How we manage conflicts of interest (COI)

Managing conflicts of interest

The NHS Frimley Integrated Board conflicts of interest policy ensures that we meet the revised NHS England Managing Conflicts of Interest Statutory Guidance published in June 2016.

This policy applies to all NHS Frimley employees, Board members and members of Committees, as well as NHS Frimley partners including primary care, secondary care, and local authority staff members.

The conflicts of interest policy enables NHS Frimley to demonstrate that it is acting fairly and transparently and in the best interest of our patients and local population. The policy aims to:

  • Safeguard clinically-led commissioning, whilst ensuring objective investment decisions.
  • Enable NHS Frimley to demonstrate that it is acting fairly and transparently and in the best interest of our patients and local population.
  • Uphold confidence and trust in the NHS.
  • Support NHS Frimley to understand when conflicts (whether actual or potential) may arise and how to manage them if they do.
  • Ensure that NHS Frimley operates within the legal framework.

Finally, it will uphold confidence and trust between patients and GPs, in recognition that individual commissioners want to behave ethically but may need support and training to understand when conflicts (whether actual, potential or perceived) may arise and how to manage them if they do.


All NHS Frimley members and employees are required to declare any relevant and material personal or business interests and any relevant and material personal or business interests of their spouse, civil partner, co-habitee, family member or close friend which may influence or may be perceived to influence their judgement.  

As a member of the public you will be able to view declarations of interest for key decision makers in line with NHS England guidance on openness and transparency by clicking here.

A full register of declarations of interests for our Board can be found here.

You can also view our register of Gifts, Hospitalities and Commercial Sponsorships by clicking here.

Register of procurement decisions

The Register of Procurement Decisions for NHS Frimley is being developed and will be published here when it becomes available.

A Register of Procurement Decisions for the ICB’s predecessor organisation - NHS Frimley Clinical Commissioning Group - can be viewed here.


NHS Frimley further maintains a Register of Breaches of the Conflicts of Interest Policy which sets out details of any breach, how it has been investigated and notification of the breach to NHS England. All breaches are reported to NHS Frimley's Audit Committee. Anonymised details of breaches are published for the purpose of learning and development.

Further information and advice - COI guardian

To further strengthen scrutiny and transparency of NHS Frimley's decision making processes, NHS Frimley has a Conflicts of Interest Guardian. The Conflicts of Interest Guardian is normally the Non-Executive Member who has qualifications, expertise or experience to enable them to lead on finance and audit matters. 

Further information and advice is available through NHS Frimley's Conflicts of Interest Guardian who:

  • Acts as a conduit for GP practice staff, members of the public and healthcare professionals who have any concerns with regards to conflicts of interest.
  • Is a safe point of contact for employees or workers of NHS Frimley to raise any concerns in relation to this policy.
  • Supports the rigorous application of conflict of interest principles and policies.
  • Provides independent advice and judgment where there is any doubt about how to apply conflicts of interest policies and principles in an individual situation.
  • Provides advice on minimising the risks of conflicts of interest.

The Non-Executive Member and Chair of the Audit Committee is the Conflicts of Interest Guardian.