Standards of Business Conduct

Standards of Business Conduct Who Should Read This Policy Target Audience All employed staff, Bank workers and secondees Partners working within the Trust Version 1.0 May 2016

Ref. Contents Page 1.0 Introduction 4 2.0 Purpose 4 3.0 Objectives 4 4.0 Process 4 4.1 Principles of Conduct 4 4.2 Casual Gifts 5 4.3 Hospitality 5 4.5 Declaration of Business Interests 6 4.6 Preferential Treatment in Private Transactions 7 4.7 Contracts 7 4.8 Private Practice 8 4.9 Rewards for Initiative 8 4.10 Uses of Sponsorship 9 4.11 Commercial in Confidence 10 4.12 Reporting Concerns Regarding Breaches of Standards of Business Conduct 10 5.0 Procedures/Policies connected to this Policy 10 6.0 Links to Relevant Legislation 10 6.1 Links to Relevant National Standards 11 6.2 Links to other Key Policies 11 6.3 References 11 7.0 Roles and Responsibilities for this Policy 12 8.0 Training 13 9.0 Equality Impact Assessment 13 10.0 Data Protection and Freedom of Information 13 11.0 Monitoring this Policy is Working in Practice 13 Appendices 1.0 Code of Conduct for Managers 14 2.0 Register of Gifts and Hospitality Received and Provided 15 3.0 General Notification of an Interest 16 Version 1.0 May 2016 2

Explanation of terms used in this policy Business Conduct - Standards of behaviour expected when involved in commercial activity Interest - Involvement by an employee or a family member or associate in a business or secondary employment Fraud - In UK legislation, Fraud is defined as follows: any person who dishonestly makes a false representation to make a gain for himself or another or dishonestly fails to disclose to another person, information which he is under a legal duty to disclose, or commits fraud by abuse of position, including any offence as defined in the Fraud Act 2006 Version 1.0 May 2016 3

1.0 Introduction This policy describes the principles and practices to be applied in the Standards of Business Conduct for NHS Staff employed by Black Country Partnership NHS Foundation Trust. It also applies to staff from partner agencies working for the Trust. It provides practical guidance to ensure that all staff and managers are aware of their responsibilities and the standards that the Trust expects in relation to business conduct. The underlying principle of this policy highlights that Public Sector bodies, which include the NHS, are to be impartial and honest in the conduct of their business, and their employees are required to remain beyond suspicion. Under the Bribery Act 2010 it is an offence for employees corruptly to accept any gifts or consideration as an inducement or reward for doing, or refraining from doing anything in his/her official capacity, or corruptly showing favour, or disfavour, in the handling of contracts. Any staff who breach the provisions of this Act will be rendered liable to prosecution and it may also lead to termination of employment and superannuation rights in the NHS. Also under the Association of the British Pharmaceutical Industry (ABPI) Code of Practice for the Pharmaceutical Industry, Pharmaceutical companies are to operate in a responsible, ethical and professional manner. 2.0 Purpose The purpose of this policy is to ensure exemplary standards of conduct are adhered to by all employees of the Trust and that staff are aware of their individual responsibilities to maintain strict ethical standards in the conduct of NHS business. 3.0 Objectives The over-riding principles to be adhered to can be summarised as follows: Accountability everything done by those who work in the NHS must be able to stand the test of parliamentary scrutiny, public judgements on propriety and professional codes of conduct Probity there should be an absolute standard of honesty in dealing with the assets of the NHS: integrity should be the hallmark of all personal conduct in decisions affecting patients, staff and suppliers, and in the use of information acquired in the course of NHS duties Openness there should be sufficient transparency about NHS activities to promote confidence between the NHS organisation and its staff, patients and the public 4.0 Process 4.1 Principles of Conduct Trust staff are expected to: Ensure that the interest of patients remains paramount at all times Be impartial and honest in the conduct of their official business Use the public funds entrusted to them to the best advantage of the service, always ensuring value for money Maintain an unimpeachable standard of integrity in all their business relationships both inside and outside the organisations in which they are employed Version 1.0 May 2016 4

Foster the highest possible standards of professional competence amongst those for whom they are responsible Optimise the use of resources for which they are responsible to provide the maximum benefit to the organisation Comply with contractual obligations Reject any business practice which might reasonably be deemed improper The Department of Health issued a Code of Conduct for Managers which provides managers with guiding principles which must be adhered to. An overview of the requirements of this code are included in Appendix 1. It is also the responsibility of staff to ensure that they do not: Abuse their official position for personal gain or to benefit their family or friends Seek to advantage or further private business or other interests, in the course of their official duties In applying these principles, staff are required to follow the guidance set out below. 4.2 Casual Gifts Casual gifts of low intrinsic value such as diaries or calendars, or small tokens of gratitude from patients or their relatives in the region of 25, need not be refused. Staff should however be mindful of the fact that in accepting such gifts this does not constitute an offence under the Bribery Act 2010. If members of staff are unsure about what they can accept, they should discuss the matter with their line manager. In all cases, when a member of staff accepts a gift (regardless of the value) from patients/service users etc. this should be declared to their line manager as soon as practicable after the acceptance of the gift/hospitality and in all cases no later than by the end of their next scheduled day of working. The details should be recorded on the local gifts/hospitality register see Appendix 2. The register will be held locally but be available, on request, for submission to the Trust Secretary for audit/compliance purposes. Any material gifts, which represent a donation to the Trust, may be accepted in line with established procedures (e.g. charitable donations etc.). For the avoidance of doubt, staff may not accept any gift of money (including gift vouchers and other such monetary equivalents) for personal gain. All gifts of money to wards or departments, without exception, must be treated as a charitable donation to the Trust and should be accepted in accordance with established endowment arrangements and paid into the relevant charitable account/fund. Under the ABPI Code of Practice, Pharmaceutical companies may not give gifts to a health professional or manager as an inducement to prescribe, supply, administer, recommend, sell or buy any medicine. The exception to this rule would be low value promotional aids that are relevant to the recipient s work. A low value promotional aid is one that has cost the company no more than 25. Items of such value again need not be refused by staff. In cases of doubt staff should either consult their line manager or politely decline acceptance. 4.3 Hospitality Visits at Suppliers expense to inspect equipment, etc., are not to be undertaken without prior approval of the Chief Executive. Modest hospitality is an accepted courtesy of a business relationship. However, the recipient should not allow him or Version 1.0 May 2016 5

herself to reach a position whereby he or she might be deemed by others to have been influenced in making a business decision as a consequence of accepting such hospitality. Lunches in the course of working visits, may be acceptable, though it should be similar to the scale of hospitality which the NHS employer would be likely to offer. Likewise, hospitality by pharmaceutical companies in the form of lunches or similar evening entertainment in support of sponsorship for educational events is normally acceptable. However under the ABPI Code of Practice the hospitality is to be secondary to the meeting, and of an appropriate standard. Lavish or deluxe venues are not to be used. Staff are to decline all other gifts, hospitality or entertainment. If in doubt they are to seek advice from their line manager being mindful of the Bribery Act 2010. 4.4 Secondary Employment Employees are advised not to engage in outside employment, which may conflict with their NHS work, or be detrimental to it. They are required to inform their line manager of any current additional employment. This is to ensure that there is no conflict of interest with their duties carried out on behalf of the Trust. Before accepting new employment employees are to discuss this with their line manager and their manager must give agreement before the offer of employment is accepted. Managers are to consider the following in relation to the secondary employment: Potential conflicts of interest The Working Time Regulations - further guidance can be provided by the Human Resources department where required Employee s current performance (on basis that secondary employment may exacerbate a health/performance related issue) Examples where a conflict of interest may arise would be the provision of care to a service user through a private company or the direct payments scheme and also through the Trust. 4.5 Declaration of Business Interests The Trust needs to be aware of all cases where an employee, or his or her spouse/close relative or associate, has a controlling and/or significant financial interest in a business (including a private company, public sector organisation, other NHS employer and/or voluntary organisation) or in any other activity or pursuit, which may compete for an NHS contract to supply either goods or services to the Trust. All staff are to declare such interests to their employer, when it comes to the knowledge of the employee that a contract is being discussed, in order that it may be known to and in no way promoted to the detriment of either the Trust or the patients whom it serves. All declarations should be made using the form in Appendix 3, as soon as the interest arises. The form once signed by the appropriate executive director should be sent to the Trust Secretary for entry onto the trust register of interests. In addition there are specific requirements Directors are to fulfil in accordance with Trust Standing Orders. Version 1.0 May 2016 6

One particular area of potential conflict of interest which may affect patients is when NHS staff hold a self-beneficial interest in private care homes or hostels. Advice on professional conduct issued by the General Medical Council recommends that when a doctor refers a patient to a private care home or hostel in which he or she has an interest, the patient has to be informed of that interest before the referral is made. 4.5.1 Determining what Needs to be Declared Staff are to make sure they understand the guidelines on standards of business conduct and consult their line manager if they are not sure. Staff are to make sure they are not in a position where their private interests and NHS duties may conflict. Staff are required to declare any relevant interests or potential conflicts to their employer. If staff are in doubt they are advised to ask: Am I, or might I be, in a position where I (or my family/friends) could gain from the connection between my private interests and my employment? Do I have access to information which could influence purchasing decisions? Could my outside interest be in any way detrimental to the NHS or to patients interests? Do I have any other reason to think I may be risking a conflict of interest? When it is not easy to decide between what is and is not acceptable in terms of gifts of hospitality, the offer should be declined or advice sought from the Employee s manager If staff are still unsure they should declare it. All declarations should be made using the form in Appendix 3, as soon as the interest arises. 4.6 Preferential Treatment in Private Transactions Individual staff are not to seek or accept preferential rates or benefits in kind for private transactions carried out with companies with which they have had, or may have, official dealings on behalf of their NHS employer (this does not apply to concessionary agreements negotiated with companies by NHS management, or by recognised staff interests, on behalf of all staff, for example, NHS staff benefits schemes). 4.7 Contracts All staff who are in contact with supplies and contractors (including external consultants) and in particular those who are authorised to sign Purchase Orders, or place contracts for goods, materials or services, are expected to adhere to the principles outlined in this document, to professional standards of the kind set out in the Ethical Code of the Institute of Purchasing and Supply (IPS), and the Trusts Standing Orders, Reservation and Delegation of Powers, and Standing Financial Instructions. 4.7.1 Favouritism in Awarding Contracts Fair and open competition between prospective contractors or suppliers for NHS contracts is a requirement of the Procurement Policy, and the Trusts Standing Orders, Reservation and Delegation of Powers, and Standing Financial Instructions. This means that: No private, public or voluntary organisation or company which may bid for NHS business are to be given any advantage over its competitors such as advance notice of NHS requirements. This applies to all potential contractors, whether or not there is a relationship between them and the NHS employer, such as a long-running series of previous contracts. Any relationship which Version 1.0 May 2016 7

might, in the long term, prevent the effective operation of fair competition, is to be avoided Each new contract is to be awarded solely on merit, taking into account the requirements of the NHS and the ability of the Contractors to fulfil them All employees are to ensure that no special favour is shown to current or former employees or their close relatives or associates in awarding contracts to private or other businesses run by them or employing them in a senior or relevant managerial capacity. Contracts may be awarded to such businesses where they are won in fair competition against other tenders, but scrupulous care is to be taken to ensure that the selection process is conducted impartially, and that staff who are known to have a relevant interest play no part in selection. 4.8 Private Practice Consultants and Associate Specialists employed under the Terms and Conditions of Service of Hospital Medical and Dental Staff are permitted to carry out private practice subject to the conditions outlined in the handbook A Guide to the Management of Private Practice within the NHS [see also PM 79 (11) ]. Other health professionals may undertake private practice work for outside agencies or may support work undertaken by Consultants, providing they do not do so within the time they are contracted to the NHS, and they observe the Conditions in paragraph 4.4. This also applies to administrative and secretarial staff who support Consultants/other health professionals, in that, any work done to support private practice should not be carried out in the time they are contracted to the NHS. All hospital doctors are entitled to fees for other work outside their NHS Contractual duties under Category 2 (para. 37 of the TCS of Hospital Medical and Dental Staff) e.g. examinations and reports for life insurance purposes. Hospital doctors and dentists in training should not undertake Locum work outside their Contracts where such work would be in breach of their Contracted hours. 4.9 Rewards for Initiative The Trust has to ensure it is in a position to identify potential intellectual property rights, as and when they arise, so that the Trust can protect and exploit them properly, and thereby ensure that they receive any rewards or benefits (such as royalties) in respect of work, commissioned from third parties, or work carried out by their employees in the course of their NHS duties. Most potential intellectual property rights are protected under the Patents Act 1977 and copyright (which includes software programmes) under the Copyright Designs and Patents Act 1988. Staff are to build appropriate specifications and provisions into the contractual arrangements which they enter into before the work is commissioned, or begins and seek legal advice if in any doubt in specific cases. With regard to patents and inventions, in certain defined circumstances the Patents Act gives staff a right to obtain some reward for their efforts. Other rewards may be given voluntarily to staff who within the course of their employment have produced innovative work of outstanding benefit to the NHS. Similar rules apply to other activities such as giving lectures and publishing books and articles. Version 1.0 May 2016 8

In the case of collaborative research and evaluative exercises with manufacturers, the Trust will obtain a fair reward for the input provided. If such an exercise involves additional work for an NHS employee outside that paid for by the Trust under his or her Contract of Employment, arrangements is to be made for some share of any rewards or benefits to be passed on to the staff concerned from the collaborating parties. Care should however be taken that involvement in this type of arrangement with a manufacturer does not influence the purchase of other supplies of that manufacturer. 4.10 Uses of Sponsorship The principal use of sponsorship is to improve the quality of educational or scientific activities. This may include research, meetings and conferences, prizes and fellowships, public education materials, newsletters and scientific publications. There will be some conferences / educational meetings for which it is inappropriate to seek sponsorship. The contribution of sponsors in supporting development / educational activities is understood and appreciated. The overriding principle is that the Trust retains control of the title and content of any event, the level of advertising and, in the case of meetings, the level of hospitality. Acceptance of sponsorship by the Trust is never to be represented by the sponsor as an endorsement of its products. Individual products and brands are not to be referred to in any acknowledgement of sponsorship. 4.10.1 Sponsorship of Educational Meetings/Conferences Company support for visiting speakers (honoraria, expenses) and/or other meeting costs (hall and equipment hire etc.) is acceptable only if the majority of speakers/ presenters are NOT chosen by the sponsoring company. Speakers who have competing interests will be required to make a brief oral declaration to this effect at the beginning of their presentations. Reference to the donor organisation will be limited to display of the company name and/or logo on papers, and a discreet exhibition stand. The Trust requires the freedom to select or reject any speakers suggested by a sponsoring company, particularly where the possibility arises that the company recommendation reflects bias on the part of the proposed speaker towards the company s product(s). Consideration is to be given to ensuring that there is an overall balance of sponsored educational events and to avoid the predominance of biological psychiatric events to the detriment of education in other areas of psychiatry such as psychotherapy. 4.10.2 Commercial Sponsorship for Attendance at Courses and Conferences Acceptance by staff of commercial sponsorship for attendance at relevant conferences and courses is acceptable, but only where the employee seeks permission in advance and the employer is satisfied that acceptance will not compromise purchasing decisions in any way. 4.10.3 Commercial Sponsorship of Posts Offers of sponsorship of posts by, for example pharmaceutical companies are to be referred to the Chief Executive. Where such sponsorship is accepted, monitoring arrangements will be established to ensure that are not, in fact being influenced by the sponsorship agreement. Version 1.0 May 2016 9

4.11 Commercial in Confidence Staff are required to be particularly careful of using, or making public internal information of a commercial in confidence nature, particularly if its disclosure would prejudice the principle of a purchasing system based on fair competition. This principle applies whether private competitors or other NHS providers are concerned and whether or not disclosure is prompted by the expectation of personal gain. Information given in the course of duty should be true and fair and never designed to mislead. However, it should not be a cause of excessive secrecy on matters which are not strictly commercial per se. For example, the terms commercial in confidence will not be taken to include information about service delivery and activity levels which should be publicly available. Nor should it inhibit the free exchange of data for medical audit purposes, for example, subject to the normalities governing patient confidentiality and data protection. In all circumstances the overriding consideration must be the best interests of the patient. 4.12 Reporting Concerns Regarding Breaches of Standards of Business Conduct Various confidential methods exist to enable staff to report any concerns regarding conduct not in accordance with this policy. If appropriate, staff can refer matters to their manager or a member of the Board in accordance with the trust s Raising Concerns at Work (Whistleblowing) Policy. The National Fraud and Corruption Reporting Line (Telephone 0800 028 40 60) exist for circumstances requiring external reporting. LCFS can be contacted on 0121 612 8055/07807345862 or fraud.confidentialreporting@bcpft.nhs.uk. 5.0 Procedures/Policies connected to this Policy Standing Financial Instructions These Standing Financial Instructions detail the financial responsibilities, policies and procedures adopted by the Trust. They are designed to ensure that the Trust's financial transactions are carried out in accordance with the law and with Government policy in order to achieve probity, accuracy, economy, efficiency and effectiveness. They should be used in conjunction with the Schedule of Matters reserved to the Board and the Scheme of Delegation approved by the Board of Directors. Anti-Fraud, Bribery and Corruption Policy The aim of this policy is to set out clearly for staff, the framework and controls in place for dealing with all forms of detected or suspected fraud, bribery and corruption. 6.0 Links to Relevant Legislation Bribery Act 2010 The Act creates a new offence under section 7 which can be committed by commercial organisations which fail to prevent persons associated with them from committing bribery on their behalf. It is a full defense for an organisation to prove that despite a particular case of bribery it nevertheless had adequate procedures in place to prevent persons associated with it from bribing. Section 9 of the Act requires the Secretary of State to publish guidance about procedures which commercial Version 1.0 May 2016 10

organisations can put in place to prevent persons associated with them from bribing. This document sets out that guidance. Patents Act 1977 The Patents Act 1977 is the main patent law in the UK and gives effect to certain international conventions on patents. The Act sets out the legal rights and duties for UK patents and patent applications, and how UK law relates to the European Patent Convention (EPC) and the Patent Co-operation Treaty (PCT). 6.1 Links to Relevant National Standards The code of Conduct for NHS Managers 2002 The Code sets out the core standards of conduct expected of NHS managers. It will serve two purposes: To guide NHS managers and employing health bodies in the work they do and the decisions and choices they have to make To reassure the public that these important decisions are being made against a background of professional standards and accountability The NHS Constitution 2015 This Constitution establishes the principles and values of the NHS in England. It sets out rights to which patients, public and staff are entitled, and pledges which the NHS is committed to achieve, together with responsibilities, which the public, patients and staff owe to one another to ensure that the NHS operates fairly and effectively. The Secretary of State for Health, all NHS bodies, private and voluntary sector providers supplying NHS services, and local authorities in the exercise of their public health functions are required by law to take account of this Constitution in their decisions and actions. References in this document to the NHS and NHS services include local authority public health services, but references to NHS bodies do not include local authorities. Where there are differences of detail these are explained in the Handbook to the Constitution. 6.2 Links to other Key Policies Raising Concerns at Work (Whistle Blowing) Policy The purpose of this policy is to provide staff with clear guidance on the Trust s commitment to ensure that fair and non-discriminatory systems are in place for staff to raise concerns under this policy. 6.3 References The code of Conduct for NHS Managers (2002) The NHS Constitution Version 1.0 May 2016 11

7.0 Roles and Responsibilities for this Policy Title Role Key Responsibilities All NHS Staff/ Bank Workers/ Secondees Managers/Team Leaders/Heads of Department Adherence - Ensure exemplary standards of conduct are adhered to at all times and be aware of their individual responsibilities to maintain strict ethical standards in the conduct of NHS business - Declare all secondary employment to their line manager or any other activity which may pose a conflict of interest to their employment with the Trust - Ensure that they are not placed in a position which risks, or appears to risk, conflict between their private interests and their NHS duties - Adhere to the guidance regarding acceptance of gifts/hospitality. If in doubt they should seek advice from their line manager. All gifts/hospitality that are accepted should be declared to their line manager Operational - Ensure all staff are aware of their responsibilities under the policy - Act in line with this policy where a conflict of interest may arise with an employee - Provide guidance to staff when queries are raised in respect to whether it is acceptable for them to accept gifts/hospitality - Maintain a local register of gifts/hospitality for their department/team and for submitting this on an ad hoc basis, in response to a request by the Trust secretary - Ensure all incidents/issues relating to this policy are reported Group Directors Implementation - Ensure compliance across the area of their responsibility with this Policy - Ensure systems are put in place to enable this policy to be implemented within their service areas - Ensure all managers are aware of the policy and promote good practice Human Resource Advisors Specialist Advice - Provide advice on any conduct/capability matters arising from alleged breaches of this policy to managers and staff Trust Secretary Monitoring and scrutiny Specialist Advice - Provide advice in respect to the implementation and interpretation of this policy to managers and staff - Implement a process of assurance by reminding staff of their obligations to declare any interests, in accordance with the requirements within this policy on an annual basis. Note: this does not apply to directors and governors who are subject to different processes out with this policy - Collate a trust declaration of interest register reporting on an annual basis and report this via the investment and finance committee Executive Directors Responsible - Ensure staff within their Group are aware of the policy and its implications and to respond appropriately when issues are highlighted - Ensure that they review and approve/reject any declarations of interest that are raised with them within their Group Director of Workforce and Organisational Development Executive Lead - Lead responsibility for the implementation of this policy - Allocation of resources to support the implementation of this policy - Ensure any serious concerns regarding the implementation of this policy are brought to the attention of the Board of Directors Version 1.0 May 2016 12

8.0 Training What aspect(s) Is this training covered in the Which staff groups of this policy will Trust s Mandatory and Risk How often will Who will ensure and If no, how will the Who will deliver the require this require staff Management Training Needs staff require monitor that staff have training be delivered? training? training? training? Analysis document? training this training? n/a n/a n/a n/a n/a n/a n/a 9.0 Equality Impact Assessment Black Country Partnership NHS Foundation Trust is committed to ensuring that the way we provide services and the way we recruit and treat staff reflects individual needs, promotes equality and does not discriminate unfairly against any particular individual or group. The Equality Impact Assessment for this policy has been completed and is readily available on the Intranet. If you require this in a different format e.g. larger print, Braille, different languages or audio tape, please contact the Equality & Diversity Team on Ext. 8067 or email EqualityImpact.assessment@bcpft.nhs.uk 10.0 Data Protection and Freedom of Information This statement reflects legal requirements incorporated within the Data Protection Act and Freedom of Information Act that apply to staff who work within the public sector. All staff have a responsibility to ensure that they do not disclose information about the Trust s activities in respect of service users in its care to unauthorised individuals. This responsibility applies whether you are currently employed or after your employment ends and in certain aspects of your personal life e.g. use of social networking sites etc. The Trust seeks to ensure a high level of transparency in all its business activities but reserves the right not to disclose information where relevant legislation applies. 11.0 Monitoring this Policy is Working in Practice What key elements will be monitored? (measurable policy objectives) Where described in policy? How will they be monitored? (method + sample size) Who will undertake this monitoring? How Frequently? Group/Committee that will receive and review results Group/Committee to ensure actions are completed Evidence this has happened All staff members who meet the relevant requirements submit a notification of interest form Section 4.5 All forms will be analysed for incidents and trends Trust Secretary in conjunction with LCFS Annually Audit Committee Audit Committee Minutes of Audit Committee Version 1.0 May 2016 13

Appendix 1 Code of Conduct for Managers The Department of Health issued a Code of Conduct for Managers which provides managers with guiding principles which must be adhered to. An overview of the requirements of this code are shown below: Make the care and safety of patients my first concern and act to protect them from risk Respect the public, patients, relatives, carers, NHS staff and partners in other agencies Be honest and act with integrity Accept responsibility for my own work and the proper performance of the people I manage Show my commitment to working as a team member by working with all my colleagues in the NHS and the wider community Take responsibility for my own learning and development Version 1.0 May 2016 14

Appendix 2 Register of Gifts and Hospitality Received and Provided For the Year to 31 st March 20XX Department/Team Name: Staff Name/Role Details of Gift or Hospitality Received From Estimated Value ( ) Copy to be maintained within Service area and provided as appropriate to Trust Secretary to support audit/reporting requirements. Version 1.0 May 2016 15

Appendix 3 General Notification of an Interest 1. Surname 2. First Name 3. Employee Number 5. Type of Post Permanent / Temporary / Fixed Term / Annualised Hours / Bank 4. Line Manager 6. Current Hours 7. Job Title & Department 8. Band & Pay Point Name of Company Partnership, Local Authority or other Body or organisation Nature of Interest (Shareholder, director, partner, adviser, employee, etc.) Type of Interest (please indicate whether the interest is Direct or Indirect and whether it is pecuniary or nonpecuniary) Date of Appointment (e.g. 01/04/12) Date of resignation (e.g. 01/04/12) I confirm that I have understood the Declaration of Interest Policy and in making this declaration to the BCPFT, I confirm compliance with the policy. I accept that in submitting this declaration, it does not remove my personal responsibility of ensuring I am not in a position or situation which may result in a potential breach of this policy. I understand that if I provide false information I may be liable to disciplinary, prosecution and civil recovery proceedings. Name Date Signature Managers Signature Executive Director Job Title Managers Name Agreed Acceptable Completed forms should be sent to the trust secretary for inclusion on the Trust Register of Interests. A copy should be held on the individual s personal file. Version 1.0 May 2016 16

Explanatory note: 1. If your interest is indirect, please include through whom the interest is acquired or held, e.g., business partner, close family members. Indirect pecuniary interests arise from connections with bodies that have a direct pecuniary interest or from being a business partner of, or being employed by, a person with such an interest. 2. Close family members include personal partners, parents, children (adult and minor), and any parent, brothers, sisters, and the personal partners of any of these. 3. A pecuniary interest is a direct financial interest received in person or by association. Non-pecuniary interests are all other interests held, not specifically relating to money, but which may be perceived (by a reasonable member of the public) to influence their judgement in the exercise of their public duties. 4. Non-pecuniary interests include those arising from memberships of clubs and other organisations. 5. Interests which should be regarded as relevant are: a) Directorships, including Non-Executive Directorships held in private companies or PLCs (with the exception of those of dormant companies); b) Ownership or part-ownership of private companies, businesses or consultancies likely or possibly seeking to do business with the NHS; c) Majority or controlling share holdings in organisations likely or possibly seeking to do business with the NHS; d) A position of trust in a public, charity or voluntary organisation in the field of health and social care; e) Any connection with a voluntary or other organisation contracting for NHS services; f) Any other commercial interest in the decision before the meeting; and g) Areas of potential conflict. Please note that this list is not exhaustive and employees should declare an interest if they are in any doubt as to whether it should be recorded. Version 1.0 May 2016 17

Policy Details Title of Policy Unique Identifier for this policy State if policy is New or Revised Standards of Business Conduct BCPFT-HR-POL-29 New Previous Policy Title where applicable Policy Category Clinical, HR, H&S, Infection Control etc. Executive Director whose portfolio this policy comes under Policy Lead/Author Job titles only Committee/Group responsible for the approval of this policy Month/year consultation process completed * n/a Human Resources Director of Workforce and Organisational Development HR Consultant Workforce Development Group February 2016 Month/year policy approved April 2016 Month/year policy ratified and issued May 2016 Next review date May 2019 Implementation Plan completed * Equality Impact Assessment completed * Previous version(s) archived * Disclosure status Key Words for this policy Yes Yes Yes B can be disclosed to patients and the public Gifts, hospitality, conduct, public funds, integrity, probity, openness, declaration * For more information on the consultation process, implementation plan, equality impact assessment, or archiving arrangements, please contact Corporate Governance Review and Amendment History Version Date Details of Change 1.0 May 2016 New policy for BCPFT Version 1.0 May 2016 18