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Declaring Interests

April 5, 2023

It’s fundamental that all colleagues are transparent and adhere to both our local policy and guidance set out by NHS England and declare any appropriate conflicts of interest against the clearly defined rules. Our ‘decision making staff’ are required to make either positive or nil declarations, aligned to each financial year. All other grades of staff are required to make positive declarations on receipt of any gift, hospitality or sponsorship or any known interest that may be a conflict to them and the Trust.

If you have a previous declaration on the system, please review and update the date from: 1 April 2023 to 31 March 2024. This will then refresh your declaration for this year.

Please click here to see instructions.

Our compliance of this will be monitored through our Counter Fraud Auditors and into the Audit and Risk Committee and Trust Board.

As NHS staff, 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. This will bring the Trust in line with the NHS England Guidance.

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 staff 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’ are required to make a declaration, even if it’s just to say they have no interests to declare. These declarations will be published on the Trust website to ensure openness and transparency.

‘Decision making staff’ are defined as the following:

  • 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

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

Staff should also always:

  • Decline gifts of cash or vouchers (to individuals) – cash donations can be made as a donation to the SWB 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:

Further guidance on how to make any declarations on ESR will be shared shortly.

The Trust’s Associate Director of Corporate Governance / Company Secretary 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 the Associate Director of Corporate Governance / Company Secretary, Dan Conway, at  swbh.declarations-admin@nhs.net if you have any questions.