Shropshire S Community & Mental Health Services NHS Trust

Shropshire Community Health NHS Trust

Report for Audit Committee

Hospitality Register: 1 August 2016 to 1 August 2017

1.Introduction

Shropshire Community Health NHS Trust Standing Orders (SO’s) require that the Trust maintains a Register of staff and Board Hospitality/Gifts. . This is in line with guidance contained in the Standards of Business Conduct for NHS Staff (Appendix to SOs), the Code of Conduct for NHS Managers, and the ABPI Code of Professional Conduct relating to hospitality/gifts from pharmaceutical/external industry.

The rationale for having the register, and asking staff to openly identify any gifts or hospitality they have been offered or accepted, is to ensure staff are not placed in a position of compromise or risk because of accepting any gifts which could be construed as an inducement. It is an offence for an employee to accept any inducement or reward for doing, or refraining from doing, anything in their official capacity or showing favour, or disfavour, in the handling of contracts. Staff must ensure they do not abuse their position for personal gain or for the benefit of their families or friends.

The principles are set out for staff in the Trust’s Code of Business Conduct, which is available on the staff zone of the Trust website.

During 2016/17, NHS England issued new guidance on the management of conflicts on interest.. This guidance sets out to:

• introduce common principles and rules for managing conflicts of interest
• provide simple advice to staff and organisations about what to do in common situations
• support good judgement about how interests should be approached and managed.

Changes from the old guidance includeupdating of circumstances where interests need to be declared, and giving more specific guidance on what and when interests should be declared.

In addition the new guidance was discussed at the Board and at Audit Committee. At its meeting in July 2017, the Audit Committee agreed a new Trust policy to incorporate the new national guidance.

The new arrangements were implemented during August 2017. The principles are set out for staff in the Trust’s Code of Business Conduct, which is available on the staff zone of the Trust website.

Staff who have who have decision making authority for goods and services exceeding £5k have been required to make a declaration of any interests.

The new Trust Code states that staff must declare and register any gifts, benefits or sponsorship of any kind - provided they meet the thresholds set out. For gifts this is £50. –Offers of hospitality over £25, whether refused or accepted must be declared. Articles of low valuesuch as small tokens of gratitude from patients or their relatives do not need to be registered.

The Code and what it means for staff has been publicised to Trust staff in ‘Inform’ the staff newsletter, and the Code is on the Trust zone of the web site with other policies. The Code and supporting publicity stress that if staff are unsure of whether they need to declare, they should seek advice from their line manager, Risk Manager or the Director of Corporate Affairs.

Staff are required to submit any declarations via ane- form on the Datix Risk Management System

It should therefore be noted that the earlier entries below were made under the “old rules”, and the later ones under the new policy.

2.Summary of Hospitality Register

Below is a summary, by Directorate, of each entry received for the Hospitality Register between 1 August 2016 and 1 August 2017 detailing offers which were accepted. There have been no notifications of offers of sponsorship/gifts etc which were made but not accepted. Each entry is submitted for review and sign off by the individual’s manager, and then by the Director of Corporate Affairs before being entered in the Register.

This year as last, there have been a number of declarations from our diabetes team relating to pharmaceutical companies. The lead for Diabetes attended the Committee in January 2017. The committee were satisfied that the sponsorship which the team receive is valuable to the team’s education, and that this approach could be used by other teams, provided the Standards of Business Conduct conflicts of interest requirements are followed

3a.Nursing & Operations Directorate

3b.Trust Board

3c.Corporate Affairs Directorate

3d.Strategy Directorate

3e.Finance Directorate

3f.Medical Directorate

None

4.Breakdown by Category

The following is a breakdown of entries for the last year by category. They have been broken down into 5 general categories, with the number of entries and estimated value. However, it should be noted that the estimated value of some entries is not given, or not known, for example when the hospitality/event was paid for directly by the sponsor.

For comparison purposes:

• 2013/14 21 entries, value £3,260
• 2014/15 15 entries, value £3,097
• 2015/16 19 entries, value £5,540
• 2016/17 15 entries, value £4,814.50

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