Standards of business conduct policy

Version number: 5.4
First published: April 2013
Date updated: 23 July 2025
Next review date: 1 July 2026
Brief summary of changes since previous version: Minor amendments clarifying applicability and disclosure requirements for different staff groups.

1. Purpose

1.1 The highest standards of conduct and integrity are expected from Board members, NHS England’s employees and all those who work for and with us, in keeping with the NHS Constitution and Nolan Principles.

1.2 As a public body, NHS England must ensure the highest standards of rigour, value for money and propriety in the way that we deliver our objectives and support the wider NHS to improve patient outcomes.

1.3 This policy describes the standards and public service values which underpin our work and which all officers of NHS England must follow.

2. Scope

2.1 Without exception, all officers of NHS England are within scope of this policy.

2.2 ‘Officer’ means an employee or any other person holding a substantive or non-substantive appointment or office within NHS England, including in its hosted bodies such as commissioning support units*, clinical networks and clinical senates.

*Commissioning support units must adhere to their own processes and approvals for declaring interests, escalating breaches, and investigating non-compliance in line with this policy. This includes the use of equivalent platforms such as Electronic Staff Record (ESR) instead of CoreStream to manage declarations.

2.3 Substantive roles include permanent and fixed term NHS England employees, non-executive directors, those on fixed term contracts, interims, agency workers, contractors (working for NHS England under a contract for services), consultants, apprentices, graduates, paid interns, secondees (internal, external or interim), Graduate Management Training Scheme trainees, strategic clinical networks and clinical senates.

2.4 Non-substantive roles include bank and honorary contract holders who perform a function on behalf of NHS England but are not employed directly by it such as members of advisory groups, medical advisors, clinical educators (for example, in our Workforce, Training and Education team), volunteers, interns (unpaid), global health fellows (GHF) including fellows, patient representatives (patient and public voice partners), lay members or those employed for tax purposes (EFTP).

2.5 The policy’s applicability and disclosure requirements for different staff groups is outlined in appendix C.

2.6 Employees of organisations contracted to provide services to NHS England may also be subject to this policy where it is a condition of the associated contract.

2.7 Throughout this policy, reference is made to NHS England’s policies and management structures. Other organisations in scope of this policy are expected to apply it with reference to their respective corporate policy and governance structures.

2.8 As part of their role, some officers make decisions or exercise influence in how public money is used. In the context of this policy, decision making officers are those in the following categories:

1. Board members.
2. National and Regional Executive team members.
3. All executive and senior managers.
4. Officers at Agenda for Change band 8d and above and their equivalent, for example medical graded staff.
5. Officers who are involved in the procurement process or are ‘authorised signatories’, including their direct and indirect reports who enter into contracts of any value, including zero-value, on behalf of NHS England.
6. Members of advisory groups which support the commissioning, planning or delivery of taxpayer funded services.
7. Officers who have direct or delegated authority to influence decisions concerning the commissioning of services, purchasing of goods and formulary decisions. 

3. Failure to comply with this policy

3.1 Allegations of a failure to comply with this policy should, without exception, be explored in discussion with the individual by a responsible officer. In the first instance, in most cases, this will be the direct line manager of the subject of the allegation.

3.2 A failure by a responsible person to adequately investigate such allegations will in itself be a contravention of this policy.

3.3 Depending on the outcome of any investigation, failure to comply may result in disciplinary actions being considered, in accordance with the Disciplinary policy, up to and including termination of employment.

3.4 Where the failure to comply relates to an officer who is not a direct employee of NHS England, this may result in action being taken in accordance with the relevant engagement procedures (for example termination of a secondment agreement).

3.5 Any financial or other irregularities or impropriety which involve evidence or suspicion of fraud, bribery, or corruption by any officer will be reported to NHS England’s Counter Fraud team for an appropriate investigation to be conducted and potential prosecution sought.

4. Raising concerns and reporting potential breaches

4.1 Officers should speak up if they have concerns about compliance with this policy or any associated policy or procedure.

4.2 Officers should raise concerns with their line manager, the Corporate Governance team (compliance@nhs.net) or a Freedom to Speak Up Guardian.

4.3 All reported concerns will be treated with the appropriate confidentiality and investigated in line with applicable NHS England policies and procedures.

4.4 The Corporate Governance team takes a report on breaches and responses to the Audit and Risk Assurance Committee at least annually. Anonymised information on breaches is published annually on NHS England’s website.

4.5 Officers must report any suspicions of fraud, bribery, and corruption to NHS England’s Counter Fraud team as soon as they become aware of them: counter-fraud@nhs.net.

5. Publication of declarations

5..1 All decision-making officers’ declarations are published on NHS England’s website at intervals set out in appendix B. Registers of all declarations held by the Corporate Governance team will, where there is a legal basis for doing so, be made available on request.

5.2 In exceptional circumstances, where the public disclosure of information could give rise to a risk of harm or is prohibited by law, an individual’s name and/or other information may be redacted from the publicly available register(s), unless it is a directorship which is not deemed to be sensitive or confidential information as it is publicly available information on the Companies House website.

5.3 For the declaration of directorships (see section 4 of appendix A), the Corporate Governance team will publish those where the declarant is a decision-making officer and the organisation directly or indirectly provides services or products to the NHS or patients or might be reasonably expected to seek to do so.

5.4 Refer to appendix A, paragraph 1.11 regarding submitting a declaration that might be sensitive in nature.

6. Equality and health inequalities impact assessment

As part of the development of this policy, its impact on equality has been analysed and no detriment identified.

7. Key references

Appendix A 

Section 1 – Declarations of interest

Minimum requirements

  • All officers must declare any interests on CoreStream as soon as possible, and within 28 days after the interest arises.
  • Officers must review their status and submit a declaration at the points outlined in paragraph 1.10 below.
  • Consult your line manager if you are in any doubt as to whether you have an interest or whether it is declarable. You can also contact the Corporate Governance team (compliance@nhs.net).

1.1 Officers must always act with the utmost integrity and objectivity and in the best interests of the public, taxpayers, and the organisation in performing their duties. They must avoid situations which may give rise to an actual, potential, or perceived conflict of interest.

1.2 Officers must not use their position for personal advantage or seek to gain preferential treatment. Officers must declare any actual or potential interests which may be perceived as conflicting with this overriding obligation.

1.3 Officers may hold interests for which they cannot see a potential conflict; however, others may see the matter differently. It is important to exercise judgement, and you are encouraged to declare interests even where the likelihood of any actual or perceived conflict is low.

What are conflicts of interest?

1.4 A conflict of interest can occur when an officer’s judgement could be impaired by a clash between personal interests and professional duties or responsibilities.

1.5 Even if the individual doesn’t actually benefit, a conflict can still occur if it appears a decision may have been influenced. The perception of competing interests, impaired judgement or undue influence can also be a conflict of interest.

1.6 A material interest is one which a reasonable person would take into account when making a decision, because the interest is relevant to that decision.

1.7 A conflict of interest may be:

1. Actual – there is a relevant and material conflict now.
2. Potential – there is the possibility of a material conflict in the future.
3. Perceived – where others might reasonably question your impartiality.

1.8 Conflicts can also occur because of interests held by a close family member, business partner, close friend, or If officers are aware of material interests, these must also be declared. A close family member is defined as:

  • spouse or civil partner
  • any other person with whom the individual cohabits
  • children or stepchildren
  • spouse/partners’ children or stepchildren
  • parents
  • grandparents
  • siblings

1.9 Interests arise in a number of different contexts and can generally be considered in the following categories:

i. Financial interests – where an individual could potentially obtain a direct financial benefit from the consequences of a decision they are involved in making. Examples include:

  • a paid outside employment, including directorship or non-executive directorship, held in any private company, public limited company, charity, or professional body
  • a shareholder (or similar ownership interests), a partner or owner of any private or not-for-profit company, business, partnership, or consultancy
  • all shareholdings and ownership interests in any publicly listed, private, or not-for-profit company, business, partnership, or consultancy that is currently engaged, or could reasonably be anticipated to engage, in business with NHS England must be fully disclosed*
  • there is no need to declare shares or securities held in collective investment, pension funds or units of ​authorised unit trusts

*Refer to appendix C outlining the declaration and approval requirement for different role types (i.e. substantive and non-substantive roles)

ii. Non-financial professional interests – where an individual may be perceived as gaining a non-financial benefit, for example, to their professional reputation/status/career, from the consequences of a decision they are involved in making. Examples include:

  • holding a decision-making position or a position of influence in another NHS organisation (see appendix A, section 4 for restrictions), commercial, charity, voluntary, statutory, or other body in the health and care sector

  • a position on an advisory group or other paid or unpaid decision-making forum that could influence how NHS England spends taxpayers’ money
  • 
an advisor for the Care Quality Commission or the National Institute for Health and Care Excellence

iii. Non-financial personal interests – where an individual could be seen to benefit personally in ways that are not directly linked to their career and do not give rise to a direct financial benefit because of decisions they are involved in making. Examples include:

  • a position on an advisory group or voluntary sector organisation that could seek to influence how NHS England spends taxpayers’ money
  • a shareholder, director, owner or business partner of a lobby or pressure group with an interest in health and care

iv. Indirect interests – where an individual has a close association with an individual who has a financial interest, a professional interest, or a personal interest who would be viewed as standing to benefit from a decision the individual is involved in making. Examples include a spouse/partner, close family member or close friend/associate who:

  • holds a decision-making position or position of influence in another NHS organisation
  • is a shareholder, director, owner, or business partner which directly or indirectly provides services or products to the NHS or patients or might be reasonably expected to seek to do so

v. Loyalty interests – as part of their role, officers may build strong relationships with colleagues across the NHS and in other sectors. Officers should be mindful of any situation where relationships may give rise to a perception that a loyalty, credit, or responsibility is owed to another person or body, which could conflict with the interests of NHS England or their responsibilities as an officer. Examples include:

  • a recent (5 years or less) previous employment with an employer which directly or indirectly provides services or products to the NHS or patients or might be reasonably expected to seek to do so
  • line management, either directly or as part of a wider management function, of family members, relatives, close friends and associates, and business partners

What officers are required to do

1.10 Where there is potential for an interest to be material, it must be declared and recorded on CoreStream.

1.11 If an officer has any concerns regarding declaring a particular interest, or raising it with their line manager, for example due to the sensitive nature of the interest, they should contact the Corporate Governance team (compliance@nhs.net) for advice.

1.12 Where an interest is deemed sensitive by the Corporate Governance team, the individual will be advised how to complete the declaration on CoreStream, in a way that protects confidentiality, for example by routing the declaration to the Governance team instead of their line manager.

1.13 Declarations deemed sensitive will be retained for auditing and compliance purposes. A redacted version may be published, in accordance with section 5 (publication of declarations) of this policy.

1.14 The Corporate Governance team will review external sources of information such as Companies House to ensure that appropriate internal declarations have been made and will take appropriate action where they have not.

1.15 Officers must review their status and submit a declaration at the following points:

Board members and Executive team members (national and regional)

  • on appointment
  • in advance of every meeting of the Board and its committees
  • at the commencement of any formal meeting (see paragraph 1.19 below)
  • nil returns are required

Decision making officers and all other officers

  • on appointment
  • through an annual review
  • when moving to a new role or when responsibilities materially change
  • at the commencement of any formal meeting (see paragraph 1.19 below)
  • nil returns are required to be made by decision-making officers but not all other officers unless their roles have significant influence on key decisions or procurement activities

Patents, intellectual property, and other assets

1.16 A conflict of interest may also arise when an officer holds patents, intellectual property rights or commercial property. Officers should declare all such holdings (whether held individually, collectively or by virtue of their association with a commercial or other organisation) where any related goods or services might reasonably be expected to be procured or used by NHS England.

1.17 Any patents, designs, trademarks, or copyright resulting from the work (for example research) of an officer carried out as part of their employment shall be the intellectual property of NHS England.

1.18 If the undertaking of external work or gaining patent or copyright benefits enhances the reputation of NHS England or results in its financial gain, consideration will be given to rewarding officers subject to any relevant guidance for the management of intellectual property in the NHS issued by the Department of Health and Social Care.

Managing conflicts of interest – general

1.19 All declarations of interest must be reviewed by the officer’s line If the interest gives rise to a potential or actual conflict, the line manager must determine what action is required to mitigate the conflict, for example:

  • agreeing with the officer that the interest will be relinquished
  • putting in place separation of responsibilities and restricting the officer’s involvement in discussions
  • removing the officer from the whole decision-making process
  • removing the officer’s responsibility for an entire area of work
  • restricting access files, folders and/or commercially sensitive information
  • allocating activities more appropriately within teams to avoid conflicts
  • putting in place a non-disclosure agreement and/or ethical walls agreements to restrict the flow of information. For further information contact the Commercial Delivery and Governance team: commercialqueries@nhs.net
  • removing the officer from their role altogether if the conflict is so significant that they are unable to operate in that role

1.20 Line managers must maintain an audit trail of the actions agreed and taken in respect of individual conflicts and record this as notes in the relevant declaration records in CoreStream.

Managing interests at formal meetings

1.21 All formal meetings, including the Board and its committees, must have a standing agenda item at the beginning of each meeting to determine whether anyone has any conflict of interest to declare in relation to the business being transacted at the meeting. Any new interests declared at the meeting should be included in the relevant register of interest as soon as practicable after the meeting by the relevant officer and the meeting secretariat.

1.22 If the chair of the meeting has a conflict of interest, the deputy chair is responsible for deciding the appropriate course of action to manage it. If the deputy chair is also conflicted, then the remaining non-conflicted voting members of the meeting should unanimously agree how to manage the conflict(s).

1.23 If a member of the meeting (including the chair or deputy chair) has a conflict of interest in relation to 1 or more items of business to be transacted at the meeting, the chair (or deputy chair or remaining non-conflicted members as described above) must decide how to manage the conflict. The appropriate course of action will depend on the particular circumstances, but could include one or more of the following:

i) Where the chair has a conflict of interest, deciding that the deputy chair (or another non-conflicted member of the meeting if the deputy chair is also conflicted) should chair all or part of the meeting.
ii) Asking the individual who has a conflict of interest (including the chair or deputy chair if necessary) not to attend the meeting.
iii) Ensuring the individual does not receive the supporting papers or minutes of the meeting which relate to the matters which give rise to the conflict.
iv) Asking the individual to leave the discussion while the relevant matters are being discussed and when any decisions are being taken in relation to those matters.
v) Allowing the individual to participate in some or all of the discussion when the relevant matters are being discussed but asking them to leave the meeting when any decisions are being taken in relation to those matters.
vi) Noting the interest and ensuring that all attendees are aware of the nature and extent of the interest but allowing the individual to remain and participate in both the discussion and any decisions. This is only likely to be an appropriate course of action where it is decided that the declared interest is immaterial or not relevant to the matter(s) under discussion.

1.24 In all cases however, a quorum must be present for the discussion and decision; and interested parties cannot be counted in determining whether the meeting is quorate for that item.

1.25 All decisions relating to a conflict of interest must be recorded by the meeting secretariat and reported in the minutes of the meeting. The minutes will include:

i) who has the interest
ii) the nature and extent of the conflict
iii) an outline of the discussion
iv) the actions taken to manage the conflict
v) evidence that the conflict was managed as intended

1.26 To support chairs in their role, the secretariat will provide access to details of any conflicts which have already been made by members of the group.

1.27 When hosting a formal meeting whose membership includes people who are not officers of NHS England, it is good practice to ensure the interests of such attendees are captured and maintained as part of the formal meeting record.

1.28 Conflicts of interest arising at the NHS England Board meeting must be managed in accordance with the requirements of the NHS England standing orders.

Procurement

1.29 NHS England has a legal obligation to minimise conflicts of interest in relation to procurements and management of contracted delivery with third party suppliers. Conflicts of interest may arise where people acting on behalf of NHS England may influence, or be seen to potentially influence, commercial outcomes. Most commonly this would be seen during the preparation and evaluation of a procurement

1.30 Potential conflicts may also arise where suppliers, such as consultants or associates are deployed to act on behalf of, or advise, NHS England on delivery and development of: 

  • a specification for a procurement 
  • an investment business case for future procurements 
  • negotiation strategies
  • procurement pipelines
  • managing suppliers or contracts
  • leadership discussions, for example attending or being part of senior leadership meetings, where commercial matters may be routinely or specifically discussed.

1.31 Conflicts of interest need to be managed appropriately through the whole procurement process. At the outset of any procurement process, the relevant interests of individuals involved must be identified and clear arrangements put in place to mitigate any This includes consideration as to whether the individual should be involved in the process at all, or which stages of the process a conflicted individual should not participate in. Refer to paragraph 1.19 (managing conflict of interest – general) for more details.

1.32 Further guidance is in the Standing financial instructions and the Procurement policy.

Grants

1.33 Grants should be awarded and governed in accordance with NHS England’s powers under the NHS Act 2006 (amended) and Revenue grants policy and guidance. Labelling a payment as a grant payment should not be seen as a way of avoiding the procurement processes in the Standing financial instructions. The Subsidy Control Act applies to the awarding of grants, therefore the process to award a grant must be treated the same as any other procurement exercise and should comply with all appropriate requirements of Standing financial instructions. As with procurement in general, conflicts of interest need to be managed through the grant application process and must be declared on the grant application form.

Section 2 – Gifts and hospitality

Minimum requirements

All officers must submit a declaration on CoreStream as soon as they become aware of any offer of a gift or hospitality, and within 28 days after the interest arises.

2. All officers are encouraged to consider the risks of perceived bias or favouritism associated with accepting gifts and/or hospitality from suppliers, potential suppliers or contractors doing business (or likely to do business). Officers should ensure they are not placed in a position that risks compromising their role, the organisation’s reputation or its public and statutory duties, and the reputation of the wider NHS.

2.1 NHS England’s involvement in any commissioner/provider relationships or regulatory interactions introduces a unique conflict of interest and, therefore commissioner, regulatory and funding relationships are subject to the same conflict of interest requirements as traditional commercial supplier relationships.

2.2 The default position regarding hospitality from suppliers, potential suppliers, contractors, and parties with whom there are commissioning, regulatory, or funding relationships is not to accept such offers (however, modest refreshments, such as coffee, biscuits, or sandwiches, provided during work-related activities are acceptable).

2.3 The Bribery Act 2010 (the Act) makes it a criminal offence to give or offer a bribe, or to request, offer to receive or accept a bribe, and this applies to gifts and hospitality.

2.4 The Act reformed the criminal law of bribery and introduced a corporate offence which means that commercial organisations, including NHS bodies, will be exposed to criminal liability, punishable by an unlimited fine, for failing to prevent bribery.

Gifts in general

2.5 Under no circumstances can officers seek or accept:

a. gifts from suppliers, potential suppliers, contractors doing business (or likely to do business) and where we have commissioning, regulatory, and funding relationships (other than low-cost promotional items valued at under £6 in total)
b. a personal gift of cash or cash equivalents (for example, tokens, vouchers, gift cards, lottery tickets or betting slips) regardless of value or source
c. preferential rates or benefits in kind for private transactions carried out with companies with which they have had, or may have in future, official dealings on behalf of NHS England (this does not apply to concessionary agreements negotiated with companies by the NHS on behalf of all staff, for example, NHS staff benefits schemes) 

Gifts from patients, their families, service users and foreign dignitaries

2.6 It is never permissible to accept gifts of cash or cash equivalents.

2.7 A one-off gift of up to £50 in value may be accepted, if appropriate and with line manager approval, and it must be declared on CoreStream. Any further gifts must be declined for the course of that financial year.

2.8 For gifts with a value of over £50, you should do one of the following:

  • decline or return the gift
  • share the gift with all staff
  • raffle the gift for charity
  • donate the gift to charity

2.9 All gifts, whether accepted or declined, must be declared on CoreStream. If the gift was accepted, the rationale must also be recorded, along with line manager approval for accepting the gift.

2.10 Value gifts using the actual cost if known, or a reasonable estimate of their value.

Hospitality in general

2.11Hospitality is an offer made to officers of meals and refreshments, invitations to functions such as ceremonies, receptions, presentations, events, and conferences, including cultural events. Some offers may include overnight accommodation and travel to and from a venue at which an event is being held.

2.12 The default position regarding hospitality from suppliers, potential suppliers, contractors, and parties with whom there are commissioning, regulatory, or funding relationships is not to accept such offers (however, modest refreshments, such as coffee, biscuits, or sandwiches, provided during work-related activities are acceptable)

2.13 All hospitality must:

  • have a legitimate business reason
  • be proportionate to the nature and purpose of the event
  • be declared appropriately and approved where required

2.14 Under no circumstances can officers accept:

a. hospitality where it would appear to place them under any obligation and/or compromise their professional judgement and impartiality
b. the offer of tickets or an invitation to a sporting event, festival, or any other non-business-related event, unless representing NHS England in an official capacity and with the prior agreement of the relevant Executive team member. This includes third party funded events, such as paying for tickets to charity balls and award events or being given privileged access to booking tickets even when paying for them 

Permitted exceptions

There are permitted exceptions to the general rules on hospitality, such as attendance at training or educational events, or where participation is clearly in the interests of NHS England – for example, representing the organisation at a conference or official engagement. These exceptions must be proportionate, declared where required, and approved in advance where applicable. 

Meals and refreshments

2.15 Meals and refreshments under the value of £25 do not need to be reported. If in doubt, seek advice from your line manager or the Corporate Governance team: nhse.compliance@nhs.net.

2.16 Meals and refreshments with a value between £25 and £75 must be declared on CoreStream, indicating whether they have been accepted or declined.

2.17 Meals and refreshments over a value of £75 should not be accepted, unless in exceptional circumstances and with executive and senior manager approval (or the line manager in the case of the officer being an executive and senior manager themselves) and a clear reason recorded when declared as to why it was permissible to accept.

2.18 Value meals and refreshments using the actual amount if known, or a reasonable estimate of their value. 

Travel and accommodation

2.19 Offers from third parties to meet the cost of travel and accommodation must be declared on CoreStream whether accepted or declined.

2.20 Offers which go beyond the type/level which would be funded by NHS England must have Executive team member approval in advance.

2.21 The rationale should be recorded on CoreStream as to why it was permissible to accept travel and accommodation of these types.

Air Travel

2.22 Prior to being accepted, offers which include air and/or overseas travel must be approved by the Flight Approval Panel. This includes where the cost of travel, accommodation or entrance to an event is being met by a third-party organisation.

2.23 Examples which would not normally be funded by NHS England include, but are not limited to, offers of:

a. business or first-class travel, and accommodation which is above the standard set out in our business travel and expenses policy
b. domestic air travel
c. foreign travel and 

Gifts and hospitality provided by NHS England

2.24 Any proposal to offer a gift from NHS England requires the prior approval of the relevant Executive team member.

2.25 Hospitality for meetings/events/conferences must be limited to essential requirements only and must be approved as per the Event and venue booking policy. Any other hospitality should not be provided from NHS England funds.

Section 3 – sponsorship

3.1 This section covers offers to NHS England from a third party of any type of sponsorship, and where NHS England is considering sponsoring a third-party activity of any kind (regardless of whether there is an associated cost). 

Minimum requirements

  • All offers of sponsorship whether accepted or declined, including the value of the sponsorship, must be declared on CoreStream within 28 days of any decision.
  • A common-sense approach should be applied to valuing the sponsorship if there is not a contractual value specified, for example, a room and refreshments being provided for an event.
  • In exceptional circumstances where there are multiple sponsorship offers or arrangements, the sponsorship may be declared within 28 days of the event taking place provided this is agreed in advance by the Director of Corporate Governance (compliance@nhs.net). 

Sponsorship types

3.2 Educational sponsorship: where support is provided for training, learning, or professional development purposes. This may include funding for educational events, speaker fees, or learning materials, provided there is no promotional or commercial intent. Funding sources for educational purposes must be transparent and it must not constitute an inducement to commission any service.

3.3 Commercial sponsorship: where support is provided for an event or initiative such as conferences, meeting venues, exhibitions, or awareness campaigns, where branding visibility may benefit the sponsor. This may create an actual, potential, or perceived conflict, and typically carry a higher risk and therefore more scrutiny.

3.4 Third parties may offer to sponsor a programme, event, meeting, publication (or other type of content), training event/course or any other NHS England activity. Any request for, or offer of, sponsorship must first be directed to the Communications team: businesssupport.comms@nhs.net for consideration and cannot be committed to without written approval.

3.5 Sponsorship must not in any way compromise any of our decisions or be dependent on the purchase or supply of goods or services by NHS England. Sponsors should not have any influence over NHS England’s decision, content or activities associated with an event, meeting, seminar, publication (or other type of content) or training event/course. However, sponsors may be able to run a sponsored session at an event where they would be able to deliver their own content. Sessions which are sponsored must be clearly marked as such. Please contact the Communications team: businesssupport.comms@nhs.net before making any commitments.

3.36 Officers who are considering entering into an agreement regarding the external sponsorship of a post will require the prior approval in writing of the relevant Executive team member and other relevant bodies as appropriate and must consult with their human resources and organisational development business partner. 

Sponsorship by NHS England of a third party’s work of any type  

3.7 NHS England budgets should not be used to sponsor programmes, events, conferences, awards (individual, team or wider), publications or any other type of third-party activity.

3.8 Occasionally, and on a case-by-case basis, we may choose to sponsor an activity if there is no associated cost, but only if it meets NHS England’s objectives, protects and enhances our reputation and that of the wider NHS, and complies with NHS identity guidelines.

3.9 All sponsorship proposals, including where there is no associated cost, must first be directed to the Communications team: businesssupport.comms@nhs.net for consideration and cannot be committed to without their written approval.

Section 4 – outside employments, clinical private practice, and company directorships

Minimum requirements

All officers must declare on CoreStream any outside employment (including self-employment/freelance, directorships or consultancy work) or private practice on appointment, and when any new employment arises.

  • All external employment and directorships must be discussed with and receive prior approval from your line manager.
  • Any external employment or directorship that is connected to the NHS (directly or indirectly, including our suppliers or potential suppliers), its competitors, or any role which could reasonably be perceived as influencing your duties with NHS England, must be declared on CoreStream and approved by both human resources and organisational development and an executive senior manager in the colleague’s line management chain.
  • When in doubt, it is advisable to disclose the interest.
  • Officers must not accept a chair, non-executive or associate non-executive appointment in an NHS foundation trust or other NHS body, including any subsidiaries without first seeking approval (see paragraph 4.10).

Outside employment in general

4.1 All officers must first seek advice and approval from their line manager if they wish to engage in outside employment, including self-employment/freelance/consultancy work, or wish to retain existing outside employment when offered a position at NHS England. This approval should be sought even if the officer is yet to join NHS England or is temporarily absent, for example, through sickness, maternity leave, or secondment.

4.2 Any external employment or directorship that is connected to the NHS (directly or indirectly, including our suppliers or potential suppliers), its competitors, or any role which could reasonably be perceived as influencing your duties with NHS England, must be declared on CoreStream and approved by both human resources and organisational development and an executive and senior manager in the colleague’s line management chain. When in doubt, it is advisable to disclose the interest.

4.3 If additional employment or self-employment has been approved, staff must never carry out any related activities during their contractual hours at NHS England, including during periods of authorised sickness, or during paid statutory leave, such as during the ‘maternity paid period’. Also, the work cannot take precedent over an officer’s substantive post and the requirements of it, for example being part of on call rotas.

4.4 If an approving executive and senior manager is uncertain about the appropriateness of additional employment/self-employment or the potential for a conflict to arise, they must seek advice from the Corporate Governance team: compliance@nhs.net

4.5 Outside employment or private practice must neither conflict with nor be detrimental to the NHS work of the officer in question. Examples which may give rise to a conflict of interest include, but are not limited to:

1. Employment with another NHS body (see restrictions in paragraphs 4.10 to 4.12).
2. Employment with another organisation which might be in a position to supply or potentially supply goods/services to NHS England.
3. Self-employment, including private practice, in a capacity which might conflict with the officer’s NHS England work.

4.6 Where a risk of conflict of interest is identified, this should be managed in accordance with the guidance provided in appendix A, paragraph 1.19. NHS England reserves the right to refuse permission to undertake outside employment where it reasonably believes a conflict will arise or that approval would be detrimental to the work of the officer in question.

4.7 In undertaking any outside employment, officers should have regard to appendix A, paragraphs 6.30 and 6.31: trading on official NHS England premises.

4.8 NHS England may have legitimate reasons within employment law for knowing about outside employment of officers, even where this does not give rise to the risk of a conflict of interest. Nothing in this policy prevents such enquiries being made.

Chair and non-executive appointments in NHS trusts, foundation trusts and other NHS bodies

4.9 In accordance with regulation 11 of The National Health Service Trusts (Membership and Procedure) Regulations 1990, employees of NHS England are not permitted to hold a position of chair or non-executive director of an NHS trust at the same time as their NHS England role.

4.10 Chair, non-executive and associate non-executive appointments of NHS foundation trusts and other NHS/health service bodies* raise a similar potential for conflicts of interests to arise. Therefore, as a general rule NHS England employees, and specialist contractors (working for NHS England under a contract for services), will not be permitted to hold such roles. This includes subsidiaries of those bodies. If there are deemed to be exceptional reasons why holding such a role is in the overall best interests of NHS England, a case will need to be made to Executive HR Group and the NHS England Chair for approval, via the Corporate Governance team: compliance@nhs.net. This approval must be secured before any commitment to take on a role is made.

4.11 The approval process for different role categories is outlined in appendix C.

*Defined as the list of NHS employers set out in annex 1 of the NHS Terms and Conditions of Service Handbook (NHS Employers) and The National Health Service Trusts (Membership and Procedure) Regulations 1990.

Section 5 – political activities

5.1 Officers are free to be a member of a political party and/or undertake political activity outside of work hours. However, any political activity should not identify an individual as an officer of NHS England, and officers must not use or share any information or resources they have access to in their role for political purposes.

Conferences or functions run by a party-political organisation, or by a third party at a party-political conference or function, must not be attended in an NHS England capacity.

5.2 This does not preclude officers from undertaking civic duties such as being a councillor at a local authority. Officers must comply with the Special leave policy when undertaking such duties within their normal working hours. All officers must declare any engagement in civic duties on appointment, and when any new such role arises. Declarations should be made as outside employment on CoreStream.

5.3 All officers must take additional care during the period running up to any national or local election, known as the pre-election period, and must comply with any instruction issued in this regard. Information concerning pre-election obligations and policy is on the uk website.

Section 6 – personal conduct  

Corporate responsibility

6.1 All officers must reflect the corporate decision or view of NHS England in the discharge of their role, even if this conflicts with their personal views. Officers may comment on such matters as they wish as private individuals in non-work-related contexts, but if their view differs from NHS England, they should make it clear it is their personal view and not the organisation’s. This also applies if NHS England is yet to decide or otherwise express a view on an issue.

6.2 Although officers may have different points of view to their colleagues, these cannot be expressed in a way which discriminates, victimises, or harasses others. Any action which discriminates against someone because of who they are, including those with protected characteristics, should not be tolerated and will be dealt with. This covers all forms of discrimination, racism, and hate-related incidents, such as antisemitism, Islamophobia, homophobia and transphobia, and any behaviours that are perceived as harmful or threatening towards colleagues.

Use of public funds

6.3 All officers must at all times ensure they are securing the best possible use of funding provided to the NHS for the purpose of delivering its statutory duties and objectives. This applies both to the use of funds directly by the organisation and funds used by the wider NHS as a result of NHS England activities or decisions.

6.4 The use of commercial services for meetings and conferences should be avoided wherever possible. Where it is not possible to accommodate a meeting within NHS England’s estate, every effort should be made to secure a venue within the wider NHS or public sector estate, as set out in the Event and venue booking policy.

6.5 Officers should avoid travel and overnight accommodation wherever possible. As set out in the Business travel and expenses policy, where travel and/or accommodation is essential, efforts should be made to secure the lowest possible cost, including by using public transport and booking as far in advance as possible.

6.6 Attendance at conferences related to the NHS, including those where NHS England is involved, particularly where this incurs travel, accommodation, and/or entrance costs, must be limited to essential staff only. Officers should seek permission from their relevant Executive team member before committing to attend. NHS England funds should not be used to pay for any supplementary recreational events associated with conferences, such as dinners or drinks receptions.

6.7 Officers cannot use NHS England funding, directly or indirectly, for the recognition, reward or recreation of teams or individuals. This includes, but is not limited to, entry to awards programmes or attendance at awards ceremonies, team meals or other team activities, and paid promotional materials (other than agreed campaigns – contact the Communications team: businesssupport.comms@nhs.net)

Representing the organisation

6.8 Officers must not provide comment or briefing to the media on issues relating to their work, NHS England or the wider NHS, whether on an attributable basis or not, without having explicit approval from the Media team in advance. Any approach to officers from journalists must be referred to the Media team: media@nhs.net, either directly or via officers’ established NHS England communications contacts.

6.9 Officers (with the exception of our non-executive directors) must not commit to speak at third party (excepting other public bodies) conferences, forums, or similar events on behalf of NHS England without explicit approval from the Stakeholder Engagement and Public Affairs team. Where conditionality is attached to approval, or advice and guidance is provided related to it, this should be adhered to. Any fees/payments received must be made payable to NHS England and not to the individual speaker. Wherever feasible, any expenses incurred in attending third party events should be met directly and in full by the organisers.

6.10 Where officers are granted approval to speak on behalf of NHS England to the media or in a public forum, they must reflect the current policies and views of the organisation. This applies equally where officers use social media as part of their role (more information is included in the Social media guidance) as well as in meetings or informal discussions with any third party.

6.11 All officers must ensure their comments are well considered, well judged, well informed, made in good faith, in the public interest, without malice and maintain the reputation of, and public confidence in, the NHS and NHS England.

Endorsement

6.12 As set out in the NHS identity guidelines, NHS England cannot endorse or be seen as endorsing third party goods or services, regardless of if the third party has provided goods and services to NHS England or the wider NHS. Similarly, NHS England staff are not permitted to use their status as an NHS employee to endorse a third party in a private or professional capacity. 

Respect and dignity at work

6.13 NHS England aims to provide a working environment where everyone is respected and can work effectively, confidently, and competently, as set out in our Respect at work policy.

6.14 That means every officer is responsible for their own standards of behaviour, and for challenging inappropriate behaviour by others where observed. The organisation will investigate vigorously any allegation of harassment, bullying, abuse, or discrimination, whether it is raised formally or informally.

6.15 NHS England commits to taking and enforcing a zero-tolerance approach to any unwanted, inappropriate, and/or harmful sexual behaviours within the workplace, in line with the NHS England sexual safety in healthcare charter. 

Drugs and alcohol

6.16 Any officer thought to be under the influence of drugs and/or alcohol at work and not able to carry out their duties in a proper, fit, and safe way will be sent home, or if working from home required to take immediate leave. They will not be allowed to return to work until in a competent state to do so.

6.17 No officer can bring alcohol into or drink it on NHS England premises unless it is for an approved formal occasion, such as a colleague’s retirement. Approval for these events should be sought and received in writing from your relevant Executive team member. Officers should not drink alcohol at all during their contracted hours – on or off NHS England’s premises – without getting permission first.

6.18 Help is available for any employee who has or thinks they may have an alcohol or drug problem. That could be by discussing the matter confidentially with your line manager or occupational health via your human resources and organisational development business partner. A range of health and wellbeing services are available for employees of NHS England, in addition to support routinely available by NHS services in your area.

Insider dealing

6.19 As officers of NHS England, you may become privy to confidential commercial information which may relate to government departments, agencies, and public bodies as well as to NHS England. You must take all necessary precautions to protect any information which may affect the value of shares or other securities of companies NHS England or other government organisations contract with.

6.20 Misuse of price-sensitive information, or “insider dealing”, arises if:

1. You use inside information in relation to the purchase or dealing of shares.
2. The dealing takes place on a regulated market or via a broker.

Any suspicion of insider dealing will be investigated and could give rise to disciplinary action and referral to NHS England’s Counter Fraud team for potential criminal investigation.

Charitable collections

6.21 While we support officers who wish to undertake charitable collections among their immediate colleagues, no reference or implication should be drawn to suggest that NHS England is supporting the charity, and no undue pressure should be applied to any officers to donate.

Use of social media and websites

6.22 Social media and websites are public forums and entries are not private. Therefore, officers must not:

1. Conduct themselves in a way that brings the NHS or NHS England into disrepute.
2. Disclose information that is confidential to NHS or NHS England business, staff, or patients.
3. Give the impression that they are a spokesperson for NHS or NHS England without permission, for example by disclosing their job title on social media and commenting on the NHS or NHS England policy or performance.

6.23 Officers communicating via social media must comply with NHS England’s social media guidance.

Confidentiality

6.24 All officers must at all times operate in accordance with the UK General Data Protection Regulation (GDPR), and maintain the confidentiality of information of any type, including but not limited to patient information; personal information relating to officers; and commercial information.

6.25 This duty of confidence remains after officers (however employed) leave NHS England.

6.26 This does not prevent the disclosure of information where there is a lawful basis for doing so (for example, consent or public interest). Staff should refer to the suite of NHS England information governance and corporate information technology policies for detailed information.

Gambling

6.27 No officer may bet or gamble when on duty or on NHS England premises, with the exception of small lottery syndicates or sweepstakes related to common events, for example the Eurovision song contest, the FIFA Women’s World Cup or the Grand National. This should be among immediate colleagues within the same offices where no profits are made by virtue of organising them, or the lottery is wholly for purposes that are not for private or commercial gain (for example, to raise funds to support a charity). Officers should seek advice from their line manager and human resources and organisational development business partner if they are in doubt as to whether any small lottery syndicates or sweepstakes are permissible. 

Lending and borrowing

6.28 The lending or borrowing of money or other goods (excluding low-cost office materials such as pens etc) between officers is not permitted, whether informally or as a business, particularly where the amounts are significant. This is to avoid the creation of any obligation on the part of 1 officer to another which may influence their decision-making. Reasonable exceptions may be made to this rule, for example the short-term lending of small amounts of money for a specific purpose such as to buy a sandwich.

6.29 It is a particularly serious breach of discipline for any officer to use their position to place pressure on or otherwise convince any other individual to give or loan them money or other valuable goods.

Trading on official NHS England premises

6.30 Trading on official premises, by whatever means, is prohibited, whether for personal gain or on behalf of others. This includes placing flyers/catalogues for services/products anywhere in NHS England premises.

6.31 Canvassing within the office by, or on behalf of, outside bodies or firms (including non-NHS England interests of officers or their relatives) is also prohibited. 

Individual voluntary arrangements, county court judgement (CCJ), bankruptcy/insolvency

6.32 Any officer who becomes bankrupt, insolvent, has active CCJ, or has made individual voluntary arrangements with creditors must inform their line manager and their human resources and organisational development business partner as soon as possible. Officers who are bankrupt or insolvent cannot be employed, or otherwise engaged, in posts that involve duties which might provide opportunity for the misappropriation of public funds, or where they would be privy to information that could be exploited for personal financial gain.

Arrest or conviction

6.33 An officer who is arrested, subject to continuing criminal proceedings, convicted of any criminal offence, or commits a traffic offence that could see them go to prison, or is disqualified from driving where they are registered to drive for business purposes, must immediately inform their line manager and their human resources and organisational development business partner.

Appendix B – publication of the register of interests

To demonstrate compliance with this policy, we publish information on our website at the following intervals:

Staff group

Declaration

Ahead of the Board meeting

Quarterly

Annually

Published

Board members and national and regional directors

Declarations of interest

yes

n/a

n/a

yes

 

Gifts and hospitality meetings with non-NHS bodies sponsorship

n/a

yes

n/a

yes

Decision making officers

Declarations of interest gifts and hospitality sponsorship outside employment

n/a

n/a

yes

yes

All other staff within the scope of this policy

Declarations of interest gifts and hospitality outside employment

n/a

n/a

yes

no

All NHS England officers in scope of this policy who do not have access to the NHS England network and are unable to access CoreStream must complete and submit an online staff declaration form (request the link from the Corporate Governance team: nhse.compliance@nhs.net).

Appendix C: How this policy applies to substantive and non-substantive colleagues 

The table below explains how this policy applies to, and the disclosure requirements for, substantive (permanent and fixed term) NHS England officers and non-substantive (bank and honorary) officers, such as advisors, patient and public voice partners (PPVs) and volunteers. It highlights key differences between these groups. If you are unsure about your employment status, consult your line manager, human resources, and/or the Compliance team. Note that the status of staff groups is subject to change and this will be updated and communicated where necessary.

Key policy decisions

Substantive roles (permanent and fixed term) – full scope of Standards of business conduct policy applies

Non-substantive roles (bank and honorary)

 

Examples, but not limited to:

  • NHS England employees
  • non-executive directors
  • secondment (internal, external, or interim)
  • fixed term contracts
  • agency
  • contractors
  • consultants
  • apprentices
  • graduates
  • Graduate Management Training Scheme trainees
  • intern (paid)
  • strategic clinical networks
  • clinical senates 

Examples, but not limited to:

  • clinical educators
  • employed for tax purposes (EFTP), PPV/lay representatives
  • interns (unpaid)
  • members of advisory groups
  • medical advisors
  • global health fellows including fellows
  • volunteers

 

Within scope of the policy

Yes

When acting in NHS England role or conflict occurs due to your NHS England role

Mandatory annual review and disclosure of interests

Yes

Yes 

Nil-returns

Applicable if band 8d or above (or equivalent), or if the NHS England role includes decision-making responsibilities (see section 2.8 of the policy).

 

The default position is that nil returns are not required. However, for individuals or staff groups whose roles significantly influence key decisions or procurement activities, completion of nil returns is mandatory. Line managers are responsible for making this assessment initially and must notify the Corporate Governance team when such roles are identified.

Outside employment and company directorships

Approval and declaration: all external employment and directorships must be discussed with and receive prior approval from your line manager.

Any external employment or directorship that is connected to the NHS (directly or indirectly, including our suppliers or potential suppliers), its competitors, or any role which could reasonably be perceived as influencing your duties with NHS England, must be declared on CoreStream and approved by both human resources and organisational development and your executive senior manager.

When in doubt, it is advisable to disclose the interest.

If the interest does not relate to the NHS in any way, a declaration is not required.

Approval and declaration: Declarations on CoreStream are required only in cases of conflict with the NHS England role and must be submitted with approval from human resources and organisational development and the line manager.

 

 

Chair, non-executive and associate non-executive appointments of NHS trust roles

Employees are not legally permitted to hold a position of chair or non-executive director of an NHS trust at the same time as their NHS England role.

Approval and declaration – you must declare these roles on CoreStream. If a conflict is identified, this will require approval from the Executive Human Resources Group.

Chair, non-executive and associate non-executive appointments of NHS foundation trusts and other NHS /health service bodies

General rule is that these roles are not permitted.

Approval – if there are exceptional reasons why holding such a role is in the overall best interests of NHS England, a case will need to be made to the Executive HR Group and the NHS England Chair for approval (prior to taking on the role).

Approval and declaration – you must declare these roles on CoreStream. If a conflict is identified, this will require approval from the Executive Human Resources Group.

 

Hospitality (including travel and accommodation)

The default position regarding hospitality from suppliers, potential suppliers, contractors, and parties with whom there are commissioning, regulatory, or funding relationships is not to accept such offers. An exception is made for modest refreshments, such as coffee, biscuits, or sandwiches, provided during work-related activities.

Please consult the Standards of business conduct policy for information regarding values that necessitate disclosure and approval.

When representing NHS England or offer provided due to NHS England role, Standards of business conduct policy rules apply.

Shares/investments and other ownership holdings

All shareholdings and ownership interests in any publicly listed, private, or not-for-profit company, business, partnership, or consultancy that is currently engaged, or could reasonably be anticipated to engage, in business with NHS England must be fully disclosed. There is no need to declare shares or securities held in collective investments, pension funds or units of authorised unit trusts.

 

Only required to declare investment interests if they present a conflict with your NHS England role. If there is no identified conflict, disclosure is not necessary.

Policy prepared by: Deputy Director Compliance and Assurance

Policy owner: Director of Corporate Governance

Policy approved by and date: NHS England Board (September 2025)

Queries about the interpretation or application of this policy: Contact the Corporate Governance team: nhse.compliance@nhs.net