Northumberland LMC – Conflict of Interest Policy
January 2014
Introduction
It is essential to maintain and ensure integrity of the Northumberland LMC and that they have a
clear process and policy for managing Conflicts of Interest. Moreover, with the introduction of
Clinical Commissioning Groups (CCG) there will be GPs who may have a role within a CCG and be
member of their Local Medical Committee. There may be involvement with a number of other NHS
or non-NHS organisations where there may be a potential conflict of interest.
Having involvement in other organisations whether NHS or non-NHS does not preclude involvement
with the LMC. The intention of a clear governance process is to provide transparency where a
conflict does arise and what action is taken to ensure that that individual does not unduly influence
a debate, policy or decision taken within Northumberland LMC.
Principles
This paper sets out the position for Northumberland LMC. The principles for this policy are:
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Openness – being open about our process for managing Conflict of Interest
Transparency – having a transparent decision-making process within the LMC
Challenge – being happy to receive challenge on these processes at any stage, as this may
help identify an issue.
3-Part process
Due to the changing role and remit of NHS organisations and similarly for individuals there is a need
to self-report any potential conflict of interest.
Northumberland LMC have identified a 3 part process for managing conflicts of interest
1. Annual declaration – as part of the 3 yearly election process all LMC candidates are asked as
part of their nomination to list organisations that they work with, have a connection and/or
affiliation to. This ensures the LMC are made aware of the potential conflict(s) which may
arise.
Northumberland LMC will request all LMC members to provide an updated list of interests
and involvements in NHS and non-NHS organisations.
2. Northumberland Local Medical Committee meetings – An agenda item will be placed at the
start of all agendas for members to identify the following;
a. Where that member may have a conflict with an item on that agenda.
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January 2014 – Policy agreed by LMC meeting 10th January.
Review January 2016
b. To agree with the Chair/Vice Chair whether that member is able to partake in that
discussion.
c. To minute and register where conflicts of interest are identified and what action was
taken by the Chair/Vice Chair.
d. For any member to raise a concern of conflict of interest about any other member,
without prejudice.
3. Register of Interests – Whilst an Annual declaration is helpful it is also the responsibility of
all LMC members, as part of their role to inform the Executive Officer of the
Northumberland LMC of any updates/additions/removals from their register of interests.
The Conflicts identified should be both actual and perceived. This responsibility lies solely
with the LMC member.
Annual Declaration
A full declaration is required by each member who is being proposed to join the LMC at the start of
new committee tenure (3 yearly).
This declaration will be updated annually at the beginning of the new financial year and published on
the LMC website.
The annual declaration will form part of the register of interests and:
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Provide the name and GP practice address of the GP.
What locality they are representing in Northumberland.
List the interests (or new additional interests) at the start of the new financial year.
Will delete any out of date conflicts of interests to ensure fairness to that member (i.e. if a
member has stopped their involvement with an organisation then they can remove their
actual or perceived conflict of interest with that organisation).
Local Medical Committee meetings
At each meeting an agenda item will request members to alert the Chair/Vice Chair of any actual or
perceived conflicts that may arise on that agenda OR where they believe that of another member of
the committee. The latter ensures appropriate challenge and scrutiny of the manner in which the
LMC conducts its’ business.
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The Chair/Vice Chair will decide whether a member should:
o Be allowed to continue to partake ‘fully’ (including voting rights, where a vote is
required) in the agenda item where an actual or perceived conflict of interest has
been identified by that member.
o Be allowed to partake ‘in-part’, but that member will not be able to vote, where a
vote is required.
o Whether that member should leave the meeting for that agenda item where an
actual or perceived conflict of interest has been identified.
The minutes of the meeting will note the Conflicts of interest identified and what action was
taken by the committee.
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January 2014 – Policy agreed by LMC meeting 10th January.
Review January 2016
The Register of Interests
This will be managed and maintained by the Executive Officer of the LMC. It will:
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Be updated annually.
Updated as required as a result of LMC members informing the Executive officer and change
to these interests.
It will be accessible on the Northumberland LMC website.
Add or remove interests of members throughout the year.
Categories of Conflict of Interest
Categories of Conflict of interest for consideration are (but not exclusively):
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Where the member undertakes a new role.
Where the member has a change to their role or their responsibilities.
Where members have a change of circumstances.
Roles and responsibilities held within member practices.
Directorships, including non-executive directorships, held in private companies or PLCs (who
do, will or could conduct their business in the field of health and social care).
Ownership or part-ownership of private companies, businesses or consultancies likely or
possibly seeking to do business within the CCG.
Shareholdings (more than 5%) of companies in the field of health and social care.
Positions of authority in an organisation (e.g., charity or voluntary organisation) in the field
of health and social care.
Any connection with a voluntary of other organisation contracting for NHS services.
Research funding/grants that may be received by the individual or any organisation they
have an interest or role in.
Other specific related interests.
Any other role or relationship which the public could perceive would impair or otherwise
influence the individual’s judgement or actions in their role within the LMC.
Whether such interests are those of the individual themselves or of a (first degree relatives)
family member, close friend or personal business contact of the individual.
This policy reflects the Standards of Business Conduct set out by the Committee on Standards in
Public Life, and known as the ‘Nolan Principles’1 (see page 4).
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“The First Report of the Committee on Standards in Public Life (1995)
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January 2014 – Policy agreed by LMC meeting 10th January.
Review January 2016
The Seven Principles of Public Life
1. Selflessness
Holders of public office should take decisions solely in terms of the public interest. They should not
do so in order to gain financial or other material benefits for themselves, their family, or their
friends.
2. Integrity
Holders of public office should not place themselves under any financial or other obligation to
outside individuals or organisations that might influence them in the performance of their official
duties.
3. Objectivity
In carrying out public business, including making public appointments, awarding contracts, or
recommending individuals for rewards and benefits, holder of public office should make choices on
merit.
4. Accountability
Holders of public office are accountable for their decisions and actions to the public and must submit
themselves to whatever scrutiny is appropriate to their office.
5. Openness
Holders of public office should be as open as possible about all the decisions and actions that they
take. They should give reasons for their decisions and restrict information only when the wider
interest clearly demands.
6. Honesty
Holders of public office have a duty to declare any private interests relating to their public duties and
to take steps to resolve any conflicts arising in a way that protects the public interest.
7. Leadership
Holders of public office should promote and support these principles by leadership and example.
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January 2014 – Policy agreed by LMC meeting 10th January.
Review January 2016