All staff, regardless of grade, need to make a declaration annually or within 28 days of a change of circumstances or when there is a new interest. This can take the form of a ‘nil declaration’.

 ICB Board and ICB Committee members (including Senior Managers, co-opted members, appointed deputies and members from other organisations) need to make a Mandatory completion of Conflicts of Interest Form upon appointment and when any new outside employment arises (even if this is a Nil return) and this would be completed 6 monthly or within 28 days of a change of circumstances.

 Procurement work: In line with the rest of the policy, the rule for those involved in a procurement / procurement decision remains ‘if in doubt, declare the interest’, taking advice from the procurement adviser / governance lead as necessary.