellectual property rights, donations, sponsored events, sponsored research, sponsored posts, clinical private practice.
- Non-financial interests, which can include, research roles, advisory roles, voluntary roles,
- Indirect interests where you have a close associate who could stand to benefit from a decision.
- Gifts and hospitality, this can be complex, but as a general rule if it is easy to avoid or decline gifts or hospitality, then do so. It can relate to events, hospitality, advertising of medicinal products or gifts.
The examples below show some potential scenarios which may help you consider any potential conflict.
Scenario 1- Other employment
Scenario 2: Shortlisting a friend
Scenario 3: Private practice
Scenario 4 : Volunteering
Scenario 5 : Hospitality
Scenario 6 : Repeated Gifts
Section 5: How to Declare
This is a step-by-step guide to help you with declaring an interest.
Step-by-step guide to help you with declaring an interest
For additional help:
- refer to your local HR documentation
- use links to TURAS
- use the decision tree
- consider the scenarios
Section 6: Worked examples: Conflicts of Interest
1. Direct Financial Interests
Scenario:
A procurement manager’s partner owns a catering company that is bidding for an NHS contract.
Action:
The manager must declare this relationship and withdraw from any involvement in the procurement process for that contract.
2. Non-Financial Interests
Scenario:
A senior nurse volunteers (unpaid) for a charity that is applying for NHS funding.
Action:
The nurse should declare this voluntary role as it could influence, or be perceived to influence, decisions about funding.
3. Indirect Interests
Scenario:
A staff member’s close friend is applying for a job in their department.
Action:
The staff member should declare the relationship and not participate in the recruitment or selection process.
4. Gifts and Hospitality
Scenario:
A supplier offers a staff member a £30 gift voucher as thanks for feedback on a product.
Action:
The staff member must politely decline the gift and report the offer to their line manager.
5. Secondary Employment
Scenario:
A physiotherapist works part-time for a private clinic that also provides services to the NHS Board.
Action:
This dual role must be declared and managed to ensure there is no conflict between NHS and private work.
6. Procurement and Contract Management
Scenario:
A staff member responsible for monitoring a supplier’s contract develops a personal relationship with an employee of that supplier.
Action:
The staff member should declare the relationship and be removed from contract monitoring duties for that supplier.
7. Recruitment
Scenario:
A manager is on an interview panel and recognises a candidate as a family friend.
Action:
The manager should declare the relationship and step back from the decision-making process for that candidate.
8. Social Media Endorsements
Scenario:
A staff member is approached by a supplier to share a positive review of their product on social media, in exchange for a small gift.
Action:
The staff member should decline the offer and report it to their line manager, as accepting could be seen as an endorsement and a conflict of interest.
9. Charitable Fundraising and Sponsorship
Scenario:
A team is organising a fundraising event for a local charity and a regular NHS supplier offers to sponsor the event in return for prominent branding at the venue.
Action:
The team should declare the sponsorship offer and seek advice from procurement and governance leads to ensure transparency and avoid any perception of undue influence.
10. Personal Relationships and Performance Management
Scenario:
A manager is responsible for conducting a performance review for a staff member who is also a close family friend.
Action:
The manager should declare the relationship and arrange for another manager to conduct the review to maintain objectivity.
11. Use of NHS Resources for Personal Projects
Scenario:
A staff member uses NHS equipment and time to work on a personal business venture.
Action:
This is not permitted under the Standards of Business Conduct. The staff member should be reminded that NHS resources are for official use only, and any misuse should be reported and managed in line with local policy.
12. Invitations to Speak at External Events
Scenario:
A clinician is invited to speak at an industry-sponsored conference, with travel and accommodation expenses covered by the organiser.
Action:
The clinician should declare the invitation and seek approval from their line manager, ensuring any acceptance is recorded and does not create a conflict with their NHS role.
13. Discounts and Loyalty Schemes
Scenario:
A supplier offers a staff member a personal discount on products not available to all NHS staff.
Action:
The staff member should decline the offer and report it, as personal inducements from suppliers are not permitted.
Section 7: Assessment & Reflection
Work through the below questions and record your answers in a word document. You can check the answers after this:
- What is a conflict of interest?
- Do I need to declare interests if I don’t think they affect my work?
- What if I receive a small gift from a patient or supplier?
- What about hospitality, such as meals or event tickets?
- How do I declare an interest?
- What happens after I declare an interest?
- What if I’m unsure whether something is a conflict of interest?
- Are there consequences for not declaring a conflict of interest?
- Can I accept a discount offered to NHS staff?
- What about secondary employment or voluntary work?
Other resources
All the statutory regulators of health and care professionals have ethical standards which professionals are expected to observe, and have separately published the ethical requirements for their professionals, for example: