Corporate publication

Conflicts of Interest Policy

Guidance on how to recognise and manage perceived and real conflicts of interest.

31 March 2024

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Purpose of this policy

This policy provides guidance on how to recognise and manage perceived and real conflicts of interest. Trustees have a legal obligation to act in the best interests of the charity, and in accordance with the NHS Confederation’s Articles of Association, to avoid situations where there may be a potential conflict of interest. Staff and volunteers have similar obligations.

Conflicts of interests may arise where an individual’s personal or family interests and/or loyalties conflict with those of the charity. Such conflicts may create problems; they can:

  • inhibit free discussion
  • result in decisions or actions that are not in the interests of the charity
  • risk the impression that the NHS Cofederation has acted improperly.

The aim of this policy is to protect both the organisation and the individuals involved from any appearance of impropriety.


This policy applies to everyone working at or with the NHS Confederation.

It applies to:

  • all staff, including chief executives, directors, senior managers, employees (whether permanent, fixed-term or temporary), seconded staff, homeworkers, agency workers and volunteers
  • consultants and contractors
  • trustees, independent committee members and non-executive directors

Any employing or contracting manager must ensure that all temporary staff, consultants, or contractors are aware of this policy.

By the NHS Confederation, we mean the NHS Confederation charity, any subsidiary companies and any hosted networked organisation.

The NHS Confederation has designated the Director of People & Governance as the individual who is responsible for ensuring that the NHS Confederation implements this policy.

This policy should be read in conjunction with the organisation’s Scheme of Delegation, Anti-Bribery policy, Anti-Fraud policy, Whistleblowing policy, Gifts and Hospitality policy and Trustee Remuneration policy.

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