Conflict of Interest Policy.pdf

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STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Overview

This Document
This document outlines the policy to ensure decisions made by our
District Health Board are not influenced by the personal interests of
its employees. The District Health Board acknowledges that
conflicts do exist from time to time; with openness and transparency,
these can be managed positively.

Topic
See Page
Overview ..................................................................................... 1
Introduction ................................................................................. 2
Policy Statements ........................................................................ 4
Conflict of Interest ...................................................................... 5
Disclosure & Documentation ...................................................... 9
Options & Appeals .................................................................... 11
Appendix 1: Conflict of Interest Examples and Recommended
Actions ...................................................................................... 12

Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by: Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
Page:
1 of 16

Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Introduction

Purpose
Our District Health Board is committed to providing a fair, ethical
and accountable environment for the conduct of health system
operations.  All employees are expected to perform duties in a fair
and unbiased way and not to make decisions which are affected by
private interests or personal gain.  The integrity and fairness of the
decisions and actions taken by employees could be undermined if,
when performing their duties, a conflict between the District Health
Board and private interests exists or appear to exist.

To protect the integrity of the District Health Board and its
employees, conflicts of interest need to be properly managed.
Employees have an on-going obligation to disclose any conflict of
interest.

Conflicts of interest must be as transparent as possible.  The
generally accepted view is that where conflict between the
organisation’s duty, requirements and private interest exists, matters
must be resolved in the organisation’s interest.

Scope
This policy applies to all District Health Board employees.  It
includes commercial transactions and recruitment of employees, any
person seconded or contracted to the Auckland DHB and students
training in DHB premises, as well as clinical research and related
activities such as funding and research grants.

Employees must disclose all interests, regardless of whether they
consider they may or may be in conflict with Auckland DHB.

The procedures by which Board members and members of
committees identify, declare and manage conflicts of interest are set
out in:
  The Auckland DHB Governance Manual
  Part 2 of the Crown Entities Act 2004
  Schedule 3 of the New Zealand Public Health and Disability Act
2000

Continued on next page
Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
Page:
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Introduction, Continued

Associated
The table below indicates other documents associated with this
Documents
policy.

Type
Document Titles
NZ Legislation
•  Crown Entities Act 2004
•  NZ Public Health and Disability Act 2000
•  Employment Relations Act 2000
Board Policies
•  Conduct - Standards
•  Discipline & Dismissal
•  Sponsorship, Donations, Gifts and Corporate
Hospitality Policy
•  Delegated Authority Policy
Other
•  Auckland DHB Governance Manual
•  Staff Interests Register
•  Managing Conflicts of Interest – Good
Practice Guide (2007) – Office of the
Auditor-General
•  PBE IPSAS 20 Related Parties Accounting
Standard
•  Conflict of Interest Guidelines for DHBs –
Ministry of Health

Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
Page:
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Policy Statements

Policy Statements
Where an employee or their related party has an interest (or potential
interest) in a transaction – financial, professional or personal –or
could be influenced or perceived as being influenced by a personal or
private influence which may potentially conflict with their
obligations to the District Health Board, they must declare that
interest to the appropriate Manager or Clinical Head.

Where an employee or their related party has a (potential) conflict of
interest, this must be discussed with the appropriate Manager/
Clinical Head, and they are to decide whether any change to the
employee’s activities is required to mitigate any conflict.

Employees have an on-going obligation to disclose actual, potential
or perceived conflicts of interest. They should err on the side of
caution; if they are unsure whether they have a conflict of interest in
a particular situation they should discuss the matter with their
manager or professional lead.

Where an employee or their related party has a conflict of interest
and has knowingly withheld this information, and/or acted to their
own advantage, the employee may be subject to disciplinary action
up to and including dismissal.

Conflicts of interest must be either eliminated or managed in the best
interest of the DHB.

Key Words
Key words to be recorded for Intranet search functions related to this
topic are as follows:
  Transaction
  Interest in a transaction
  Conflict of Interest
  Related party
  Gifts
  Sponsorship
  Donation
  Corporate Hospitality

Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
Page:
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Conflict of Interest

The Meaning of
Conflict of interest exists when it is likely that an employee
Conflict of Interest
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 District Health Board.
  Transaction means:
•  The exercise or performance of a function, duty, or power of
the District Health Board; or
•  An arrangement, agreement, or contract to which the DHB
is a party; or
•  A proposal that the District Health Board enter into an
arrangement, agreement, or contract.
The functions the relevant individual performs, and delegated
authorities that employee holds at the District Health Board, will
need to be considered to determine how a conflict of interest may
arise.
A personal or private interest are those interests that can bring
benefit or disadvantage to an employee as an individual, or to
others whom the employee may wish to benefit or disadvantage.
  Related party means:
•  A friend
•  A relative or close member of the family
•  An associate
  Close members of the family of an individual are those family
members who may be expected to influence, or be influenced by,
that person in their dealings with the entity and include:
a)  That persons children and spouse or domestic partner
b)  Children of that persons spouse or domestic partner; and
c)  Dependants of that person or that persons spouse or domestic
partner

An Interest in a transaction that can lead to a conflict of interest
may exist where an employee:
•  Will derive financial benefit from the transaction
•  Has financial interest in another party to a transaction

Continued on next page
Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Conflict of Interest, Continued

The Meaning of
•  Is a director, officer or trustee of another party to the
Conflict of Interest
transaction, or is a person who will or may derive a material
continued
financial benefit from the transaction
•  Has an interest in another party tendering for work which the
District Health Board is contesting
•  Is a shareholder of another party to the transaction
•  Is the parent, child, or spouse of another party to the transaction,
or a person who will or may derive a financial benefit from the
transaction.

Examples of interests employees should consider are:
•  Shares they own
•  Their having made or received a donation or gift
•  Their being an adviser, employee, trustee or director of another
business or organisation
•  Their being a member of a professional body
•  Their family affiliations
•  Any business proposals they are developing

See Appendix 1 for a list of situations where conflicts of interest may
potentially occur. Be aware that these are examples only and that the
list is not exhaustive.

Perceived and
Conflicts of interest can be actual, perceived or potential.
Potential Conflicts

of Interest
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.

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.

Continued on next page
Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Conflict of Interest, Continued

Competing
Conflicts of interest can also arise where an individual has official
Interests or
roles in more than one public organisation. In these situations, it may
Conflict of Duties
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.

Deciding if a
Employees should ask themselves the following questions to help
Conflict of Interest  decide if a conflict of interest exists or could be perceived by any
Exists
person to exist:
•  Do I, a relative, friend or associate stand to gain/loss financially
from the District Health Boards decision or action on this
matter?
•  Do I, a relative, friend or associate stand to gain/loss in any way
from the District Health Board 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 District Health Boards
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
District Health Boards consideration of the matter?
•  Could there be benefits for me in the future that could cast
doubt on my objectivity?
•  •  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?

Continued on next page
Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Conflict of Interest, Continued

Deciding if a
•  Would a fair and reasonable person perceive that I was
Conflict of Interest
influenced by personal interest in performing my public duty?
Exists
•  Do I need to seek advice or discuss the matter with an objective
continued
party?
•  Am I confident of 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?
•  Might I be perceived as favouring a particular person or firm
because of a longstanding 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?
•  When I am making a presentation or recommendation to the
Board or other decision making group, are they aware of my
interests (including private practice commitments) which might
be perceived as influencing the advice I am giving?

Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
Page:
8 of 16

Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Disclosure and Documentation

Disclosure of
After determining that a conflict of interest may exist in a particular
Conflict of Interest  situation, the individual employee must disclose any actual or
potential interest they have (whether pecuniary or non-pecuniary).
Disclosures should be made at the earliest opportunity on the
declaration of interests form and documented in the interests register.

The employee should disclose to their manager and/or 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.
A disclosure should provide relevant information such that
management can make an informed decision about how best to
manage the actual or potential conflict of interest.

Specific information disclosed must include:
•  The position at issue (the role) and its functions and duties
specifically in relation to the transaction
•  The potential value (direct and indirect) of the transaction
•  The way in which the interest or conflict will or may impact on
the performance of the employees role
•  An explanation of any personal benefit – perceived, actual or
potential, direct or indirect, financial or otherwise – resulting
from the transaction
•  Possible future involvements and benefits

Disclosures should be made verbally and in writing. An employee
who has a conflict of interest must ensure that the interest is reported
to the Corporate Business Manager for recording in the Staff
Interests Register.

If an employee, their manager or professional lead is uncertain
whether a particular situation constitutes a conflict of interest they
should err on the side of caution and arrange for the interest to be
declared and recorded in the interests register. If further advice is
needed on whether or not the particular situation constitutes a
conflict of interest, the matter can be referred to the Corporate
Business Manager for guidance.

Continued on next page
Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Disclosure and Documentation, Continued

Documentation
Employees are to complete the Declaration of Interests form
and provide it to their manager who will manage the potential
conflict of interest. The manager will provide the form to the
Corporate Business Manager for recording in the Staff
Interests Register.

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.

Interests Register
An Interests Register is to be maintained by the Corporate Business
Manager to record all interests (actual or potential).

The Register is 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 and how the conflict of interest will
be managed/mitigated.

Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Options & Appeals

Options for Dealing  Generally, if a pecuniary interest is disclosed, the individual with the
with a Conflict of
interest must not be involved in consideration or discussion of the
Interest
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, 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 minimise the actual or perceived influence or involvement of
the person with the actual or reasonably perceived conflict.

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
•  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 disagree with respect to any
Conflict of Interest issue, an appeal may be made for a review to the
Chief Human Resources Officer, or the Chief Medical Officer, or
through other options available to the employee.

Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
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.
  Purchasing of Goods and Services or Letting of Contracts
Situation
Recommended Action
Accepting gifts or benefits from
Refer to your policy on Sponsorship,
suppliers, or other individuals, involved in
Donations, Gifts and Corporate Hospitality.
the provision of goods and/or services could
Best practice is to accept the gift on behalf of
present a conflict of interest or obligation
the unit for which you work. , Report that
and be perceived as encouraging or obliging
you received the gift to your manager to
the employee to favour that supplier.  Gifts
record the details appropriately.  Complete
and benefits can take many forms e.g.
the Sponsorship, Donations, Gifts and
Lucky door prizes, raffles, travel, meals.  It
Corporate Hospitality Declaration form.
also includes opportunities to attend
Note that there are limits placed on the value
educational conferences or meetings and
of gifts that can be received.
attendance at or participation in sports
Relevant register: Gifts Register
events.
Selection of Tenders/Appointment of
Where there is a private interest with any
contractors: Preferring tenderers or
Tenderer or contractor, the employee must
prospective contractors with whom there is a  declare their conflict of interest and
private relationship
withdraw from the selection process.

Relevant register: Staff Interests Register
Recruitment
Situation
Recommended Action
Sitting as a member on selection panels
Declare the interest and withdraw from any
where applicants for the position are
part of the recruitment process is the
known to the member personally, as
preferred option; however in some situations
family, friend or close associate, to an
it may be necessary to include the person
extent that could be considered to be a
with the conflict on the panel (for example
conflict of interest.
in cases where they have specific expertise
that is required).  In these cases it may be an
option to include an independent person in
the recruitment process.
Relevant register: Staff Interests Register

Continued on next page
Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
Page:
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Appendix 1: Conflict of Interest Examples and
Recommended Actions, Continued

Situation
Recommended Action
Being in a position to influence the
Declare the interest.  Other choices as noted
selection, or non-selection, of an applicant
above.
for a position where the applicant is known
Relevant register: Staff Interests Register
personally and 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
fairly and any relationships that could be
whom control is exercised.
perceived to be of possible concern should be
brought to the attention of the appropriate
senior employee. If it appears that employees
are being given preferential treatment, these
concerns should be addressed through the
disciplinary process.
Relevant register: Staff Interests Register

Presentations to the Board or Other Decision Makers
Situation
Recommended Action
Making a written or oral presentation
At the start of the presentation the presented is
to the Board (or to another Auckland
expected to explicitly declare their private
DHB decision making body) about
practice involvement. The Board or other
equipment, facilities or services when
decision making body then as an opportunity
the presenter has, or is contemplating,
to ask questions about this interest.
private sector involvement in a similar

service.
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.
Relevant register: Staff Interests Register

Continued on next page
Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Appendix 1: Conflict of Interest Examples and
Recommended Actions, Continued

Improper Actions
Promoting friends or relatives where other employees are more
deserving.

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.

Allocation of overtime regularly 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:
•
Training courses
•
Attending conferences
•
Job or advancement opportunities

Recommending incremental progression, or non-progression, of
particular employees 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.

Continued on next page
Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by: Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Appendix 1: Conflict of Interest Examples and
Recommended Actions, Continued

Client/Patient Relationship
Situation
Recommended Action
Providing information or making
Staff are not to give preferential treatment to
recommendations to client/patient regarding
personal associates at the expense of others.
service providers where one of the service
(Wherever practicable, staff are not to
providers is a close friend/relative, etc.
recommend any one service provider or firm.
Providing information or making
They should provide “lists” of available
recommendations to patients by
service providers/firms.)  If a staff member is
recommending yourself in a private capacity.  found to have received a financial return for
recommending one service provider, or firm,
or oneself, disciplinary action taken may
include dismissal.
Relevant register: Staff Interests Register

Membership of Associations or Clubs, Professional Organisations, Political Parties
Situation
Recommended Action
Being involved in decision-making processes  Declare the interest and allow management
of the District Health Board or a professional  to determine the extent of involvement. If an
body, association, etc. that could have an
employee is found to have made or
effect on the method of operation of the
influenced a decision to the District Health
District Health Board or that association,
Board’s detriment, then that employee could
club, professional organisation, etc. that the
be subject to disciplinary action and possible
employee is a member of, or has an interest
dismissal depending on the circumstances.
in.
Relevant register: Staff Interests Register

Clinicians and Other Health Professionals
Health professionals encounter a variety of circumstances in their day-to-day work which
could give rise to potential conflicts of interest.
Situation
Recommended Action
Establishing a relationship with a
Declare any potential conflict of interest to
pharmaceutical company or medical
the Chief Executive Officer (CE) or
equipment supplier where it could be
authorised delegate(s) e.g.  Your manager
perceived that preference was given to that
Relevant register: Staff Interests Register
particular company during procurement/
tendering process.

Continued on next page
Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
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Auckland District
STAFF
Board Policy
Health Board
(Section 6)
Manual
CONFLICT OF INTEREST
Appendix 1: Conflict of Interest Examples and
Recommended Actions, Continued

Situation
Recommended Action
Accepting travel and accommodation fees
Obtain approval from CE or authorised
to present research findings.
delegate(s) for accepting travel and
accommodation fees and releasing of
possible confidential information.
Relevant register: Gifts Register
Accepting payment of fees and/or
If a fee-for-service is received and the
honorariums for sitting on committees
service is provided during working hours,
then the income must be declared and
provided to the organisation.  (Also refer to
Secondary/Additional Employment Policy)
Relevant register: Gifts Register
Participating on professional boards,
Obtain approval from CE or authorised
committees, societies, etc. Which could
delegate(s) to participate in external
constitute a conflict of interest with position
boards, etc. where there is any or could be
held in health organisation.
a perception of a conflict with the duties or
functions performed in the health
organisation.
Relevant register: Staff Interests Register
Having directorships and share holdings in  Declare the interest to the CE or authorised
private companies, associations, etc.
delegate(s) who would then decide whether a
which deal with the health organisation.
conflict of interest existed and possibly
restrict the person’s involvement in the
District Health Board s processes or request
resignation from external involvement.
Relevant register: Staff Interests Register
Evaluating new products / drugs where
Declare any potential conflict of interest to
decisions may be influenced by personal
the CE or authorised delegate(s).
associations/offers of samples or equipment,
Relevant register: Staff Interests Register
whether to the individual or the organisation
Evaluating new products / techniques
This must be approved by the Clinical
devices developed by employees also
Review Board and the Research Review
involved in clinical trials of same; or when a
Committee, who will decide on how to
company licensed to use an employee’s
manage the conflict and legal
invention is sponsoring trial to be undertaken  responsibilities.
with the District Health Board
Relevant register: Staff Interests Register

Section:
Staff
Issued by:
Chief Human Resources Officer
File:
Conflict-of-Interest_2017-02-18.docx
Authorised by:  Chief Executive & Endorsed by The Board
Classification:
PP01/STF/003
Date Issued:
Updated February 2017
Conflict of Interest
Page:
16 of 16