SUBJECT / Standards of Business Conduct
PRESENTED BY / Diane Collier, Head of Corporate Affairs
SUBMITTED TO / Governing Body, 16th April 2013
PURPOSE OF PAPER / The Governing Body is asked to note formally at this first meeting in public that the Group, during the transition period from 1st April 2012 – 31st March 2013 has:
  • ApprovedNHS North Norfolk CCG’s Standards of Business Conduct policy, which is available at
  • Noted formally that Member Representatives, Governing Body members and CCG staff have declared relevant potential conflicts of interest;
  • Approvedthe adoptionof the NHS Commissioning Board Authority’s Code of Conduct concerning CCG-commissioned services where GP practices are potential providers;
  • Approved use of the template for managing conflicts of interest when commissioning services from GP practices / organisations in which GPs have a financial interest (Appendix 1 of the Standards of Business Conduct policy); and
  • Approvedthe publication of contract details.
The Governing Body is also asked to:
  • receive formally at this first meeting in public the Register of Interests

EXECUTIVE SUMMARY
1Standards of Conduct / Managing Conflicts of Interest: General
Compliance with the national Code of Conduct and Code of Accountability in the NHS (revised 2004) is integral to the work of NHS North Norfolk Clinical Commissioning Group. These Codes form the core framework for the conduct of business in our organisation and apply to all Members of the Council, the Governing Body and employees of North Norfolk Clinical Commissioning Group.
There are three crucial public service values that underpin the work of the health service:
  • accountability – everything done by those who work in the NHS must be able to stand the test of parliamentary scrutiny, public judgements on propriety and professional codes of conduct;
  • probity – there should be an absolute standard of honesty in dealing with the assets of the NHS: integrity should be the hallmark of all personal conduct in decisions affecting patients, staff, and suppliers, and in the use of information acquired in the course of NHS duties;
  • openness – there should be sufficient transparency about NHS activities to promote confidence between NHS North Norfolk Clinical Commissioning Group and its staff, and patients and the public.
Member Representatives, Governing Body members and CCG staff have all signed a commitment to apply the principles of the NHS Codes of Conduct and Accountability; the Nolan Principles on standards in public life; and (where applicable) the Code of Conduct for NHS Managers and staff in all aspects of business. In addition, all parties have declared relevant potential conflicts of interest, which are set out in the Register below and which will be recorded in the minutes of today’s meeting.
In response to audit recommendations, the adoption of the Codes of Conduct and Accountability by Members of the Council, the Governing Body, and employees will be affirmed formally annually.
2 Managing Conflicts of Interest: Commissioning Services from GP Practices
It is an essential feature of reforms that CCGs should be able to commission a range of community-based services, including primary care services, to improve quality and outcomes for patients. The Standards of Business Conduct policy,at paragraph 8,takes account of guidance from the NHS Commissioning Board Authority (NCH CBA) concerning CCG-commissioned services where GP practices are potential providers and NHS North Norfolk CCG has adopted the specific, additional safeguards set out in the NHS Commissioning Board Authority’s Code of Conduct in this regard in order to demonstrate that those services:
  • clearly meet local health needs and have been planned appropriately;
  • go beyond the scope of the GP contract; and that
  • the appropriate procurement approach is used.
The Council of Members has notedand agreed that:
  • such services will be commissioned using the standard NHS contract rather than the GP contract;
  • NHS North Norfolk CCG will use the procurement template at Appendix 1 of the Standards of Business Conduct policyroutinely as part of the planning and commissioning process and will make completed templates publicly available; and that the
  • details of all such contracts, including their value, will be published on NHS North Norfolk CCG’s website. Where services are commissioned through Any Qualified Provider (AQP) arrangements, information will also be made publicly available about those providers who qualify to provide such services.

Register of Interests, April 2013

The list of practices with which GP Representatives of the Council of Members is associated is set out overleaf

NameInterest Declared

Rachel ArkiesonPartner, Drayton and St Faiths Medical Practice;

Practice in receipt of research funding from the Primary Care Research Network

Rebecca ChampionBrother is Chief Executive of Life Science Investment Organisation, a government funded body, which is part of UK Trade and Investment (UKTI)

Dr Deborah ClarkPart-ownership, Kelling Pharmacy;

Partner of Dr Peter Brueggemann, provider of minor surgery through Choose and Book

Practice is a Level 3 Member of the NHS Research Initiative Scheme

Dr Anoop DhesiPractice is a Level 3 Member of the NHS Research Initiative Scheme;

Member, Norfolk and Waveney LMC

Dr James GairPart-ownership, Birchwood Pharmacy Ltd

Dr John Harris-HallDirector, Mundesley Medical Services Ltd;

Shareholder, NHS Ltd

Practice is a Level 3 Member of the NHS Research Initiative Scheme;

Shareholder, North Norfolk Healthcare CIC;

Dr Manhar JoshiDirector / Shareholder, FMP (Norfolk) Ltd (Fakenham Pharmacy)

Dr Jane KeidanIndependent advisor to Queen Elizabeth NHS Trust, King’s Lynn during transition of pathology services

Dr Jenny LatoyPractice is a Level 2 Member of the NHS Research Initiative Scheme;

Dr Peter LawsonDirector, Norfolk Health Solutions Ltd;

Director, North Norfolk Healthcare CIC;

Practice is a Level 3 Member of the NHS Research Initiative Scheme;

Member, Norfolk and Waveney LMC

Ellis LaywardVolunteer, Norfolk Coalition of Disabled People

Dr Alan LeeDirector, Drayton Pharmacy

Director, North Norfolk Healthcare CIC;

Shareholder, Norfolk Health Solutions Ltd

Dr Alasdair LennoxDirector, Apris Medical Services Ltd

Dr Gordon McAnshMember of the Management Committee,

Wells Community Hospital Trust;

In receipt of research funding from:

- Primary Care Research Network;

- Bayer Pharmaceuticals (aspirin trial); and

- Servier UK (procoralan trial)

David McNeilOwnership, DGM Consulting (provides Corporate Affairs and Communications expertise to NHS Trusts);

Ownership, Potentia (Coaching and Leadership Development);

Trustee, Peace Hospice, Hertfordshire;

Chair, Remuneration Committee, Watford Borough Council;

Parish Councillor, Foulsham;

Support to Monitor as Director of Corporate Services and Company Secretary, Sherwood Hospitals NHS Trust (short-term contract to Spring 2013)

Dr Chris MalpasShareholder, Norfolk Health Solutions Ltd;

Employee, NNUH NHS Foundation Trust

Dr Hugh O’NeillDirector, Unity Medical Services Ltd

Sally Ross-BenhamPracticeManager, Staithe Surgery, Stalham;

Practice is a Level 3 Member of the NHS Research Initiative Scheme;

Minor shareholder, NHS Ltd

eal;thcare COIC

All other members of the Council, Governing Body, Executive and CCG staff returned ‘nil’ Declarations

These Interests will be recorded in the minutes of today’s Governing Body meeting

TheRegister is available for inspection from the Head of Corporate Affairs and Interests will be further declared in NHS North Norfolk CCG’s Annual Report for the financial year ending 31st March 2014.

Practice Name / Member Representative
Acle Medical Partnership / Dr Mike Noble
Aldborough Surgery / Dr Philip Wood
The Market Surgery, Aylsham / Dr Peter Lawson
Birchwood Surgery / Dr James Gair
Blofield Surgery / Dr Mark Gaskin
Brundall Medical Centre / Dr Philip Harston
Coltishall Medical Practice / Dr Chris Malpas
Cromer Group Practice / Dr Alasdair Lennox
Drayton & St Faiths / Dr Alan Lee
Fakenham Medical Practice / Dr Manhar Joshi
Holt Medical Practice / Dr Deborah Clark
Horsford Medical Centre / Dr Hugh O’Neill
Hoveton & Wroxham / Dr Linda Hunter
Ludham Surgery / Dr Elizabeth Christie
Mundesley Medical Centre / Dr John Harris-Hall
Paston Surgery / Dr Jenny Latoy
The Surgery, Reepham / Dr Penelope Ayling
Sheringham Medical Practice / Dr Ian Smith
The Staithe Surgery / Dr Anoop Dhesi
Wells Health Centre / Dr Gordon McAnsh

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