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Declaring interests

February 16, 2022

The Trust are introducing a new way of declaring interests through ESR. As NHS colleagues, we need to declare any interests – including gifts, hospitality or sponsorship received from third parties – to ensure transparency on how public funds and assets are being used and accessed.

It’s important to know that having an interest isn’t necessarily a problem – it’s the perception that can be damaging to individuals and the Trust, especially if something isn’t declared – but it is necessary to be open about what interests we have so that they can be taken into account in the appropriate way.

All colleagues are required to declare any interests on appointment and again if they change job or their circumstances change (e.g. they take on a second job outside of the Trust). Additionally, all ‘decision-making staff’ – that is those who are:

  • Executive and Non-Executive Directors (including Associate Non-Executive Directors)
  • Those at Agenda for Change band 8c and above
  • Medical consultants
  • All staff in the procurement team
  • All staff listed as having delegated financial authorities per the scheme of reservation and delegation

All of the above are required to make a declaration at least twice a year, even if it’s just to say they have no interests to declare.

Soon you will be able to make your declarations through a specific module on ESR called ‘Conflicts of Interest’.

Some key tips on what to declare:

  • Any non-cash/voucher gift (e.g. from a patient) of over £50 (gifts under £50 don’t need to be declared but it’s good practice to)
  • Any sponsorship received from suppliers/individuals
  • Any secondary employment or private practice.

Colleagues should also always:

  • Decline gifts of cash or vouchers (to individuals) – cash donations can be made as a donation to the Trust charity
  • Decline any gifts from suppliers or contractors doing business (or likely to do business) with the Trust.

There is helpful specific guidance from NHS England for the following staff groups:

The Trust’s Associate Director of Corporate Governance/Company Secretary, Dan Conway can also help provide advice on interpretation of the guidance; however decisions about what to declare or not are the responsibility of individuals. Please don’t hesitate to contact Dan by emailing swbh.declarations-admin@nhs.net if you have any questions.

Dan will also be offering the following drop in sessions on Microsoft Teams, for a live demonstration of how to make your declarations on ESR and a Q&A session.

See joining details for these sessions below: