Conflict of Interest Policy
The LMC prides itself on its openness, transparency and strong governance; we have a responsibility to maintain the highest standards and this policy aims to deal with an area which can lead to accusation of unprofessional behaviour by allowing actual or perceived potential conflicts of interest to influence advice given by the LMC. The policy should be viewed as protecting individuals against the perception that they have un-declared interests or are acting for personal gain, by having the additional benefit of making different areas of expertise known to other members.
The LMC represents the views of the Northumberland GPs to the wider NHS, other public bodies, the media and the public.
We try to make known your concerns and opinions nationally through the General Practitioner Committee (GPC). We also develop policies on matters concerning general practice that enable GPs in the county to act together. We can assist in pastoral type of work such as advising and supporting
i) LMC Members attend meetings as representatives of their constituents
- The default position is accepted that at LMC meetings, a rep is speaking in their capacity as a LMC rep unless specifically requested by the committee to speak in another capacity or he or she specifically states that he or she is speaking in a different capacity (in such a circumstance, it is incumbent upon the rep to say in which capacity they are speaking).
- The default position is accepted that at LMC meetings, a rep is voting in their capacity as a LMC rep. If the potential conflict is significant, in the view of the chair, then the LMC rep will be asked to abstain from voting
ii) The LMC will keep a register of members’ interests
- Reps will be responsible for ensuring that their entry on the register is kept up to date by notifying the secretariat of any changes as soon as possible and not longer than within four weeks of the change occurring
- Reps will also be responsible for declaring interests of first degree relatives (parents, siblings and children) if there is any chance that an actual or perceived conflict of interest might exist
- The register shall be available on the LMC website but will not be actively disseminated outside the LMC
- Reps will be required to update their declaration of interests on a regular basis
- A copy of the register will be distributed by email to all reps once a year after it has been updated
- Reps will not be allowed to speak or vote at committee meetings until their declaration of interests has been received by the secretariat
iii) There shall be a standing item at the beginning of each meeting which asks members to declare any conflict of interest not already covered by the register pertaining to the agenda for that meeting
Should a member declare a conflict of interest the chair will decide whether that member should participate in the debate, remain silent or withdraw completely
iv) The LMC promotes a culture whereby potential conflicts of interest can be explored with individual members by the Chair, Secretary or other members without offence
Appendix A – Categories of information that should be declared
The categories of information which members should consider declaring as potential conflicts of interest are as follows:
- Directorships: Both paid and unpaid directorships of public or private companies, including Medical Directorships of public or private organisations.
- CCG positions: including Chair, Vice-Chair, board and executive management positions; locality Chair or locality board position; advisor; joint co-commissioning committees or primary care co-commissioning committees or equivalent.
- Other remunerated work: Any paid employment or other sources of income outside their normal medical work. Examples might be paid consultancy or advisory positions with government departments, pharmaceutical companies or the medical press, articles sold to the paramedical press or remunerated speaking engagements. Also included should be work for companies active in other health care fields or NHS trusts.
- Gifts, benefits and hospitality: This includes any substantial gift or material advantage received by a member which in any way relates to his/her membership of the LMC. This would include trips or visits arising out of membership of the LMC, where the costs has not been wholly borne by the member of LMC. Gifts of less than £500 in value and other benefits of less than £500 in value would be exempt as would events to which all members of the LMC are invited.
- Shareholdings: Declaration of the name of any public or private company, active (holds or has the potential to hold a relevant contract) in the field of healthcare, in which the member holds significant shareholdings. Significant is defined as either (a) greater than 1% of the issued share capital of the company or body, or (b) less than 1% of the issued share capital but more than £25,000.
- Family Interests: These would include financial and other interests of close family members that might be considered relevant to an individual’s position as a member of the LMC.
- Miscellaneous and unremunerated interests: This includes other interests which do not fall clearly within any of the above categories, for example, an active role within a political party. Membership of, or work for, other bodies such as charities or This includes other interests which do not fall clearly within any of the above categories, for example, an active role within a political party. Membership of, or work for, other bodies such as charities or trusts which could possibly influence a member’s position with regard to his/her LMC activities should also be included, as well as membership of Government or Department of Health committees/working groups on which the member is not a designated LMC representative.
- Administrative arrangements: The administrative arrangements for the establishment and maintenance of the register of interests are as follows:
- On a regular basis, members will be asked to register their interest on a proforma reflecting the above categories.
- The secretariat will hold the information submitted. It will be made available on request for inspection by any member.
- Information held in the register will not be processed in any way or disseminated outside the process outline above. At the end of each session, the register will be closed and access only granted to it in any case of dispute arising over the conduct of business relevant to the session which a conflict of interest may have occurred. This later access procedure will be subject to the decision of the LMC Officers, if appropriate.