Policy Document Control Page

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1 Policy Document Control Page Title Title: Standards of Business Conduct Policy Version: 4 Reference Number: HR40 Supersedes Standards of Business Conduct Policy V3 Policy on the Receipt of Gifts and Hospitality, Payment and Commercial Sponsorship Description of Amendment(s): Combines two previously separate policies. Update to paragraph Change of wording to allow acceptance of modest amounts of alcohol Originator Originated By: Louise Bishop Designation: Trust Secretary Equality Impact Assessment (EIA) Process Equality Relevance Assessment Undertaken by: Louise Bishop ERA undertaken on: 12/05/2016 ERA approved by EIA Work group on: Where policy deemed relevant to equality- EIA undertaken by: EIA undertaken on: EIA approved by EIA work group on: HR40 Standards of Business Conduct Policy V4 Page 1 of 16

2 Approval and Ratification Referred for approval by: Martin Roe, Executive Director of Finance/Deputy CEO Date of Referral: 6th June 2016 Approved by: Executive Directors Approval Date: 6 th June 2016 Date Ratified by Executive Directors: 6 th June 2016 Executive Director Lead: Executive Director of Finance/Deputy CEO Circulation Issue Date: 7 th June 2016 Circulated by: Performance and Information Issued to: An e-copy of this policy is sent to all wards and departments Policy to be uploaded to the Trust s External Website? Yes Review Review Date: 31 st March 2018 Responsibility of: Louise Bishop Designation: Trust Secretary This policy is to be disseminated to all relevant staff. This policy must be posted on the Intranet. Date Posted: 6 th June 2016 HR40 Standards of Business Conduct Policy V4 Page 2 of 16

3 POLICY ON STANDARDS OF BUSINESS CONDUCT 1. Introduction 1.1 The purpose of this policy is to clarify the responsibilities of all Pennine Care officers, employees, temporary workers, volunteers, contractors and others ( staff is used as a convenient description but it is appreciated that the differing status of individuals will affect the application of some issues of this and related policies) who undertake work for Pennine Care NHS Foundation Trust ( The Trust ). 1.2 Its aim is to ensure that the behaviour and interests of staff both inside and outside work do not conflict with their position within the Trust, or their duties and responsibilities. 1.3 This policy sets out the core standards of conduct expected to avoid conflicts of interest and to safeguard the interests of the Trust, its staff and patients by indicating areas where these could be put at risk. It also endeavours to show areas where this could be put at risk so that these can be addressed. It covers hospitality, gifts, payment and commercial sponsorship offered to staff, Board members and the Trust by individuals (including patients) or public sector, independent or commercial organisations, except in the case of gifts, hospitality and entertainment offered by pharmaceutical company employees, in which case staff should refer to the Trust s Policy for the conduct of and liaison with Pharmaceutical Company Employees. 1.4 It is intended that adherence to this policy will assist in the furthering of the Trust s overall aims and objectives by seeking to promote high levels of professional, personal and corporate conduct. 1.5 It is the responsibility of all staff to ensure that they are not placed in a position which risks or appears to risk conflict between their private interests and NHS duties. Additionally, staff are responsible for ensuring they adhere to the requirements of any applicable Professional Codes of Conduct. 1.6 This policy includes guidance derived from the main provision of HSG(93) 5 Standards of Business Conduct for NHS Staff, the Prevention of Corruption Acts 1906 and 1916, and should be read in conjunction with related policies including the following non-exhaustive list: Code of Conduct for NHS Managers Conduct and Disciplinary Policy Confidentiality Policy Fraud Policy and Response Plan Internet Access Policy Policy on the Conduct of and Liaison with Pharmaceutical Company Employees Professional Registrations Policy Raising Concerns at Work (Whistle Blowing Policy)

4 Recruitment & Selection Policy Reservation of Powers to the Board and Delegation of Powers Standards of Business Conduct for NHS Staff Standing Financial Instructions Standing Orders for the Practice and Procedure of the Board of Directors Working Time Regulations Guidance for Managers A guide to the management of Private Practice in the NHS Nolan Principles Clear sexual boundaries between healthcare professionals and patients (Council for Healthcare Regulatory Excellence) 2. Principles of Conduct 2.1 The Trust expects all staff to: Ensure that the interests of service users remain paramount at all times. Be impartial and honest in the conduct of their business. Use public funds entrusted to them to the best advantage of the service, always ensuring value for money. Use the resources available to them in an effective, efficient and timely manner having proper regard to the best interests of the public and service users. Report and record all offers of gifts, hospitality, donations, sponsorship etc. whether accepted or not. 2.2 It is also the responsibility of staff to ensure that they do not: Abuse their official position for personal gain to their benefit or that of their friends or family. Seek to advantage or further their private business interests in the course of their official duties. 2.3 The guiding principles are that the interests of service users are put first and for staff to seek advice from their line manager if they are in any doubt about a particular situation. 2.4 The Trust embraces the Nolan Principles of Public Life. Nolan Principles of Public Life: Selflessness Holders of public office should act 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. Integrity

5 Holders of public office should not place themselves under any financial or other obligation to outside individuals or organisations that might seek to influence them in the performance of their official duties. Objectivity In carrying out public business, including making public appointments, awarding contracts, or recommending individuals for rewards and benefits, holders of public office should make choices on merit. 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. 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 public interest clearly demands. 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. Leadership Holders of public office should promote and support these principles by leadership and example. 3. External Codes of Conduct 3.1 Staff must follow the values expressed within any relevant professional or managerial codes of conduct, including the Code of Conduct and Accountability for NHS Boards and the Code of Conduct for NHS Managers. 3.2 Those individuals governed by a professional body (e.g. the GMC, NMC, HPC) are responsible for complying with their relevant standards of conduct. 3.3 A breach of such standards may lead to action by the Trust independently of any action taken by the regulatory or professional body concerned. 4 Observance of Policies and Procedures

6 4.1 Staff must observe all relevant Trust policies and procedures. In all cases it is the responsibility of staff to ensure that they have read and understood policies and procedures that govern their duties. 5 Fraud and Corruption 5.1 The Trust s policy on Fraud and Corruption provides the Trust with a policy for dealing with suspected fraud and other fraudulent acts, dishonesty or damage to property involving employees, contractors and their employees. 5.2 In line with the National Counter Fraud Strategy the Trust has nominated an Individual to act as the Local Counter Fraud Specialist (LCFS), whom staff may contact confidentially if they suspect a fraudulent act. Further details are included in the full policy. 5.3 One of the basic principles for all public sector organisations is that of ensuring the proper use of public funds. It is therefore important that all staff working in the public sector are aware of the risk presented by potential fraud and of the means available to enforce the rules against fraud. 5.4 This document sets out the Trust s policy for detected or suspected illegalities. The Trust already has procedures in place to reduce the likelihood of fraudulent acts occurring. These include Standing Orders (SOs), Standing Financial Instructions (SFIs), documented procedures, a system of internal control, internal audit and external audit. Further information is included in both of these policies. 6 The Receipt of Hospitality, Gifts & Payment and Commercial Sponsorship 6.1 Gifts, donations, hospitality or entertainment other than articles of low intrinsic value or modest hospitality should be declined and those accepted may need to be formally registered. If you are in any doubt you should always seek guidance from your Line Manager or equivalent. 6.2 Gifts of low intrinsic value are classed of items which individually or collectively amount to approximately or less. 6.3 Although members of staff and the Board are expected to refuse gifts, payment or offers of hospitality, there are certain exceptions. It is acceptable for members of staff or the Board to receive: Gifts of low intrinsic value from patients/service users, such as flowers, confectionery or modest amounts of alcohol (but not cigarettes or cash), to express their gratitude, as long as it is clear that the gift is not intended as an inducement to favour the patient/service user in future. Casual gifts of low intrinsic value such as pens, diaries or calendars, from contractors or others, for instance at Christmas. Gifts made to a particular service area or the Trust as a whole, provided they are consistent with the objectives of the Trust. Office refreshments or working lunches offered in the course of working visits to other organisations which are on a similar scale to the hospitality that the NHS as an employer would be likely to offer. Reasonable hospitality offered by a public sector or not-for-profit organisation which is on a similar scale to the hospitality that the NHS as an employer would

7 be likely to offer. 6.4 Refusals of Hospitality, Commercial Sponsorship, Gifts and Payment Staff and Board members should not accept personal gifts, payment or hospitality, other than those detailed in 6.3 above, from individuals or organisations outside the Trust The Chief Executive s Office must be informed of the refusal of personal gifts, payment and offers of hospitality (accommodation or entertainment) when they are from external organisations or individuals with whom the Trust has a contract or other purchasing arrangement for the supply of goods or services. The details of what they were offered, and by whom, will be recorded in the Register of Gifts and Hospitality, so that they are available to other members of staff and the Board. If members of staff or the Board have reason to believe that they have been offered an inducement or bribe, they must inform the Chief Executive s Office immediately. 6.5 Register of Gifts and Hospitality A Register of Gifts and Hospitality will be maintained in the Chief Executive s Office Office refreshments, working lunches and casual gifts of low intrinsic value do not need to be registered Commercial sponsorship of training events, seminars, away days, conferences and courses must be in accordance with this policy and must be declared in the Register of Hospitality by informing the Chief Executive s Office Any doubt about whether or not to register receipt of hospitality or commercial sponsorship should be discussed in the first instance with the staff member s line manager, or in the case of Board members, with the Chairman. Advice may also be sought from Chief Executive s Office. 6.6 Donations Occasionally the Trust is offered a cash donation to a particular service area or to the Trust as a whole. Pennine Care NHS Foundation Trust has a charitable fund to which donations may be accepted. Staff should contact the Chief Executive s office for advice on how to receipt a donation to the Trust. 6.7 Commercial Sponsorship The definition of Commercial Sponsorship within the NHS is: funding from an external source, including funding of all or part of the costs of a member of staff, NHS research, staff, training, pharmaceuticals, equipment, meeting rooms, costs associated with meetings, meals, gifts, hospitality, hotel and transport costs (including trips abroad), provision of free services (speakers), buildings or premises The Trust does not permit commercial sponsorship by alcohol or tobacco companies. 1 Commercial Sponsorship Ethical Standards for the NHS, Department of Health, November 2002

8 Sponsorship arrangements, for instance with pharmaceutical companies, should be at a corporate rather than an individual level and, without exception, must be subject to the agreement of a senior manager. Purchasing and prescribing decisions must always be based on best practice and value for money and must not be linked to commercial sponsorship Industry representatives who organise or sponsor meetings are permitted to provide reasonable hospitality, or meet any reasonable hospitality costs, which may be incurred. The level of hospitality offered must be on a similar scale to the hospitality that the NHS as an employer would be likely to offer. If no hospitality is required there is no obligation, or right, to provide such hospitality. Hospitality must be secondary to the purpose of the meeting and sponsorship of meetings by external sources must be disclosed in the papers relating to the meeting Attendance at commercially sponsored courses and conferences (including seminars and away days) requires the approval of the relevant service manager/director before they take place. The service manager/director must be confident that the sponsorship will not exert undue influence on purchasing or prescribing decisions. The Chief Executive s Office must be informed of sponsored seminars and away days so that the sponsorship can be entered into the Register of Gifts and Hospitality Commercially sponsored course and conference attendance, including conferences taking place abroad, must reflect the individual s personal development needs identified in their Individual Personal Development Plan and must be approved by their service manager/director in advance. Individual doctors and their peer groups will need to satisfy themselves that the conference is of a genuine academic value rather than a promotional event for an individual pharmaceutical company Commercially sponsored conference or course attendance must be declared in the Register of Gifts and Hospitality. Details of commercially sponsored course or conference attendance must be sent to Chief Executive s Office either after the course or conference has taken place or on an annual basis for the whole of the previous year An offer of a sponsored training event should be referred for approval to the relevant director who will assess whether the training is unbiased, evidence-based and meets ethical standards. This includes consideration of the benefits to both the Trust and the sponsoring company and whether the event will exert undue influence. Approval must be sought in advance Staff and managers should not feel pressurised to agree to requests from companies who wish to provide training. The onus of proof is on the company to demonstrate that the training will be unbiased and of benefit to the service. If this proof is not provided and agreed as reasonable, then the offer should be declined. 6.8 Procedure for registering the acceptance or refusals of gifts and hospitality Staff and Board members should always decline politely, but firmly, gifts (apart from gifts of low intrinsic value), cigarettes and money from patients Upon acceptance/refusal of a gift/hospitality, the form contained in Appendix 1 must be completed (except in the case of gifts of low intrinsic value as detailed in 6.2 above, which do not need to be registered). This form must be countersigned by the person s line manager, and then sent to the Chief Executive s Office for inclusion in the Trust s Gifts &

9 Hospitality Register. Each entry into the Gifts & Hospitality Register will be signed by the Chief Executive (or Deputy Chief Executive) Furthermore, it may be appropriate to follow up in writing a verbal refusal of a gift. An example of a letter to service users/patients, which can be used in these circumstances, is attached in Appendix Any difficulty encountered in declining hospitality, commercial sponsorship, gifts or payment should be discussed in the first instance with the staff member s line manager, or in the case of Board members, the Chairman. Advice may also be sought from Chief Executive s Office. 7 Internet Access Policy 7.1 The Trust encourages the appropriate use of the internet as a tool to provide increased immediacy of access to medical databases, Health Service Circulars, Guidance Notes and National Strategy Documents, professional discussion groups, bulletin boards and other information relevant to the work of the Trust. 7.2 Employees must not perform any action whilst on-line which could jeopardise the security and integrity of the Trust's IT capability. 7.3 Please refer to the Internet Access Policy, which sets out further corporate guidelines in relation to Internet access and use that must be adhered to. 8 Declaration of interests 8.1 All substantive, temporary staff employed through the bank and volunteers are required to sign a declaration of interest form (issued during the recruitment process) before commencing their appointment and are required to complete a new declaration if their circumstances change. Any new declarations should be submitted to the relevant Service Manager/Service Director. For senior contractors employed to work on specific trust wide or significant projects the appointing manager will ensure that a declaration of interest form is completed as part of the contracting process. 8.2 All declarations of interest will be kept on a register with the Chief Executive; this will be made available for inspection by the public. Any member of staff not making a declaration of a relevant interest or being found to have abused their position for the purpose of self-benefit or family and friends will be subject to disciplinary action. 9 Conflict of Interests 9.1 No matter at what level of the organisation people work, there is always the possibility of a situation arising when a potential or perceived conflict of interest arises. 9.2 Employees who are in a position to directly or indirectly influence the outcome of Trust business must take extra steps to ensure that their private interests do not compete with their professional duties.

10 9.3 It is the responsibility of all staff to ensure that they are not placed in a position which risks, or appears to risk, conflict between their private interests and their NHS duties. 9.4 Whilst staff might be involved in party, or other political or campaigning activity, they should ensure that their work with the Trust is kept separate from such personal activity and their association with the Trust is not used to promote such activity and that the activity is not such that it brings the trust into any disrepute. 10 Outside/Secondary Employment 10.1 Staff may, unless otherwise provided, engage in work outside the Trust above their contract with Pennine Care NHS Foundation Trust, unless this affects their ability to perform their contractual duties or it is in a business engaged in direct competition with the Trust In all cases, staff must discuss any proposal for additional work with their Manager, or equivalent Staff must declare immediately all work outside of the Trust to the relevant Manager, including where circumstances change (e.g. an increase in the hours worked) Any staff with a controlling or significant financial interest in a business, or any other activity which competes for an NHS contract should declare such interest in order that it may be known and in no way promoted to the detriment of the employer or its patients Under the Working Time Regulations, the Trust has a responsibility to ensure that staff are not working in excess of an average of 48 hours a week (over a 17 week reference period), in their Trust role or in a combination of their Trust role and any other employment, therefore staff are required to declare any additional employment for these purposes to their Line Manager or appropriate Service Manager. 11 Private Practice 11.1 Subject to the terms of their contracts with the Trust clinical staff may undertake private practice or work for outside agencies provided that they do not do so within the time that they are contracted to the Trust and that this is declared in job planning. Any work should be subject to the conditions outlined in A Guide to the Management of Private Practice in the NHS The overriding principle is that staff do not compete directly for work which otherwise might have come to the Trust and that their outside role does not affect the conduct of their Trust work in any detrimental way. Where there are such outside interests particular care must be taken as to issues of confidentiality and [refer other policies] Staff who carry out private work, or work for an external organisation/agency, must declare that work in the Trust s Register of Interests. 12 Recruitment & Selection

11 12.1 The aim of the recruitment and selection processes is to ensure that the best candidate is fairly appointed on the basis of merit. This does not preclude the employment of near relatives or close friends of existing members of staff, provided that the individual selected is demonstrably the best candidate. If a near relative, or a close friend, is being considered, the member of staff should not justify the need for the appointment; canvass on their behalf, select the appointee; or directly supervise the appointee Please refer to the Recruitment & Selection Policy for further guidance. The aim of this policy is to provide clear guidance to managers to ensure a fair, consistent and lawful approach in all our recruitment and selection procedures. 13 Confidentiality 13.1 All staff employed by the Trust have a duty to keep patient and staff information safe and strictly confidential and to use it only for the proper purposes in accordance with the law and Trust policy. For further guidance please refer to the Confidentiality Policy. 14 Conduct and Disciplinary (Trust employees only) 14.1 Failure to meet required standards of performance and behaviour can be identified from a wide variety of sources, including observation, incidents and complaints. Informal reflection with staff about minor performance difficulties should remain the first option to resolve any issues. This is in line with the informal stages of the policy. However, the formal stages of the Conduct & Disciplinary Policy should be referred to where there are continuing concerns or where a single act which is of a serious nature and/or may be classed as gross misconduct The Trust policy on Conduct and Disciplinary gives guidance on the conduct expected of staff working within the Trust. It sets out conduct, which is not acceptable; although the guide given is in no way an exhaustive list. 15 Relationships 15.1 Relationships with Service Users Staff must always act in such a way as to promote and safeguard the wellbeing and interests of service users and to maintain the trust between service users and staff Under no circumstances should staff form inappropriate personal relationships with service users. They should not behave in a way, in work or outside work, which would call into question their suitability or professional conduct. This includes friendships, social networking and breach of sexual boundaries (which includes include acts, words or behaviours of a sexual nature), business, commercial or financial Staff working with service users must declare issues that might create conflicts of interest and must make sure that they do not influence their judgement or practice,

12 including adhering to policies and procedures about accepting gifts and money from clients and their carers Positive relationships, built on trust, should be fostered with service users. Staff must ensure that relationships with clients are conducted openly and that they are never of a private or personal nature. Under no circumstances is it appropriate to take advantage of the vulnerability of a service user It is inappropriate for a personal relationship to develop between an employee and a service user directly in their care and should this occur it may result in the staff member being dismissed. If a personal relationship does develop between a staff member and a service user then the staff member must raise the issue with their line manager to decide on the appropriate course of action Research has shown that a patient may be harmed as a result of a sexual relationship with their healthcare professional(s), although the circumstances clearly differ. Circumstances when a relationship between a healthcare professional and former service user would almost never be appropriate would be if the healthcare professional was providing long term emotional or psychological support, or where the service user was suffering from mental health issues at the time of treatment from the healthcare professional ( Clear sexual boundaries between healthcare professionals and patients, Council for Healthcare Regulatory Excellence, 2008). If a relationship does develop between a member of staff and a former service user this should be raised with the line manager who will decide on the appropriate course of action Practitioners should not allow their professional relationships with service users to be prejudiced by any personal views they may have about age, gender, disability, race, sexuality, belief, lifestyle or culture Relationships Between Staff Members Staff are encouraged to socialise and develop professional relationships in the workplace, provided that these relationships do not interfere with the work performance of either individual, or with the effective functioning of the workplace Staff who engage in personal relationships should be aware of their professional responsibilities and will be responsible for ensuring that the relationship does not give concerns about clinical practices, priorities, use of resources, favouritism, bias, ethics and conflict of interest Colleagues must work in a collaborative and co-operative manner and recognise and respect the contribution that each person makes Relationships between staff should always be professional. Where a relationship forms between colleagues that is of a more personal nature, and relates to one or more of the criteria outlined in , they should inform their line manager who will speak to each party in order to safeguard the interests of the service and the individuals concerned. For members of the Board (voting and nonvoting), the Chairman should also be notified of a relationship As a complex organisation, there will inevitably be occasions when the Trust may

13 be the employer of both partners in a marriage/relationship, or of close relations. Ordinarily this is of little or no significance, but there are limited circumstances where it may be and, consequently, where serious difficulties could arise. In particular this will apply where there is a possibility of partners or close relatives working in posts which have direct line management relationship, such that one would be involved in appointing, managing, counselling, appraising, disciplining etc., the other, or where both would be members of a management or clinical group with corporate responsibilities to the Trust In such circumstances there is a potential for a division of loyalty, which should be avoided wherever possible. However, the requirements of the equality legislation must be scrupulously observed, and selection for appointment, training and promotion must not be inappropriately affected by such relationships If in doubt over whether a conflict of interest exists, staff should contact their line manager for further guidance. The manager will then seek advice from Human Resources. A failure to notify could potentially to be viewed as misconduct The Trust will take reasonable action to change structures and responsibilities, where possible, to avoid people with close relationships working in the same direct line of management. This may include the transfer to other roles If staff have concerns about a relationship or potential relationship, they are encourage to use the various avenues for raising concerns at work such as the Whistleblowing Policy (also see Section 19 below). 16 Register of Interests 16.1 All parties should declare any interests that could possibly conflict with their work for the Trust, either on starting employment or on acquisition of the interest All declarations made in accordance with this policy must be made in writing to the Chief Executive in order for it to be properly recorded on a central register An annual reminder is sent out within the Staff Newsletter to inform staff about their obligations under this policy. This is also published on the Trust s Intranet site The Chief Executive, will keep and maintain registers of declarations made in accordance with this policy Board members are written to on an annual basis and asked to declare/update any interests in relation to this and other supporting policies. 17 Failure to Follow Code 17.1 This policy details an agreed Code of Conduct, it is an integral part of staff s contract of employment and it is required that the principles of the code are upheld at all times Staff found to be in breach of any aspect of this policy may be subject to disciplinary, or other, action including possible summary dismissal for gross misconduct. In certain cases staff may also be subject to referral to the regulator

14 or even criminal proceedings. 18 Raising a Concern 18.1 The Trust is committed to achieving the highest possible standards of service and the highest possible ethical standards in public life and in all of its practices. It also encourages staff to use internal mechanisms for reporting any malpractice or illegal acts or omissions by its employees or ex-employees Any member of staff who has a genuine concern regarding fraud, corruption, or theft is encouraged to report that concern as soon as possible without fear of reprisal or subsequent action of any description against them. This should ordinarily be reported via their manager The Trust s Whistleblowing Policy states that the interests of patients are of paramount importance and that staff have a duty to draw to the attention of the Trust any concern or reasonable suspicion of damage or risk to the interests of patients, the public, or other staff of the Trust. This policy should be referred to for further details. 19. Review This policy will be reviewed in two years time.

15 DECLARATION OF ACCEPTANCE / REFUSAL OF GIFTS OR HOSPITALITY This form must be completed if, in connection with your official duties, you accept or refuse any form of gift, hospitality or consideration from a third party (other than gifts of low intrinsic value, as described in paragraph 6.2). Following completion, please forward this form to your line manager who will countersign and forward it to the Chief Executive s Office. The completed form will be filed on an official register, which will be periodically scrutinised by the auditors and may be viewed at any time by a member of the public or interested organisation. It will also form part of the year-end Report on Gifts and Hospitality, which is presented to the Board of Directors on an annual basis. Name Job Title Workplace Address I disclose that on.(date) I *accepted/refused the following *gift/ hospitality (*delete as appropriate) Details Estimated Value: From (person or company offering gift/hospitality Is this a pharmaceutical company? *Yes/No Are you a member of the Drugs and Therapeutics Committee? *Yes/No Signed and dated: Countersigned (line manager) and dated: Line Manager Name and Job Title (printed) Signed and dated: Chief Executive or Deputy

16 Date Private and Confidential Our ref: Your ref: Department: Ask for: Extension: Dear Thank you so much for your kind offer of a (insert details of gift). It means a great deal to me and my colleagues to be appreciated in this way. As I explained to you, the NHS has clear rules about what staff can and cannot accept and regrettably this means that I am not able to accept this gift. However, the Trust does run a charity, to which donations may be made instead. If you wish to receive further information on the charity, you may contact the Chief Executive s Office on With many thanks. Yours sincerely Name Title