This organization’s conflict of interest policy applies to all prospective or current employees, as well as independent contractors and persons acting on behalf of the organization.

Conflict of interest may occur whenever an employee’s interest in a particular subject may lead them to actions, activities, or relationships that undermine the company and may place it at disadvantage.

The key principles to any effective policy are as follows:

Board members must act in the best interests of [the governing body], with [the governing body’s] governing document. [Staff and volunteers have similar obligations]. Conflicts of interests may arise where an individual’s personal or family interests and/or loyalties conflict with those of [the governing body].

Such conflicts may create problems. They can:

This policy aims to protect both the organization and the individuals involved from any appearance of impropriety.

Accordingly, we ask[Board Members and all staff to declare their interests, and any gifts or hospitality received in connection with their role in Sphere Specialist Healthcare Ltd. A declaration of interests form is provided for this purpose, listing the types of interest you should declare.
To be effective, the declaration of interests needs to be updated at least annually, and when any changes occur.
If you are not sure what to declare or whether/when your declaration needs to be updated, please err on the side of caution. If you would like to discuss this issue, please contact the governing body secretary or Case Managers for confidential guidance. Interests will be recorded on the governing body’s register of interests, which will be maintained by the Registered Manager. The register will be accessible by level of access.

The information provided will be processed in accordance with data protection principles as set out in data protection legislation. Data will be processed only to ensure that Board Members and all staff act in the best interests of Sphere Specialist Healthcare Ltd]. The information provided will not be used for any other purpose.

If you are a user of Sphere Specialist Healthcare Ltd services or the carer of someone who uses Sphere Specialist Healthcare Ltd services, you should not be involved in decisions that directly affect the service that you or the person you care for receive(s). You should declare your interest at the earliest opportunity and withdraw from any subsequent discussion. The same applies if you face a conflict for any other reason. You may, however, participate in discussions from, e.g. where the benefits are universal to all users or where your benefit is minimal.
If you fail to declare an interest that is known to the Chairman will declare that interest.

In the event of the board having to decide upon a question in which a board member or member of staff has an interest, all decisions will be made by vote, with a simple majority required. A quorum must be present for the discussion and decision; interested parties will not be counted when deciding whether the meeting is quorate.

Interested board members may not vote on matters affecting their own interests. They may participate in the discussion but not the decision-making process].
All decisions under a conflict of interest will be recorded by Registered Manager and be reported in the minutes of the meeting. The report will record:

A de minims exemption applies to contracts less than £15 in value. Random checks against the register of interest will be made on the award of contracts below this value. If the cumulative value of a series of small contracts exceeds £50, the board member will operate the policy used for individual contracts over that sum.

The de minims exemption does not apply to contracts of employment with Sphere Specialist Healthcare Ltd.
Independent external moderation will be used where conflicts cannot be resolved through the usual procedures through an independent arbitration service.

If you have a conflict of interest, you must not be involved in managing or monitoring a contract in which you have an interest. Monitoring arrangements for such contracts will include provisions for an independent challenge of bills and invoices, and termination of the contract if the relationship is unsatisfactory.

Bribery and Corruption
Duty of Candour
Data Protection Legislative Framework (GDPR)
Fit and Proper Persons – Directors
Position of Trust

Managing conflicts of interest:
https://www.nhsemployers.org/

Acas Contracts of employment:
http://www.acas.org.uk/

All staff, during induction, are made aware of the organisation’s policies and procedures, all of which are used for training updates. All policies and procedures are reviewed and amended where necessary, and staff are made aware of any changes. Observations are undertaken to check skills and competencies. Various methods of training are used, including one to one, online, workbook, group meetings, and individual supervisions. External courses are sourced as required.

Date Reviewed: May 2021
Person responsible for updating this policy: Carly Fortune
Next Review Date: May 2022