20th May 2021
N Vaughan
Private/Individual
Email:
[FYI request #15152 email]
Dear Mr Vaughan
Official Information Act Request for – Gifts to medical staff from Pharmaceutical Companies
I write in response to your Official Information Act request received by us 13th April 2021, you
requested the following information:
1. Do you keep a central gift register, which records details about what gifts medical staff receive,
who they are from, and the gift's value? If not, why not?
2. How many staff in your DHB have accepted gifts (of any form) from pharmaceutical
companies? Information from the past 2-year period is preferred, including what these gifts
were, and their monetary value.
3. Is there any policy in place that prevents medical staff from accepting some gifts from
pharmaceutical companies? If so, please send a copy of this policy.
In relation to disclosure of these gifts (from pharmaceutical companies):
4. When must medical staff disclose these gifts to the hospital or DHB? If there is a related policy,
please send a copy.
5. Are medical staff required to disclose these gifts to their patients? If there is a related policy,
please send a copy.
Counties Manukau Health Response:
For context Counties Manukau Health (CM Health) employs over 8,500 staff and provides health and
support services to people living in the Counties Manukau region (approx. 601,490 people). We see over
118,000 people in our Emergency Department each year, and over 2,000 visitors come through
Middlemore Hospital daily.
Our services are delivered via hospital, outpatient, ambulatory and community-based models of care.
We provide regional and supra-regional specialist services i.e. for orthopaedics, plastics, burns and spinal
services. There are also several specialist services provided including tertiary surgical services, medical
services, mental health and addiction services.
1. Do you keep a central gift register, which records details about what gifts medical staff receive,
who they are from, and the gift's value? If not, why not?
CM Health does not centrally capture information on gifts given, each service is responsible for
maintaining their own gift register. As per the CM Health conflict of Interest Policy, “any
Hospitality that is offered or accepted that has a value over $100 must be recorded in the
CMDHB Gifts Register for the relevant service”.
Counties Manukau Health
Private Bag 93311, Otahuhu, Auckland
T: 09 276 0000 | cmdhb.org.nz
2. How many staff in your DHB have accepted gifts (of any form) from pharmaceutical
companies? Information from the past 2-year period is preferred, including what these gifts
were, and their monetary value.
Table 1 below reflects the 2019 and 2020 entries of gifts/hospitality on the gifts register from
Pharmaceutical companies.
Description of gift, hospitality or Benefit
Approximate Value
Return flights to Wellington and 1 night’s
accommodation, Stroke Nurse Specialist Symposium
$737.00
2019
Meals, Venue, Parking – Heart Rhythm annual event
$768.00
attendance
Accommodation & food & transport - NZ Respiratory
$1,000.00
Workshop - July 2019
American College of Rheumatology (ACR) Conference in
$15,000.00
Atlanta Georgia, USA - Nov 2019
One Day conference at Wellington Oct 2019
$300.00
Heart Rhythm Meeting
$384.00
Return Economy flights to attend IBD Master class 2019
as an invited speaker. One night stay in Sofitel Melbourne
Value Unknown
on Collins.
IMID Conference Registration Speaker Honorarium Spa
$1,150.00
GP Seminar – July 2019
CSSANZ Colorectal Journal Club sponsorship and dinner
Value Unknown
meeting up to 4 x per year (for 5 staff).
Table 1: Data Sourced Finance Team
3. Is there any policy in place that prevents medical staff from accepting some gifts from
pharmaceutical companies? If so, please send a copy of this policy.
In relation to disclosure of these gifts (from pharmaceutical companies):
4. When must medical staff disclose these gifts to the hospital or DHB? If there is a related policy,
please send a copy.
In response to questions three and four, as per the CM Health Conflict of Interest Policy, “any
Hospitality that is offered or accepted that has a value of over $100 must be recorded in the
CMDHB Gifts Register for the relevant service”.
CM Health, has a Donations, Gifts and Sponsorship policy that provides detailed guidance to
staff on the appropriateness of specific interactions with third parties. The policy defines the
DHB’s requirements when considering approving (or declining) offers of sponsorship, donations,
gifts and corporate hospitality from external parties. The DHBs Conflict of Interest policy also
provides guidance in this regard.
5. Are medical staff required to disclose these gifts to their patients? If there is a related policy,
please send a copy.
Medical staff are not required to disclose gifts received from Pharmaceutical companies to
patients.
I trust this information answers your request. You are entitled to seek a review of the response by the
Ombudsman under section 28(3) of the Official Information Act. Information about how to make a
complaint is available at
www.ombudsman.parliament.nz or Freephone 0800 802 602.
Please note that this response or an edited version of this may be published on the Counties Manukau
Health website. If you consider there are good reasons why this response should not be made publicly
available, we will be happy to consider this.
Yours sincerely
Fepulea’i Margie Apa
Chief Executive Officer
Counties Manukau Health
Appendix 1 - Conflict of Interest Policy
Appendix 2 - Donations, Gifts & Sponsorship Policy
Appendix 1
Page 1 of 18
Conflict of Interest Policy
Policy: Conflict of Interest
Purpose
The purpose of this policy is to provide guidance on the identification, disclosure and
management of conflicts of interest within CMDHB. A secondary purpose of this policy is
to protect the integrity of the DHB and its employees by helping to ensure that employees
perform their duties in a fair and unbiased manner and that decisions are made
unaffected by private interests or personal gain.
Scope
This policy is applicable to all CMDHB employees, (full-time, part-time and casual
(temporary) including contractors, visiting health professionals and students working in
any CMDHB facility.
The activities covered by this policy include commercial transactions and recruitment of
employees as well as clinical research and related activities such as funding and research
grants.
Policy Statements
Where an employee has an interest (or potential interest) in a transaction - financial,
professional or personal - which may potentially conflict with their obligations to the DHB,
VAUGHAN
they must immediately declare that interest to the appropriate Manager or Clinical Head.
Where an interest, including an actual or potential conflict of interest, is identified the
relevant employee’s Manager/Clinical Head must:
decide whether any change to the employee’s activities is required to mitigate
any conflict; and
determine what other steps are necessary to appropriately deal with the interest.
Such decisions will be made in conjunction with the appropriate General Manager and
Legal Adviser where appropriate.
Where an employee has a conflict of interest and has knowingly withheld this
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information, and/or acted to their own advantage, the employee may be subject to
disciplinary action including dismissal.
The meaning of “conflict of interest”
A conflict of interest exists when it is likely that an employee could be influenced or could
be perceived to be influenced by a personal or private interest
in any transaction whilst
carrying out their responsibilities for the DHB.
Transaction means:
(a) the exercise or performance of a function, duty, or power of the DHB; or
(b) an arrangement, agreement, or contract to which the DHB is a party; or
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Conflict of Interest Policy
(c) a proposal that the DHB enter into an arrangement, agreement, or
contract; or
(d) the development of a strategy or policy that will guide future decision
making on service provision, purchasing, contracting or staff employment.
The functions the relevant individual performs, and delegated authorities that employee
holds at the DHB, will need to be considered to determine how a conflict of interest may
arise.
A personal or private interest is an interest that can bring benefit or disadvantage to an
employee as an individual, or to others whom the employee may wish to benefit or
disadvantage.
An Interest in a Transaction that can lead to a conflict of interest may exist where an
employee:
will derive financial, professional or personal benefit from the transaction
has financial interest in another party to a transaction
is a director, officer or trustee of another party to the transaction, or is a person
who will or may derive a material financial benefit from the transaction
is a shareholder of another party to the transaction
has an interest in another party tendering for work which the DHB is contesting
is the parent, child, spouse, sibling, partner or close friend of another party to the
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transaction, or a person who will or may derive a financial benefit from the
transaction.
Identifying a conflict of interest
Whether an actual or perceived conflict of interest exists must be actively
considered by:
a) all employees on an on-going basis, and
b) employees with decision making responsibilities whenever business or human
resources decisions are made.
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Although not all staff are responsible for making business decisions or managing other
staff, they may have an ability to indirectly influence decisions that are made or may
make other types of decisions which could be affected by a conflict of interest.
It can often be difficult to determine whether an actual or perceived conflict of interest
exists.
If an employee answers yes to any of the following questions it indicates that conflict of
interest may exist and further advice should be sought.
Would a fair and reasonable person perceive that I was influenced by personal
interest in performing my public duty?
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Conflict of Interest Policy
Do I, a relative, friend or associate stand to gain/lose financially from the DHB’s
decision or action on this matter?
Do I, a relative, friend or associate stand to gain/lose in any way from the DHB’s
decision/action?
Am I in a position to influence decision making about a matter related to a
potential personal or professional interest?
Have I made any promises or commitments in relation to this matter?
Have I received a benefit or hospitality from someone who stands to lose or gain
from the DHB’s decision/action?
Am I a member of an association, club or professional organisation, or do I have
particular ties or affiliations with organisations or individuals, who stand to lose or
gain from the DHB’s consideration of the matter?
Could there be benefits for me in the future that could cast doubt on my
objectivity?
Might I be perceived as favouring a particular person or firm because of a
personal friendship or long-standing association?
Am I in a position to influence development of a particular strategy or policy that
will guide future decisions from which I may benefit personally?
Do I need to seek advice or discuss the matter with an objective party?
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Am I concerned about my ability to act impartially and in the public interest?
Do I need to declare the matter to my manager or to the relevant decision making
group?
Answering “No” to any of the following questions should be a signal to an employee to
disclose their interest:
If I do participate in assessment or decision-making, would I be happy for my
colleagues and the public to be aware of any association or connection?
When I am making a presentation or recommendation to the Board or to another
decision making group, are they aware of my interests (including private practice
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commitments) which might be perceived as influencing the advice I am giving?
Actual, Perceived and Potential Conflicts of Interest
Conflicts of interest can be actual, perceived or potential.
An
actual conflict of interest involves a direct conflict between an employee’s
current duties and responsibilities and existing private interests.
A
perceived or
apparent conflict of interest can exist where it could be perceived,
or appears, that an employee’s private interests could improperly influence the
performance of their duties, whether or not this is the case.
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Conflict of Interest Policy
A
potential conflict of interest arises where an employee has private interests
that could conflict with other official duties in the future.
For advice, please contact the head of the decision making group to which you belong or
your relevant manager or Clinical Head.
Competing Interests or Conflict of Duties
Conflicts of interest can also arise where an individual has official roles in more than one
public organisation. In these situations, it may be difficult for a public official to keep the
roles separate and this can lead to poor performance of one of the roles, at least, and
unlawful or improper decision making at worst, or improper use of information to give
advantage to the second organisation etc. These types of conflict are not always
recognised because no private interest is involved or apparent. These situations are
usually described as one of competing interests or a conflict of duty, and are best
managed on the same basis as conflict of interest.
Employment of or promotion of relatives
There are situations under Section 32 (exception in Relation to Family Status) of the
Human Rights Act 1993 which allow an employer to impose restrictions on the
employment of any people who are married to, or living in a relationship in the nature of
marriage with, or who are related to other employees.
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Managers recruiting staff must ascertain whether the appointment of a person may
create an actual, potential or perceived conflict of interest. Employees should inform
their manager in the event that, subsequent to commencing employment, they enter into
a relationship that causes an actual or potential conflict of interest or a perception
thereof.
Managers should refer to the Recruitment Policy for further information
.
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Dealing with Conflicts of Interest
Disclosure of Conflict of Interest
After determining that a conflict of interest may exist in a particular situation, the
individual employee must disclose any actual or potential interest they have (whether
pecuniary or non-pecuniary).
The employee should disclose to their manager, or Clinical Head, and any relevant
decision making group, or the responsible decision making person, his or her conflict of
interest at the first available opportunity, for a decision as to what action should be taken
to avoid or deal with the conflict. Disclosures are to be treated as confidential if
appropriate. The employee must disclose not just the existence of a conflict or potential
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Conflict of Interest Policy
conflict, but sufficient details about the nature of the situation to allow appropriate
decisions to be made about management of the conflict.
Documentation of Conflict of Interest
The existence of a conflict of interest by a member of staff must be documented in an
Interests Register. This documentation should note:
the name of the employee
the nature of their interest in the transaction, and
what role they had in the transaction e.g. no role, only involved in the
discussion but not the decision, full involvement.
In circumstances where issues have been discussed and it has been decided that there is
no conflict of interest then there is no need to declare this, unless this is the expressed
wish of the employee involved.
It is best practice for the DHB to acknowledge that interests have been declared and
recorded appropriately.
Interests and Gift Registers
Interest Registers will be maintained to record all interests (actual or potential). The
required template for Interest Registers is attached at Appendix 3. The required template
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for Gift Registers is attached at Appendix 4. Registers are to incorporate as a minimum
the following information:
name of the person declaring the interest
name of the person the interest was declared to
date of declaration
organisation or individual involved
brief description of matter
action taken/comments.
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For Executive Leadership Team members the Interests and Gifts Register will be held by
the Director of Strategic Development. For all other service areas, the relevant General
Manager (or equivalent e.g. CMO, DON, DAH) will maintain an Interest and Gifts register
for their service. Each General Manager is responsible for ensuring that:
any staff within their area of responsibility who are required to complete an
interests/gifts declaration do so.
a copy of each completed form is maintained in a central folder.
any interests that are declared are recorded, along with a description of what will
be done to manage the interest (for example, arranging another staff member to
take over responsibilities relevant to the interest, ensuring the staff member is
not part of specific procurement processes)
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Conflict of Interest Policy
a register is maintained of all gifts that are declared.
advice is sought from the Legal Adviser and/or HR department as required in
relation to specific issues that may arise in relation to conflicts.
the above registers and documentation are available for inspection by internal
audit, legal services etc as required.
Interest and Gift Declarations
The following staff will be required to complete an annual Declaration of Interests, Gifts
and Hospitality Form as attached at Appendix 2, or confirm in writing to their manager or
Clinical Head that they have no interests, gifts or hospitality to declare:
Executive Leadership Team members
General Managers
Service Managers
Programme Mangers
Clinical Directors
Clinical Nurse Directors
Any employees or contractors involved in the purchase of major goods or services
or in a position to influence significant purchasing decisions.
VAUGHAN
In situations where an interest or potential conflict is identified in relation to an employee
not listed above, it is expected that a Declaration of Interest, Gifts and Hospitality form
will be provided to the individual for completion and that this will be included in the
Conflicts and/or Gifts register along with other required documentation about the nature
and extent of the interest and actions taken.
Assessing the seriousness of a conflict of interest
Assessing the seriousness of a conflict of interest is important for a number of reasons. It
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may be necessary for determining whether an interest exists (e.g. an interest may be so
remote or insignificant that it could not reasonably be regarded as influencing the
employee). The seriousness of the conflict can also be important in determining the
appropriate manner in which to manage the interest (for example, whether the
employees should be excluded from activities relating to the subject of the conflict or
potential conflict.
The Office of the Auditor General has identified the following factors that should be
weighed when assessing the seriousness of the conflict:
The type or size of the employee’s other interest
The nature or significance of the particular decision or activity being carried out
by the DHB
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Conflict of Interest Policy
The extent to which the employee’s other interest could specifically affect, or be
affected by, the DHB decision or activity
The nature or extent of the employee’s current or intended involvement in the
DHB’s decision or activity.
Seriousness is a question of degree. It involves a spectrum of directness and significance.
“Directness” is how closely the two interests concern each other, and “significance” is the
magnitude of the potential effect of one interest on the other.
Options for Dealing with a Conflict of Interest
Generally, if a pecuniary interest is disclosed, the individual with the interest must not be
involved in consideration or discussion of the matter in which he or she has the interest
and must not vote on any question relating to the matter.
In rare situations this may not be possible or desirable. For example, if a conflict of
interest is identified at or near the conclusion of a process. Appointing an independent
person to be involved in decision-making would minimize the actual or perceived
influence or involvement of the person with the actual or reasonably perceived conflict.
Another example is an employee with an interest may also have particular and unique
expertise in the matter under discussion. If that expertise is not readily available from
another source it may be to the DHB’s benefit to allow the employee to contribute their
expertise despite their interest in the matter. Such situations should be handled with
caution. There should be documentation of the reasons for allowing the employee’s
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participation and the steps taken to ensure the decision on the matter is unbiased.
However, a broader range of options exists for dealing with conflicts of interest that do
not have a pecuniary component. Choosing the right option to deal with the situation will
depend on the circumstances and an objective assessment of it. Options can include:
take no action because the conflict is assessed as being minor in nature or is
eliminated by disclosure or effective supervision
allow limited involvement (e.g. participate in discussion, but not in decision
making)
prohibit any involvement
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request the individual concerned relinquish or divest the personal interest which
creates the conflict
appoint an independent person to manage the process to provide assurances of
fairness and equity in the matter.
Appeals Process
If an employee and their manager/Clinical Head disagree with respect to any Conflict of
Interest issue, an appeal may be made for a review to the General Manager Human
Resources, or the Chief Medical Officer Hospital Services, or through other options
available to the employee.
Gifts and Hospitality
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Conflict of Interest Policy
Accepting gifts, hospitality or other benefits (such as sponsorship) can in some
circumstances cast doubt on the integrity and impartiality of CMDHB and the decisions
that the Board makes. Employees must ensure that they comply with the CMDHB
“
Donations, Gifts and Sponsorship” Policy and that appropriate disclosures are made
about any hospitality that is offered or received. All offers of hospitality must be
discussed with the relevant manager or Clinical Head to determine whether acceptance is
appropriate. Any hospitality that is offered or accepted that has a value of over $100
must be recorded in the CMDHB Gifts Register for the relevant service. The required Gift
Register Template is attached at Appendix 4.
Employees should be particularly aware that acceptance of any gifts or hospitality during,
or in close proximity to, any procurement or tendering process could undermine the
probity requirements in relation to purchasing transactions, particularly if the provider of
the gift or hospitality has any relationship, or potential relationship with a supplier of
goods or services to the DHB.
Employees should be aware that these requirements apply to any gifts or hospitality
offered or received where they may relate to DHB business, even if offered to an
individual in a capacity other than his/her capacity as an employee of the DHB.
VAUGHAN
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Conflict of Interest Policy
Definitions
Term/Abbreviation
Description
Conflict of interest
In the context of the public sector there is a conflict of interest
where:
“
A member’s or official’s duties or responsibilities to a public entity
could be affected by some other interest or duty that the member or
official may have”.
Relationship
A personal level of connection, association, interaction or
interdependence with any other person who may or may not be a
life partner, intimate other, blood relative or member of the same
household
Relative
For the purposes of this policy, a relative means any other person
who:
a) is related by blood, marriage (whether legal or de facto),
affinity, or adoption; or
b) is wholly or mainly dependent upon the employee; or
c) is a member of the employee’s household.
s.2(1)(c) Human Rights Act 1993
Associated Documents
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Other documents relevant to this policy are listed below:
NZ Legislation
Crown Entities Act 2004
NZ Public Health and Disability Act 2000
NZ Standards
None
CMDHB Policies / Procedures Code of Conduct
Delegated Authority
Additional / secondary Employment
Discipline and Dismissal
Donations, Gifts and Sponsorship
Conflicts of Interest, Gifts and Hospitality – Board
Members
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Workplace Relationship Policy
Other related documents
“Good Practice Guide: Managing conflicts of interest:
Guidance for public entities” Office of the Controller and
Auditor-General (2007)
“Good Practice Guide: Procurement guidance for public
entities” Office of the Controller and Auditor-General
(2008)
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Conflict of Interest Policy
Appendix 1: Conflict of Interest Examples and Recommended Actions
Listed below, under various classifications, are situations where conflicts of interest may
potentially occur and a recommended action to avoid or deal with the conflict.
Gifts/benefits or hospitality from Suppliers
Situation
Recommended Action
Accepting gifts or benefits from suppliers, or
Refer to your policy on gifts and gratuities. Best
other individuals, involved in the provision of
practice is to accept the gift on behalf of the
goods and/or services could present a conflict
unit for which you work. If the gift is expressly
of interest or obligation. Gifts and benefits can for you, report that you received the gift to
take many forms e.g. lucky door prizes, raffles,
your manager/clinical head to record the
travel, meals. It also includes opportunities to
details appropriately.
attend educational conferences or meetings
Note that there are limits placed on the value
and attendance at or participation in sports
of gifts that can be received.
events.
Offers of sponsorship to attend clinical
(Note: Sponsorship/benefits for the use of a
conferences should be discussed with the
particular Unit or Service, rather than for an
clinician’s Clinical Director before acceptance.
individual, may be solicited from suppliers with Offers accepted must be reported to the
the prior approval of a General Manager or the clinician’s General Manager.
Chief Executive. The Executive Director of the
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South Auckland Health Foundation should be
advised of the intention to approach a
supplier.)
Purchasing of Goods and Services or Letting of Contracts
Situation
Recommended Action
Selection of Tenders: Preferring tenderer or
Where there is a private interest with any
prospective contractor with whom there is a
tenderer or contractor , the employee must
private relationship (family relationship or close withdraw from the selection or appointment
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friendship).
process.
Presentations to the Board or other decision-makers
Situation
Recommended Action
Making a written or oral presentation to the
At the start of the written or oral presentation
Board (or to another CMDHB decision making
the presenter is expected to explicitly declare
body) about equipment, facilities or services
their private practice involvement. The Board
when the presenter has, or is contemplating,
or other decision making body then has an
private sector involvement in a similar service.
opportunity to ask questions about this
interest.
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Conflict of Interest Policy
When arrangements are being made for a staff
member to make a presentation to the Board,
the staff member will be reminded of the
expectation to declare private practice
commitments.
Recruitment
Situation
Recommended Action
Sitting as a member on selection panels where
Declare the interest and withdraw from any
applicants for the position are known to the
part of the recruitment process is the
member personally, as family, friend or close
preferred option; however in some situations
associate, to an extent that could be considered
it may be necessary to include the person with
to be a conflict of interest.
the conflict on the panel (for example in cases
where they have specific expertise that is
required). In these cases it may be an option
to involve an independent person in the
recruitment process.
Being in a position to influence the selection, or
Declare the interest. Other actions as noted
non-selection, of an applicant for a position
above.
where the applicant is known personally and
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involvement could be perceived to be a conflict
of interest.
Staff administration
Situation
Recommended Action
Having a close personal and/or family
All employees are to be treated equally and
relationship with another employee over whom
fairly and any relationships that could be
control is exercised.
perceived to be of possible concern should be
brought to the attention of the appropriate
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See Definitions for definition of ‘relationship’ and senior employee. If it appears that employees
‘relative’.
are being given preferential treatment, these
concerns should be addressed through the
disciplinary process.
Improper actions in relation to staff administration
Improper actions in the context of staff management include:
promoting friends or relatives when other employees are more deserving
Document ID:
A5702
CMH Revision No:
4.0
Service :
Legal and Privacy Services
Last Review Date :
10/04/2019
Document Owner:
Chief legal advisor
Next Review Date:
10/04/2022
Approved by:
Chief Executive Officer (CEO)
Date First Issued:
23/04/2009
If you are not reading this document directly from the Document Directory this may not be the most current version.
Page 12 of 18
Conflict of Interest Policy
Preferentially rostering staff to the advantage of particular individuals due to personal
association with those persons. This can have financial (penalty rates etc) advantage to
the favoured individuals to the disadvantage of other employees.
Regular allocation of overtime to particular individuals, to the disadvantage of other
persons equally entitled and equally efficient.
Assessment and/or inappropriate recommendation of particular individuals over others
because of personal associations, for such things as:
o training courses;
o attending conferences;
o job or advancement opportunities.
Recommending incremental progression, or non-progression, of particular individuals due
to personal interests, or attitudes, that are not aligned to the work situation.
Giving preference for the taking of leave by individuals to the detriment of others due to
personal association.
Not applying the same rules equally to all employees because of personal association e.g.
failure to address issues of late attendance, non-performance, etc.
Election to public office
Situation
Recommended Action
Employees may offer themselves for appointment
Employees should notify the Chief Executive
or election to any public office, but they should be
immediately they offer themselves for
aware that the duties of the office may conflict with appointment or election to public office (or,
VAUGHAN
the due and proper discharge of their duties with
preferably, before they offer themselves).
Counties Manukau DHB.
Client/Patient Relationship and Referrals to Private Practice
Situation
Recommended Action
Providing information or making recommendations Staff are not to give preferential treatment
to patient s about service providers where one of
to personal associates at the expense of
the service providers is a close friend/relative, etc.
others.
OIA13042021 Clinicians have an ethical duty to provide
patients with all the information necessary
for them to make decisions about treatment
options. When a patient requests
information about private sector treatment,
the clinician should ensure that they make
known to the patient all the options that
might reasonably be considered. Care is
especially needed if the clinician is a
potential private provider. It is advisable to
recommend that the patient discuss the
referral with their GP.
Document ID:
A5702
CMH Revision No:
4.0
Service :
Legal and Privacy Services
Last Review Date :
10/04/2019
Document Owner:
Chief legal advisor
Next Review Date:
10/04/2022
Approved by:
Chief Executive Officer (CEO)
Date First Issued:
23/04/2009
If you are not reading this document directly from the Document Directory this may not be the most current version.
Page 13 of 18
Conflict of Interest Policy
Situation
Recommended Action
If a staff member is found to have received a
financial return for recommending one
service provider, or firm, disciplinary action
taken may include dismissal.
Participation in Political Activities
Situation
Recommended Action
Employees serving in executive positions within any Employees should advise the Chief
political party or politically sensitive organisation
Executive in writing, with a copy to the GM
are open to allegations of bias in favour of that
Human Resources, upon being appointed to
organisation to the detriment of Counties Manukau executive positions within any political party
DHB.
or politically sensitive organisation.
Working in Clinical Teams
Situation
Recommended Action
VAUGHAN
Temporary reporting relationships between
Manager discretion (in consultation with
relatives/partners
their manager) to implement a different
reporting line if deemed necessary in the
particular circumstances.
Agree to and review processes to assess how the
Discuss with the employees involved about
professional relationships between family
how this might best occur.
members/partners are working.
All staff, including Clinicians and Other Health Professionals
Health professionals encounter a variety of circumstances in their day-to-day work which could
OIA13042021
give rise to potential conflicts of interest.
Situation
Recommended Action
Establishing a relationship with a
pharmaceutical Declare any potential conflict of interest to
company or medical equipment supplier where
the Chief Executive Officer (CEO) or
it could be perceived that preference was given
authorised delegate[s] e.g. your Manager or
to that particular company during a procurement Clinical Head.
/ tendering process.
Accepting
travel and accommodation fees to
Obtain approval from CEO or authorised
present research findings.
delegate[s] for accepting travel and
Document ID:
A5702
CMH Revision No:
4.0
Service :
Legal and Privacy Services
Last Review Date :
10/04/2019
Document Owner:
Chief legal advisor
Next Review Date:
10/04/2022
Approved by:
Chief Executive Officer (CEO)
Date First Issued:
23/04/2009
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Page 14 of 18
Conflict of Interest Policy
Situation
Recommended Action
accommodation fees and releasing of
possible confidential information.
Accepting
payment of fees and/or honorariums
for sitting on committees.
If a fee-for-service is received and the
service is provided during working hours,
then the income must be declared and
provided to the organisation. (Also refer to
Secondary/Additional Employment Policy)
Participating on
professional boards,
committees, societies, etc. which could
Obtain approval from CEO or authorised
constitute a conflict of interest with position held delegate[s] to participate in external boards
in the DHB.
etc where there is any or could be a
perception of a conflict with the duties or
functions performed in the DHB.
Having
directorships and
share holdings in
Declare the interest to the CEO or
private companies, associations, etc which deal
authorised delegate[s] who would then
with the DHB.
decide whether a conflict of interest existed
and possibly restrict the person’s
involvement in the DHB’s processes or
request resignation from external
Evaluating new
products/drugs where decisions
involvement.
VAUGHAN
may be influenced by personal
associations/offers of samples or equipment,
Declare any potential conflict of interest to
whether to the individual or the organisation.
the CEO or authorised delegate[s].
Evaluating new
products/techniques/devices
developed by employees also involved in clinical
This must be approved by the Clinical Review
trials of same; or when a company licensed to use Board and the Research Review Committee,
an employee’s invention is sponsoring trial to be
who will decide on how to manage the
undertaken with the DHB.
conflict and legal responsibilities.
Appointment to a paid position as a
medical or
technical advisor to a supplier (e.g. a
OIA13042021 The offer of appointment should be
pharmaceutical company or medical supplies
discussed by the employee with his or her
company) is likely to create a conflict of interest.
General Manager or Clinical Director before
accepting.
Publicly endorsing a product or service and
including the health professional’s position at the DHB employees must not allow their names
DHB, is not to take place unless authorised by the and positions at the DHB to be used in
employee’s Manager or Clinical Director.
product or service endorsements in material
sent by suppliers to potential customers.
Employees may, subject to the approval of
their Manager or Clinical Director, agree to
give advice about the adequacy of the
product or service to another prospective
Document ID:
A5702
CMH Revision No:
4.0
Service :
Legal and Privacy Services
Last Review Date :
10/04/2019
Document Owner:
Chief legal advisor
Next Review Date:
10/04/2022
Approved by:
Chief Executive Officer (CEO)
Date First Issued:
23/04/2009
If you are not reading this document directly from the Document Directory this may not be the most current version.
Page 15 of 18
Conflict of Interest Policy
Situation
Recommended Action
purchaser e.g. another DHB.
Other Activities that are likely to cause conflicts of interest
Situation
Recommended Action
Having a significant financial interest in an
Such interests must be disclosed.
organisation that receives funding from the DHB
or is a supplier to the DHB.
Receiving gifts, loans or other special privileges
As a general rule such benefits should not
from an organisation that receives funding from
be accepted. The offer of them should be
the DHB or is a supplier to the DHB.
disclosed. (See section on Gifts/Benefits or
Hospitality above for limited exceptions and
further guidance).
Payment or receipt, by individual employees, of
Such activities are prohibited.
rebates or bribes or other forms of compensation (Rebates for the DHB itself may be
to induce funding or obtain favourable contract
negotiated in some instances as part of
terms.
normal contractual arrangements).
VAUGHAN
Use of the DHB’s funds to reimburse employees
Such activities are prohibited.
or others in ways that would violate CMDHB’s
policies.
Holding unrecorded cash funds.
This is prohibited. All funds due to the DHB
must be paid into a DHB bank account.
Holding outside employment or being a director
Such activity must be disclosed to Counties
of another healthcare provider.
Manukau DHB. Refer also to the Additional
Employment Policy.
OIA13042021
Document ID:
A5702
CMH Revision No:
4.0
Service :
Legal and Privacy Services
Last Review Date :
10/04/2019
Document Owner:
Chief legal advisor
Next Review Date:
10/04/2022
Approved by:
Chief Executive Officer (CEO)
Date First Issued:
23/04/2009
If you are not reading this document directly from the Document Directory this may not be the most current version.
Page 16 of 18
Conflict of Interest Policy
Appendix 2- Declaration of Interests Form
Declaration of Interests, Gifts and Hospitality
This form must be completed by all DHB staff who:
o
are involved, or may be involved, in the purchase of any goods and/or services or who are in a position to make or
influence a significant purchasing decision.
o
are required to complete the declaration in accordance with the CMDHB Conflict of Interest Policy
o
who have, or may have, an interest or conflict relevant to DHB activities
PART A:
DECLARATION OF INTERESTS
Please declare any interest you may have which may cause, or may be perceived as causing, a conflict with your duties and
responsibilities as a CMDHB employee. This includes financial interests you may have in other agencies that the DHB does
or may contract with or has relationships with; secondary employment with such other organisations; private clinical practice
commitments you may have; and close family relationships with other individuals who may be in any of the above categories
(e.g. parent, partner). Please ensure that you provide full details of the nature of the interest you are declaring. If you have
no interest to declare please write “NIL”.
DESCRIPTION OF INTEREST
PART B:
DECLARATION OF GIFTS, GRATUITIES, HOSPITALITY AND SPONSORSHIP
Please include below details of any offers, gifts, gratuities, hospitality and/or “sponsorship” with value greater than $100 that
VAUGHAN
have been offered and/or received during the past 12 months from any company or organisation that CMDHB does or may
contract with for the provision of goods or services.
COMPANY OR
DESCRIPTION OF OFFER
ACCEPTED/DECLINED
OGRANISATION
PART C:
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I confirm that at the date of signing, the above is true and complete.
I agree that I will declare any interests, conflict, offers, gifts, gratuities, hospitality, sponsorship and/or interest on an ongoing
basis throughout the year in accordance with the CMDHB “Conflict of Interest” and “Gifts, Donations, and Sponsorship”
policies.
Signature
Print Name
Date:
Document ID:
A5702
CMH Revision No:
4.0
Service :
Legal and Privacy Services
Last Review Date :
10/04/2019
Document Owner:
Chief legal advisor
Next Review Date:
10/04/2022
Approved by:
Chief Executive Officer (CEO)
Date First Issued:
23/04/2009
If you are not reading this document directly from the Document Directory this may not be the most current version.
Page 17 of 18
Conflict of Interest Policy
Appendix 3 – Template Conflict of Interest Register
INTERESTS REGISTER for recording all interests declared for
…………………………………service/department
Interest
Date
Full description of the
Actions to be taken to
Signature of GM,
declared by:
declared
nature of the interest.
appropriately manage
CMO, DON, DAH or
any conflict or potential
equivalent
conflict.
VAUGHAN
OIA13042021
Document ID:
A5702
CMH Revision No:
4.0
Service :
Legal and Privacy Services
Last Review Date :
10/04/2019
Document Owner:
Chief legal advisor
Next Review Date:
10/04/2022
Approved by:
Chief Executive Officer (CEO)
Date First Issued:
23/04/2009
If you are not reading this document directly from the Document Directory this may not be the most current version.
Page 18 of 18
Conflict of Interest Policy
Appendix 4 – Template Gifts and Hospitality Register
GIFTS REGISTER for recording gifts, donations and hospitality over the value of $100 for
………………………………service/department
Gift declared by
Description of
Donor
Approx
Accepted
Date declared
Gift, Hospitality
value
/declined
or Benefit
VAUGHAN
OIA13042021
Document ID:
A5702
CMH Revision No:
4.0
Service :
Legal and Privacy Services
Last Review Date :
10/04/2019
Document Owner:
Chief legal advisor
Next Review Date:
10/04/2022
Approved by:
Chief Executive Officer (CEO)
Date First Issued:
23/04/2009
If you are not reading this document directly from the Document Directory this may not be the most current version.
Appendix 2
Page 1 of 12
Policy: Gifts, Donations and Sponsorship
Policy: Gifts, Donations and Sponsorship
Purpose
Donations and sponsorship may assist Counties Manukau District Health
Board (CM Health) to enhance the services that it delivers for the CM
Health community and achieve its Triple Aim of improving population
health and reducing inequities, improving patient experience and
providing value for money.
In relation to the
receipt of gifts, donations or sponsorship, the purpose of
this policy is to ensure that any offer made by an external organisation or
individual to:
(a) supply goods or services at no financial cost to CM Health;
(b) provide funding voluntarily to CM Health without expectation of
receiving goods or services in return; or
(c) sponsor CM Health activities
is carefully reviewed, and that any risks to CM Health in accepting the
donation are minimised.
This will be particularly important where there is a potential for the
VAUGHAN
commercial entity to gain public exposure as a result of the donation,
potential for the public to perceive that the entity may gain some
advantage from CM Health by providing the donation or potential for
public concern regarding the donation.
In relation to the
provision of gifts, donations or sponsorship by CM
Health to an external organisation or individual, the purpose of this
policy is to ensure that funds are only provided in this manner in
appropriate circumstances and the application of funds in this way is in
line with CM Health’s objectives, functions and values.
OIA13042021
Scope
This policy is applicable to all CM Health employees, contractors and
Board members in relation to their CM Health activities or any activities
that could be considered directly or indirectly relating to their CM Health
duties. The policy does not apply to:
(a) small donations or koha (<$500) given by patients or their families
for the comfort of patients or staff in the ward or outpatient setting;
(b) gifts offered by external parties or individuals to individual CM
Health employees or groups of CM Health employees where these
Document ID:
A10443
CMH Revision No:
5.0
N/A - Controlled document used across the
Service :
Last Review Date :
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organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
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Page 2 of 12
Policy: Gifts, Donations and Sponsorship
arrangements are adequately covered by the general CM Health
Conflict of Interest Policy.
(c) in kind contributions negotiated as part of a service agreement in the
normal course of business and in accordance with DHB probity and
procurement processes.
While the terms “gift”, “donation” and “sponsorship” are predominantly
used in this document, this Policy also covers any prizes, koha, gratuities
and hospitality which is provided free of charge and with no expectation
that goods or services will be delivered in return. This Policy also
applies to sponsorships to attend conferences and/or undertake
educational activities where those activities are proposed to be paid for
by third parties.
For avoidance of doubt, this Policy applies to all areas of CM Health.
The general policy directions contained in this document are also
applicable to the activities of the Middlemore Foundation. However, it is
acknowledged that the Middlemore Foundation has its own processes for
ensuring that sponsorship arrangements are sought, assessed, negotiated
and managed in line with the general policy requirements specified in
this document. As such, the specific processes that will be followed by
the Middlemore Foundation when seeking, implementing and managing
sponsorship arrangements may be different to those specified for CM
VAUGHAN
Health Staff.
Policy
Receiving donations, gifts and sponsorship
From time to time, CM Health may be offered donations, gifts or
sponsorship. These can come from a number of sources including
corporate entities, suppliers, trusts, patients and estates, which may be
private or public entities, for-profit or not-for-profit. Donations are
valuable as they may enable CM Health to expand service provision,
enhance patient comfort and further develop health care services to meet
OIA13042021
community health needs and aspirations.
Prior to accepting any donation, CM Health must be satisfied that:
(a) there has been a transparent and open process leading up to the offer
of the donation;
(b) any risks associated with accepting the donation have been carefully
considered and minimised;
(c) no donor or sponsor (or individual employed by or associated with a
donor or sponsor) shall benefit directly, or gain advantage over
Document ID:
A10443
CMH Revision No:
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N/A - Controlled document used across the
Service :
Last Review Date :
2/02/2021
organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
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Page 3 of 12
Policy: Gifts, Donations and Sponsorship
others, in respect of services provided by CM Health as a result of
the donation, gift or sponsorship;
(d) the donation, gift or sponsorship complies with any sector or
industry codes and guidelines relevant to the proposed donation;
(e) any conditions attached to the sponsorship or donation are acceptable
and can be met by CM Health;
(f) the donation, gift or sponsorship does not impact on CM Health’s
ability to deliver health services safely and in an manner that is
acceptable to CM Health in all respects; and
(g) appropriate and transparent processes are in place to manage the
receipt and subsequent use of the donation.
Risks to be considered include:
(a) probity risks (for example, risks that the donation may, or may be
perceived to: affect CM Health’s impartiality; place CM Health
under an obligation to the donating party; or have a commercial
influence over CM Health purchasing decisions);
(b) reputational risks (for example, risks which may be seen to affect
CM Health’s integrity);
(c) risks that the proposed donation does not align with CM Health’s
Triple Aim objectives of improving population health and reducing
VAUGHAN
inequalities, improving patient experience and providing value for
money;
(d) risks that the donation will impact on CM Health’s ability to achieve
its objectives or perform its functions as set out in the New Zealand
Public Health and Disability Act 2000 (the Act);
(e) risks that accepting the donation would give rise to adverse publicity
or public concern;
(f) risks relating to any conditions imposed by the donating party on the
donation.
OIA13042021
In considering the above, CM Health shall have regard to:
(a) the reasons for the gift being offered;
(b) whether the gift displays an organisation logo or branding;
(c) whether the party making/offering the gift, donation or sponsorship
has or appears to have values, practices, products or branding which
Document ID:
A10443
CMH Revision No:
5.0
N/A - Controlled document used across the
Service :
Last Review Date :
2/02/2021
organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
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link to page 25
Page 4 of 12
Policy: Gifts, Donations and Sponsorship
are in conflict with the stated vision, objectives or policies of CM
Health
1;
(d) any conditions attached to the donation;
(e) specific wishes of the donor or sponsor;
(f) how the donation may look to the public;
(g) whether the donation might be construed as providing access for
marketing by the donor (e.g. via branding) to the CM Health
population;
(h) any services provided by the donating party or CM Health contracts
held by the party;
(i) The benefits to CM Health;
(j) The benefits to the external organisation; and
(k) the value or importance of the gift or donation to CM Health.
Process:
The following process is to be followed by staff members who are
considering receiving a donation, gift or sponsorship:
Step1:
The appropriate General Manager will document a risk
analysis for acceptance of the proposed donation, gift or
sponsorship with consideration given to the above factors.
VAUGHAN
The General Manager may approve the acceptance of gifts
>$50 or hospitality >$100 but less than $500 .
Step 2:
The ELT Director
associated with the service
area/Directorate will review the risk analysis and where
he/she considers that there are significant risks associated
with
it,
and/or
the
proposal
relates
to
a
gift/donation/sponsorship of a value equal to $500 or greater,
the proposal is to be considered by the Executive Leadership
Team, who shall recommend to the Chief Executive Officer
the actions to be taken with respect to the proposal.
OIA13042021
Step 3:
If ELT is of the view that there are no significant risks
associated with accepting, they shall promptly advise the
relevant General Manager of this decision in writing.
1 This is likely to include (but is not limited to) situations where the proposed sponsor or associated party,
product or service is strongly linked to:
the production, sale or promotion of tobacco or alcohol
the gambling industry
the production, sale or promotion of food or beverages where the overall or specific approach is in
conflict with nutrition messages promoted by CM Health
health products whose use is not endorsed by CM Health (e.g. unresearched medicines or devices).
Document ID:
A10443
CMH Revision No:
5.0
N/A - Controlled document used across the
Service :
Last Review Date :
2/02/2021
organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
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Page 5 of 12
Policy: Gifts, Donations and Sponsorship
Step 4:
As a general rule, acceptance of the donation, sponsorship or
gift is to be notified to the donor in writing. Any terms of
acceptance should be specified in writing to ensure that there
are no subsequent misunderstandings between the donor and
CM Health.
Figure 1 below provides a summary of the gift, donation, sponsorship approval
process described above.
Donation,
No further action.
sponsorship or gift
Donor/
made as arranged.
Sponsor
The Staff Member notifies
Decision to
Decision to
their GM of proposed
accept donation
decline donation
CM Health
donation, gift or
notified to the
notified to the
Staff Member
sponsorship.
Staff Member
Staff Member
GM undertakes and
Decision to
accept
Decision to
decline
CM Health
documents a risk analysis
donation notified to
donation notified to
General
for the proposed donation.
the GM.
the GM.
Manager
Proposal and GM risk
Proposal considered high
No -
analysis considered by
risk or proposal relates to
ELT Sub-
Accepted
relevant ELT Director
gift/donation of a value
committee
equal to $500 or greater
>$500?
Yes
Accepted
Declined
Proposal &
ELT
recommendation of the
VAUGHAN
ELT Director considered
Committee
by ELT.
Gift, donation, sponsorship proposal
Chief
accepted or declined by CEO.
Executive
Officer
OIA13042021
Document ID:
A10443
CMH Revision No:
5.0
N/A - Controlled document used across the
Service :
Last Review Date :
2/02/2021
organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
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Page 6 of 12
Policy: Gifts, Donations and Sponsorship
Accepting gifts, hospitality or other benefits (such as sponsorship) can in some
circumstances cast doubt on the integrity and impartiality of CMDHB and the
decisions that the Board makes. Employees must ensure that they comply with
the CMDHB “Gifts
Donations and Sponsorship” Policy and that appropriate
disclosures are made about any hospitality that is offered or received. All offers
of gifts or hospitality must be:
Discussed with the relevant manager or Clinical Head to determine whether
acceptance is appropriate. Any gift that is offered or accepted that has a
value of over $50 must be recorded in the CM Health Gifts Register for the
relevant Service. Any hospitality that is offered or accepted that has a value
of over $100 must be recorded in the CM Health Gifts Register for the
relevant service. The required Gift Register Template is attached at Appendix
1. Any gift, donation or sponsorship over the value of $500 requires
consideration by the Executive Leadership Team (refer Gifts, Donation and
Sponsorship Policy). Any gifts or offers of hospitality that are declined must
also be recorded in the Gifts Register.
Employees should be particularly aware that acceptance of any gifts or
hospitality during, or in close proximity to, any procurement or tendering
process could undermine the probity requirements in relation to purchasing
transactions, particularly if the provider of the gift or hospitality has any
relationship, or potential relationship with a supplier of goods or services to
the DHB.
Employees should be aware that these requirements apply to any gifts or
VAUGHAN
hospitality offered or received where they may relate to DHB business, even
if offered to an individual in a capacity other than his/her capacity as an
employee of the DHB.
Soliciting Donations or Sponsorship:
CM Health may also wish to solicit donations and sponsorship from external parties
in order to support organisation objectives that are not already funded under normal
revenue streams or contracts.
No staff member may solicit for donations or sponsorship without the express
approval of their GM , who may set limits on that approval. Consideration should
OIA13042021
be given before solicitation about whether the donation or sponsorship contributes
to CM Health’s achievement of the Triple Aim and whether it could pose any risks
to the DHB as described in this policy. These issues should be discussed with the
GM when approval to solicit is sought.
Staff members who have received approval to solicit donations must ensure that all
potential donors and sponsors are aware that final decisions regarding acceptance
of any donation of a value equal to $500 or greater can only be made by the CEO
(in accordance with the requirements specified above), in consultation with the
Executive Leadership Team.
Document ID:
A10443
CMH Revision No:
5.0
N/A - Controlled document used across the
Service :
Last Review Date :
2/02/2021
organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
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Page 7 of 12
Policy: Gifts, Donations and Sponsorship
Managing donations:
If CM Health accepts a donation, gift or sponsorship, CM Health shall subsequently
ensure that:
(a) Donations and sponsorships received do not distract staff energies or divert
CM Health operating funds from planned objectives and contractual
responsibilities;
(b) Any conditions attached to the donation or sponsorship (which CM Health has
accepted) are recorded in writing and notified to the staff members who will be
responsible for managing the donation;
(c) Specific wishes of the donor or sponsor in relation to the donation, gift or
sponsorship are met wherever possible, provided that the requests are
reasonable;
(d) Gifted assets, money and/or services are managed appropriately and in
accordance with any agreed conditions;
(e) Donated or gifted monies that are not directly or immediately spent on
products or services are held in trust by CM Health in a specific account
separate from CM Health’s operating monies;
(f) Expenditure of any sort from accounts holding donated or gifted money is
approved by a CM Health staff member with the relevant level of delegated
authority; and
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(g) Expenditure related from accounts holding donated or gifted funds is recorded
and reported as part of standard CM Health financial reporting processes.
Providing donations, gifts and sponsorship
In exceptional circumstances, CM Health may choose to provide donations, gifts or
sponsorship to external organisations or individuals. In these situations, CM
OIA13042021
Health must be satisfied that:
(a) any donations are consistent with CM Health’s objectives and
functions as set out in the Act and relevant planning documents;
(b) the size of any gift, donation or sponsorship is appropriate for the
circumstances;
(c) benefits to CM Health in making the donation are clear and can be
justified;
Document ID:
A10443
CMH Revision No:
5.0
N/A - Controlled document used across the
Service :
Last Review Date :
2/02/2021
organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
If you are not reading this document directly from the Document Directory this may not be the most current version.
Page 8 of 12
Policy: Gifts, Donations and Sponsorship
(d) the donation does not impact CM Health’s impartiality or integrity, or
give rise to public perception that impartiality or integrity has been
compromised;
(e) in the case of koha, that the koha reflects the occasion and will not be
confused with any other payments made to the entity;
(f) in the case of gifts, that the nature and the value of the gift is
appropriate for the particular occasion;
(g) any donation is non-political; and
(h) any donation is lawful in all respects;
Any donation, gift or sponsorship for an external organisation or individual must be
pre-approved by the CEO who shall seek advice on the risks associated with
providing the donation, if appropriate, from the CM Health Executive Leadership
Team prior to offering any donation.
If the CEO approves the donation,
(a) the monetary donation is recorded through normal CM Health
financial expenditure systems;
(b) any conditions attached to the donation are documented in writing
and clearly articulated to the recipient; and
VAUGHAN
(c) the name of donation recipient and purpose of the donation is
documented.
(d) A register of these approvals will be kept by the CEO Office.
Middlemore Foundation
CM Health has a special relationship with the Middlemore Foundation in the
fundraising area. As such, and because the Middlemore Foundation has
considerable expertise in negotiating and managing sponsorship arrangements, it is
strongly recommended that they assist in the design, negotiation and management
of any high value or complex sponsorship agreements.
OIA13042021
CM Health acknowledges that the Middlemore Foundation has its own processes in
place to consider the matters specified above. As part of this process, selected CM
Health ELT members participate in assessments of sponsorship opportunities
managed by the Middlemore Foundation and are able to request that a sponsorship
arrangement be reviewed or considered by all ELT members in appropriate
circumstances.
Document ID:
A10443
CMH Revision No:
5.0
N/A - Controlled document used across the
Service :
Last Review Date :
2/02/2021
organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
If you are not reading this document directly from the Document Directory this may not be the most current version.
Page 9 of 12
Policy: Gifts, Donations and Sponsorship
It is also acknowledged that the Middlemore Foundation makes it clear to donors
and/or potential donors, that donations can only be accepted by the CM Health
CEO
Definitions
Terms and abbreviations used in this document are described below:
Term/Abbreviation
Description
Donation
A payment (either in money or by
way of goods or services) made
voluntarily
and
without
expectation that goods or services
will be provided in return but
usually with an expectation that
the donation will be put directly
towards the purposes of the
recipient.
Gift
Money,
service,
product or
tangible item given generally in
recognition of something provided
by the recipient. Could also be in
VAUGHAN
the form of free hospitality or
privileged access to goods or
services.
Koha
A gift, token or contribution given
on appropriate occasions, often as
a cultural courtesy.
Could be considered a ‘gift’ or
‘donation’ depending on the
circumstances and purpose of the
koha.
OIA13042021
Sponsorship
Money, service or product given to
support an organisational activity
with, or without, a requirement on
the part of the sponsor to
publically
acknowledge
the
sponsorship. Could also be in the
form of
free hospitality or
privileged access to goods or
services.
Document ID:
A10443
CMH Revision No:
5.0
N/A - Controlled document used across the
Service :
Last Review Date :
2/02/2021
organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
If you are not reading this document directly from the Document Directory this may not be the most current version.
Page 10 of 12
Policy: Gifts, Donations and Sponsorship
Supply of goods or services
Includes
patient
education
resources/packs (as goods); for
example contributions to newborn
packs given to women birthing in
CM Health facilities
Prize
A gift, token or contribution given
generally
in
recognition
of
something
achieved
by
the
recipient. Could also be in the
form of free hospitality or
privileged access to goods or
services.
A prize could be considered a
‘gift’, ‘donation’ or form of
‘sponsorship’ depending on the
circumstances in which the prize is
given.
Associated Documents
Other documents relevant to this policy are listed below:
VAUGHAN
NZ Legislation
New Zealand Public Health and
Disability Act 2000
CM Health Policies
Conflicts, of Interest Policy
Delegated Authority Policy
Corporate Relationships Policy
Code of Conduct Policy
Discipline & Dismissal Policy
Fraud Monitoring & Management
Policy
NZ Standards
None
OIA13042021
Organisational Procedures
Other related documents
Office of the Auditor General
Controlling Sensitive Expenditure:
Guidance for Public Entities
(2007).
Office of the Auditor General
Public Sector Purchases, Grants
and Gifts: Managing Funding
arrangements with external parties
(2008).
Document ID:
A10443
CMH Revision No:
5.0
N/A - Controlled document used across the
Service :
Last Review Date :
2/02/2021
organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
If you are not reading this document directly from the Document Directory this may not be the most current version.
Page 11 of 12
Policy: Gifts, Donations and Sponsorship
VAUGHAN
OIA13042021
Document ID:
A10443
CMH Revision No:
5.0
N/A - Controlled document used across the
Service :
Last Review Date :
2/02/2021
organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
If you are not reading this document directly from the Document Directory this may not be the most current version.
Page 12 of 12
Policy: Gifts, Donations and Sponsorship
Appendix 1 – Template Gifts and Hospitality Register
GIFTS REGISTER for recording gifts, donations over the value of $50 and hospitality over
the value of $100 for………………………………service/department
Gift declared by
Description of
Donor
Approx
Accepted
Date declared
Gift, Hospitality
value
/declined
or Benefit
VAUGHAN
OIA13042021
Document ID:
A10443
CMH Revision No:
5.0
N/A - Controlled document used across the
Service :
Last Review Date :
2/02/2021
organisation
Document Owner:
Chief Executive Officer (CEO)
Next Review Date:
2/02/2024
Approved by:
Executive Leadership Team (ELT)
Date First Issued:
30/05/2004
If you are not reading this document directly from the Document Directory this may not be the most current version.
Document Outline
