Hospitality, Gifts andExternal Sponsorship

Policy

Document Control Summary

Ratified By and Date Audit Committee, January 2014Date of Publication: January 2014Author: Angela Attah, Director of Corporate AffairsAccountable Director: Angela Attah, Director of Corporate AffairsDate issued: January 2014Review date: November 2015Target audience: All staff and external contractorsDepartment: Corporate AffairsPolicy Number:

Version Control Summary

Version Date Status Comment/ChangesV 0.2 March 2011 General revisionV 0.3 June 2011 Further revision following

comments by EMC, Audit Committee and revisions to

the policy on policies following a pre assessment

by NHSLAV 0.4 November 2011 Further revision to

clarify the rules around the acceptance of gifts from

patients following an internal audit report on patients’

monies.Reference the Bribery Act 2010,

which came into force on 1 July 2011

V 0.5 November 2013 Revision to clarify rules around representatives and

companies dealing with the Pharmacy and general

updateV.0.5 January 2014 Final Minor changes following review

and benchmarking by Internal audit

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CONTENTSParagraph page

1. Executive summary 42. Introduction 4

3. Purpose 4

4. Bribery Act 5

5. Duties 5

6. Ratification Process 5

7. Consultation Process 5

8. Acceptability 5

9. Individuals 6

10. Teams Responsibility 7

11. Commercial Sponsorship 8

12. Donations 10

13. Training Needs 10

14. Monitoring Compliance 10

15. References 11

16. Equality Impact 12

Appendices

1. Register of Hospitality, Gifts and External Sponsorship

2. Register of External Sponsorship for Education and Training

3. Procedure for pharmaceutical companies and their commercial representatives in their dealings with the Trust4. Procedure for commercial representatives in their dealings with the Trust

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1. EXECUTIVE SUMMARY

1.1 South West London and St George’s Mental Health NHS Trust recognises that public service values must be at the heart of the National Health Service and endeavours to promote and uphold these values. The NHS is publicly funded and is accountable to Parliament for the effective and economical use of taxpayers’ money.

1.2 A high standard of corporate and personal conduct, based on the recognition that service users come first, has been a requirement throughout the NHS since its inception and is expressed in the Nolan principles of public life and the NHS Constitution.

1.3 The aim of this policy is to put the relationship between the staff of South WestLondon and St. George’s Mental Health NHS Trust and its service users, their carers and families; and current and potential suppliers on a sound and professional footing and to provide suppliers and their commercial representatives with information on how they are expected to behave and what behaviour they can expect from the Trust’s staff.

2. INTRODUCTION

2.1 The Trust appreciates the role that its current and potential suppliers play in supporting health practitioners in providing safe, effective and economic products and services to the service users in their care and other staff working within the NHS, in the delivery of their duties.

2.2 The Trust is also aware that services users, their carers, families and friends sometimes wish to show their appreciation for the care they have received from staff and may do so by offers of gifts.

2.3 Staff must act in the best interests of service users when making referrals, arranging for and providing treatment or care. Staff must not ask for any inducement, gift or hospitality.

2.4 Staff must not encourage service users to give, lend or bequeath money or gifts or make donations that will directly or indirectly be of benefit to them.

2.5 This policy covers all areas of the Trust; all staff, clinical and non –clinical, including those who hold honorary contracts or joint appointments with St George’s University, and all hospitals and sites which Trust staff and service users occupy.

2.6 This policy will be available to the Trust’s suppliers through the Procurement Department. Copies will also be made available to staff in all areas and will be accessible on the Trust intranet.

2.7 Any breach of this policy that is considered potentially fraudulent and/or corrupt will be reported to, and investigated by, the Local Counter Fraud Specialist and may result in a criminal investigation being commenced.

3. PURPOSE

3.1 The aim of this policy is to set out the practical framework within which collaboration between the Trust, service users, their carers and families, suppliers and commercial

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sponsors can continue whilst maintaining public service values

3.2 The following procedure sets out how the Trust will implement its policy on hospitality, gifts and external sponsorship. It includes any business expense that is paid for by a third party (a drug company, for example, paying for a clinician to attend a conference or other educational event).

3.3 It does not cover any payment to a member of staff that amounts to remuneration for the delivery of a service, e.g. receiving a fee for providing a lecture, or participation in a marketing focus group etc.

4. BRIBERY ACT 2010

4.1 The Trust is bound by the Bribery Act 2010, under which it is an offence for employees to pay or receive bribes

4.2 Pay bribes: that is to offer or give a financial or other advantage with the intention of inducing a person to perform a relevant function or activity improperly or to reward that person for doing so.

4.3 Receive bribes: that is to receive a financial or other advantage intending that a relevant function or activity should be performed improperly as a result.

4.4 Conviction under the Act is punishable by imprisonment for a maximum of 10 years. More detail can be found in the Trust Fraud, Corruption and Bribery Policy 2011.

4.5 This section should be read in conjunction with the s 21.2.6 (d) of the Trust’s Standing Orders.

5. DUTIES

Committee/Individual Responsibilities/key activitiesBoard Overall responsibility for governance of the Trust

Receipt of annual register of gifts, hospitality and sponsorship

Audit Committee Approval of the Trust policy on Gifts, Hospitality and SponsorshipOverarching committee with responsibility for monitoring and reviewing application of the policyReceipt of register annually prior to presentation to the Board

Director of Corporate Affairs Responsible for operational corporate governance including the compliance with all legal, statutory and good practice guidance requirementsResponsible for revisions to the policy, dissemination and day to day implementation across the Trust, including the provision of advice where necessary.Responsible for maintenance of the register

Trust staff All staff, including temporary and agency staff, are responsible for compliance with this policy

6. RATIFICATION PROCESSKey Area Lead Director Working Group

(where appropriate) Ratification Body

Corporate Governance

Director of Corporate Affairs

Audit Committee

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7. CONSULTATION PROCESS

7.1 The Procurement and Pharmacy departments were given an opportunity to comment on early drafts of the policy and suggest amendments.

8. ACCEPTABILITY

8.1 Staff must not accept as an individual or a team from a service user, their carers or families; or potential or actual suppliers;

8.1.1 Any cash or cheque of any amount.

8.1.2 Any vouchers, exchangeable for cash of any amount

8.1.3 Any vouchers, exchangeable for goods or services of any amount.

8.1.4 Any holiday or travel event of any amount.

8.1.5 Any hospitality event (defined as attendance at a sporting event, concert or similar).

8.1.6 Any other gift (e.g. bottle(s) of beverage/box of chocolates, flowers, toiletries or similar), with a value of more than £25 from one individual or organisation

8.1.7 Any meal, or other hospitality, costing the provider more than the individual would normally pay themselves in the course of their work.

8.1.8 Any event where the employee’s partner is invited.

8.1.9 Bequests of any items/amounts

8.1.10 Any educational conference or seminar or other similar event, which is paid for, or partly paid for, by a commercial company, whether directly or indirectly UNLESS there is a record of agreement by the Head of Department, Head of Profession or their nominee providing evidence that a decision was made for the member of staff to attend based on a clear benefit to the Trust. The record must show who is financing the event. (Study leave must be applied for in the normal way.)

8.2 Declare and Register

8.2.1 There are areas where hospitality and gifts are acceptable but these must be recorded and will be published in the form of a Trust-wide Register. The Register will be reviewed quarterly by the Audit Committee and submitted to the Board annually.

8.3 The following may be accepted, but must be declared on the appropriate form;

8.3.1 A business lunch in the course of working visits or social event

8.3.2 Any other gift (bottle(s) of beverage/box of chocolates, flowers, toiletries or similar), with a value of less than £25 from one individual or organization

8.4 No Need to Declare in the Register

8.4.1 A diary, calendar, pen, other item of stationery, containing an advert for the company as this will have no perceived private value.

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8.4.2 Routine hospitality from service users or their carers and families e.g. tea/coffee and biscuits in a service users home

9. INDIVIDUALS

9.1 Individuals must record the details of any accepted hospitality on the pro-forma (attached as appendix 1) and submit to the Director of Corporate Affairs/Trust Secretary as soon as possible following receipt of a gift or agreement to accept any hospitality.

9.2 The Director of Corporate Affairs will maintain a composite register for the Trust, which will be available for inspection by auditors at any time and an annual report will be made to the Trust Board in public session.

9.3 A copy of the register will be available on the Trust website.

10. TEAMS HOSPITALITY

10.1 External Hospitality

10.1.1 Teams must not accept hospitality from external organisations. In exceptional cases where there is an obvious and genuine educational, training or research and development benefit to the team and the Trust this must be authorised locally by a Operational Manager or above, or by the Director of Corporate Affairs.  The hospitality must be proportionate to the benefit. For example, it is not acceptable to accept a £25 per head lunch in return for a short talk from a commercial representative about the company’s services.

10.2 Internal Hospitality

10.2.1 The code of accountability states that NHS monies for hospitality andentertainment should be used sparingly and modestly and only after each case has been carefully considered. All expenditure on these items should be capable of justification as reasonable in the light of the general practice in the public sector.

10.2.2 Whenever possible, meetings should be arranged within Trust premises. If this isnot possible, NHS establishments should be the preferred choice of venue. If rooms are not available within NHS premises, the meeting should be arranged at the most economic rate, taking into account room rates and refreshment charges.

10.2.3 Refreshments should not normally be provided at internal management/staffmeetings. Where refreshments are considered necessary, these should be limited to sandwiches, fruit, tea/coffee and fruit juice. Catering for all meetings should normally be arranged through the Facilities Department. For any other meetings where the need for external caterers is identified, the caterer used should be one with the most economic choice and be approved by the Facilities Department.

10.2.4 Lunches should not be provided if a morning meeting ends before 1.00 p.m. or ifan afternoon meeting commences after 2.00 p.m.

10.2.5 It is acceptable to supply coffee/tea for mid-morning/mid-afternoon meetingswhen attendees have travelled some distance to the meeting or when the meeting is to last a considerable period of time, i.e. in excess of 3 hours.

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10.3 Team Away Days

10.3.1 The Trust recognises that Team Away Days are a useful part of team building and Service improvement. However such events have to be consistent with value for money and in compliance with Trust Standing Orders.

10.3.2 HR guidance is that as far as possible teams should take the opportunity to meet away from the distractions of their usual environment in a planned event to

achieve agreed objectives/outcomes.

10.3.4 The general principle of the hospitality policy should apply, that such events should take place within Trust premises or where this is not practical, at other NHS venues. The use of external venues should be used sparingly and should be subject to the appropriate evaluation of costs, including the provision of refreshments where appropriate.

10.3.5 Use of non-Trust premises may only be booked with prior involvement of the Procurement Department and must be authorised locally by an Operational Manager or above or by the Director of Corporate Affairs, who must be satisfied that steps were taken to seek Trust premises for the event.

10.3.6 It should be noted that the use of external venues may mean the event is subject to public scrutiny with regards to appropriate and economical use of public funds.

10.3.7 All chosen venues should ensure appropriate access in accordance with the Disability Discrimination Act and that appropriate levels of confidentiality will be maintained.

11. COMMERCIAL SPONSORSHIP

11.1 Definition

11.1.1 Commercial Sponsorship is defined as:

11.1.1.1 Funding from an external source, including funding of all or part of the cost of a member of staff, piece of research, training, equipment, meeting rooms, costs associated with meetings (e.g. speakers, refreshments etc.), gifts, hotel and transport costs (including trips abroad).

11.1.2 All sponsorship arrangements require the joint approval of the Head of Department or Profession and the Director of Corporate Affairs.

11.2 Considerations

11.2.1 In deciding whether or not sponsorship is appropriate, the Trust will give due consideration to:

11.2.1.1 The need for purchasing decisions (including those concerning pharmaceuticals and appliances) always to be taken on the basis of best clinical practice and value for money. Such decisions should take into account their impact on primary as well as secondary care e.g. products dispensed in hospital that are likely to be required by patients regularly at home. See appendix 3 &4.

11.2.1.2 Any sponsorship linked to the purchase of particular products or the supply from particular sources, is not allowed, unless as a result of a transparent tender

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for a defined package of goods and services. See appendix 3 &4.

11.2.1.3 The legality and ethical standard of any sponsorship arrangements. This is particularly important where the sponsorship allows legally and ethically sound access to patient information (e.g. the sponsor is to carry out or support NHS functions, where patients have explicitly consented), and here a contract should be drawn up which draws specific attention to obligations of confidentiality. The sponsorship and contract should be approved by the Executive Management Committee.

11.3 Education and Training

11.3.1 Where a commercial company sponsors training events, any hospitality must be secondary to the meeting (and in line with such provision provided by the Trust) and not out of proportion to the event.

11.3.2 Education and training programmes should not be directly related to a specific treatment or product i.e. the content of the meeting will not be linked to any of the sponsor’s product portfolio.

11.3.3 External speakers for education and training events will speak according to a Trust brief. Content must not be provided by the sponsor, e.g. slides, PowerPoint presentations, posters etc.

11.3.4 Education and training in a particular clinical specialty, e.g. mental health, may be sponsored by pooling funding from a number of relevant companies. Companies may not specify how specific funding is spent. Any stand the sponsor uses to promote products is to be outside the main meeting room or, where this is not possible, in a discreet position for example at the back of the room.

11.3.5 Sponsorship of education and training events may be acknowledged in the following way if this is requested by the sponsor: “South West London and St George’s Mental Health NHS Trust is grateful for the support of Company X, Company Y, Company Z in the arrangement of this education and training event. “The Trust organiser must register, on behalf of the group, an estimate of cost prior to the event on the appropriate form. Individual participants do not need to record this.

11.4 Research and Development

11.4.1 When assessing a research proposal, consideration must be given to the possibility that it is merely a marketing ploy. In particular, the possible need for continuing treatment once the trial has finished must be addressed. For trials of drugs already marketed, it cannot be assumed that they will be supported by the Trust and added to the Drugs Formulary. Consequently, patients participating in a clinical trial must be made aware that there is no guarantee that it will be possible to continue a drug at the end of the trial, irrespective of the results. The Local Research Ethics Committee will need to assure itself that arrangements for any on-going treatment are in place before medication is commenced.

11.4.2 Research and development proposals should have received Local Research Ethics Committee (LREC) approval. The LREC submission must make clear the role and involvement of the sponsor.

11.4.3 Research and development proposals must accord with all relevant Trust policies and procedures.

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11.4.4 Sponsorship linked to the purchase of particular products is not allowed e.g., a researcher sponsored by a company prescribing only that company’s product.

11.4.5 Any intellectual property arising from sponsorship of research and development should be negotiated between the Trust (rather than an individual) and the sponsor.

11.5 Advertising Sponsorship

11.5.1 Some companies will offer to fund patient information (leaflets or maps are typical) on the basis that the sponsoring organisation's expenditure is covered through advertising space. This can be a useful means of providing well-formatted information for patients, but the Trust must ensure that the agreement does not permit advertising of services or specific products.

11.5.2 Therefore, no agreements for advertising sponsorship should be entered into without the prior approval of the Director of Corporate Affairs.

12. DONATIONS

12.1 All charitable donations by individuals or groups received by a member of staff must be immediately directed to the Director of Finance and Deputy Chief Executive for onward transmission to the Trust Charitable Funds.

12.2 Where there is any uncertainty regarding the acceptance of any gift, hospitality or sponsorship, advice should be sought from the Director of Corporate Affairs

13. TRAINING NEEDS

13.1 In order to ensure the health, safety and well-being of our service users and staff, the Trust aims to address the needs and impact of its corporate, mandatory and statutory training with a comprehensive and robust training needs analysis procedure. To this end, all Trust procedural documents which have risk management training needs for permanent staff are included in the ‘Corporate, Mandatory and Statutory Training Needs Analysis’ document as managed by the Training and Development Department. This document is available on the Trust intranet, under ‘Training and Development’.

13.2 Duties within this area are as follows:

Author Responsible for informing the Training and Development Department of amendments to policy training needs.

Ratification Body The ratification body is responsible for ensuring all permanent staff are adequately trained as appropriate to the employees’ duties and work location and to follow up on refresher training needs.

Staff responsibility

To ensure they attend all relevant training as detailed in their induction and annual development review.

Training and Development Department

To provide access to training for all permanent staff. To maintain monitoring, reporting and review systems as per the ‘Corporate, Mandatory and Statutory Training Policy’.

13.3 Periodically, the Director of Corporate Affairs, on behalf of the Audit Committee will seek to raise awareness of policy by appropriate means.

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14. MONITORING COMPLIANCE WITH AND THE EFFECTIVENESS OF PROCEDURAL DOCUMENTS

Element to be monitored

Lead Tool Frequency

Reporting arrangements

Acting on recommendations and Lead(s)

Change in practice and lessons to be shared

Number of declarations made

Audit Committee and Director of Corporate Affairs

Annually Audit Committee

Audit Committee/ Director of Corporate Affairs

Required changes to practice will be identified and actioned within a specific time frame. The Director of Corporate Affairs will take changes forward, liaising with other senior staff as appropriate.

Associated Documents;

Standards of Business Conduct for NHS Staff – 1993 – as superseded in part by the Bribery Act 2010

NHS Code of Conduct – April 1994 (as amended in 2002 & 2004)

Commercial sponsorship – Ethical Standards for the NHS – DOH Nov 2000

NHS Constitution 2013

Bribery Act 2010

Trust Fraud, Corruption and Bribery Policy 2011

Trust Standing Orders 2012

Royal College of Psychiatrists – Good Psychiatric Practice July 2003

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Susan L Coyle. Physician – Industry Relations. Part 1: Individual Physicians/Part 2: Organisational Issues

British Journal of Nursing, 2001, Vol 10, No 21 – the pharmaceutical industry and mental health nursing

Mental Health Practice, October 2001 Vol 5 No 2 – concerns over the influence that pharmaceutical representatives have on nurses

The World Medical Association, 2004 – The world medical association statement concerning the relationship between physicians and commercial enterprises9.

15. References

In relation to the Equality Impact Assessment;

Health and Social Care Act 2001 (as amended)The Human Rights Act 1998The Equal Pay Act (as amended) 1970Promoting Equality and Human Rights in the NHS - A Guide for Non-Executive Directors of NHS Boards (2005) Department of HealthNHS Act 2006The Equality Act 2010

16. EQUALITY IMPACT ASSESSMENT TOOL

To be completed and attached to any procedural document as an appendix when submitted to the appropriate committee/group for consideration and approval.

Yes/No Comments1. Does the policy/guidance affect one group

less or more favourably than another on the basis of:Race NoEthnic origins (including gypsies and travellers)

No

Nationality NoGender NoCulture NoReligion or belief NoSexual orientation including lesbian, gay and bisexual people

No

Age NoDisability - learning disabilities, physical disability, sensory impairment and mental health problems

No

2. Is there any evidence that some groups are affected differently?

No

3. If you have identified potential discrimination, are any exceptions valid, legal and/or justifiable?

4. Is the impact of the policy/guidance likely to be negative?

No

5. If so can the impact be avoided?

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6. What alternatives are there to achieving the policy/guidance without the impact?

7. Can we reduce the impact by taking different action?

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APPENDIX 1

REGISTER OFHOSPITALITY, GIFTS AND EXTERNAL SPONSORSHIP

NameDesignationTelephone NumberEmail Address

Date Sponsoring Organisation

Nature of Sponsorship Estimated Cost

Signed:Date:

PLEASE SEND TO:CORPORATE AFFAIRS MANAGER/ASSISTANT TRUST SECRETARY, TRUST HQ, 2ND FLOOR

BUILDING 15, SPRINGFIELD HOSPITAL,61 GLENBURNIE ROAD, TOOTING SW17 7DJ

AT EACH MONTH END

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APPENDIX 2

REGISTER OFEXTERNAL SPONSORSHIP FOR EDUCATION AND TRAINING

Date Sponsoring Organisation

Nature of Sponsorship Estimated Cost

Name_______________________________________________________________

Designation_________________________________________________________

Name of Group (SHOs/Ward Managers etc.____________________________________

Date~___________________________________________________________________

Telephone Number

Email Address

PLEASE SEND TO:CORPORATE AFFAIRS MANAGER/ ASSISTANT TRUST SECRETARY, TRUST HQ, 2ND FLOOR

BUILDING 15, SPRINGFIELD HOSPITAL,61 GLENBURNIE ROAD, TOOTING SW17 7DJ

AT EACH MONTH END

APPENDIX 3

(This procedure is available in leaflet form from the Pharmacy to give to representatives.)

Procedure for pharmaceutical companies and their commercial representatives in their dealings with the Trust

1. General Information

1.1 It is recognised that the prime function of representatives is to promote and sell their products and services. This function should be carried out in a proper and ethical manner, and not contravene the ABPI Code of Practice, Trust, NHS or government policies. Any contravention will be reported to the Chief Pharmacist, as detailed in paragraph 1.3 below.

1.2 The Trust policy statement (overleaf) must be noted and adhered to.

1.3 Commercial representatives should note that the Trust has an Incident Reporting Policy. Should anyone (service user, carer, member of staff, student, visitor, volunteer or contractor) be affected by any inappropriate behaviour on the part of a commercial representative, they should complete an Incident Report Form. Appropriate action will then be taken by the Trust’s senior management.

1.4.1 Trust staff are aware of the Trust policy statement, and this procedure, so that if direct contact is made between an individual member of staff and a commercial representative, the procedure is followed.

2. Visits to Trust sites

2.1 Representatives may not enter any Trust premises (including clinical areas) without an appointment arranged with a clinical staff member of appropriate seniority (see 3.1). Promotional activities must not take place in any clinical settings.

2.2 When on site, all representatives must respect their position as a visitor to the

Trust, and comply with any instructions given to them by an authorised member of staff in the event of an emergency situation arising (e.g. fire). They are also expected to comply with, for example, security regulations, the No Smoking Policy, the Car Parking Policy, and any other such policies, procedures or guidance as would be relevant at the time.

3. Personal appointments

3.1 Commercial representatives may not seek appointments with medical staff below the level of consultant or any other staff below Band 7 e.g. ward manager. The emphasis and scope of such meetings must be agreed in advance.

3.2 Representatives should be well informed about the products they are promoting and non-formulary medicines or off-label prescribing of drugs must not be promoted. Price comparisons should not be used unless approved in advance, in writing by the Chief Pharmacist.

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4. Promotional Activity

4.1 In the case of sponsorship of educational meetings where hospitality is provided by the pharmaceutical company, the educational content of the meeting must be entirely independent, provided by Trust staff rather than by the pharmaceutical company. The representative may not be present during the educational talk or any subsequent discussion.

4.2 Any promotion at the meeting must not contravene/challenge existing Trust or NHS policies and procedures e.g. non-formulary drugs may not be promoted or discussed.

4.3 Pharmaceutical representatives may be allowed to speak about their products to attendees who wish to discuss the products with them, but this needs to be in an area of the venue clearly demarcated as separate from the educational meeting (or ideally in a separate room).

4.4 Representatives must contact the Lead Directorate, Deputy Chief or Chief

Pharmacist before sponsorship of any events is planned anywhere on Trust premises.

4.5 Leaflets and posters produced by the pharmaceutical industry may not be distributed or displayed in clinical areas, unless the Chief Pharmacist has approved this in writing.

4.6 Industry representatives must not inform staff about the Trust’s prescribing policies, except with the written permission of the Chief Pharmacist or Chair of the Drugs & Therapeutics Committee. Misrepresentation of this information, within or outside the Trust, will be construed as a deliberate attempt to contravene the Trust’s policy.

5. Medicine samples

5.1 Medicine samples and medical devices or instruments must never be left with any staff.

5.2 Product trials must be discussed with the Deputy Chief Pharmacist and the main Trust procedure must be followed.

By adhering to this guidance, it is hoped that the association between the Trust and the pharmaceutical industry will be a constructive one.

Drugs & Therapeutics Committee

December 2012

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APPENDIX 4

(This procedure is available in leaflet form from the Procurement Department to give to representatives.)

PROCEDURE FOR COMMERCIAL REPRESENTATIVES IN THEIR DEALINGS WITH THE TRUST

1 GENERAL INFORMATION

1.1 It is recognised that, in addition to providing information to health practitioners, the prime function of representatives is to promote and sell their products and services. This function should be carried out in a proper and ethical manner, and not contravene Trust, NHS or government policies. Any contravention will be reported to the Head of Procurement, as detailed in paragraph 3 below.

1.2.1 The Trust’s Policy on Hospitality, Gifts and External Sponsorship must be noted and adhered to.

1.3 Commercial representatives should note that the Trust has an Incident Reporting Policy. Should anyone be affected (patient, staff, student, visitor, volunteer or contractor) by any behavioural actions from a commercial

representative, they should complete an Incident Report Form. Appropriate steps will then be taken by the Trust’s senior management.

1.4 The Trust’s staff will be aware of the Trust policy statement, and this procedure, so that if direct contact is made between an individual member of staff and a commercial representative, the procedure is followed.

1.5 Note that commitment to purchase goods and services is only entered into by the raising of an official Trust Purchase Order. Suppliers must not deliver goods or provide a service without first receiving an official Trust Purchase Order.

2 VISITS TO TRUST SITES

2.1 When on site, all representatives must respect their position as a visitor to the Trust, and comply with any instructions given to them by an authorised member of staff in the event of an emergency situation arising (e.g. fire). They are also expected to comply with, for example, security regulations, the No Smoking Policy, the Car Parking Policy, and any other such policies, procedures or guidance as would be relevant at the time.

2.2 Representatives may not enter any Trust premises (including clinical areas) without an appointment. Promotional activities must not take place in any clinical settings.

3 PERSONAL APPOINTMENTS

3.1 Commercial representatives may not seek appointments with junior members of staff (medical staff below the level of specialist registrar, all other staff below Band 7), without the agreement of the Head of Procurement but may

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seek an open meeting with the staff in a group. The emphasis and scope of such meetings must be agreed in advance.

4 PROMOTIONAL ACTIVITY

4.1 Representatives should be well informed about the products they are promoting. In addition to standard technical data, including information on comparative effectiveness, the representative must be prepared to discuss the specific use of the product. Price comparisons should not be used unless approved in advance, by letter from the Head of Procurement.

4.2 Representatives must contact the Head of Procurement when teaching/promotional activity is planned anywhere on Trust premises. The

intent of the meeting must not contravene/challenge existing Trust or NHS policies and procedures.

4.3 Leaflets and posters produced by the industry may not be distributed or displayed unless approved by the Head of Procurement.

By adhering to this guidance, it is hoped that the association between the Trust and potential suppliers will be a constructive one. Clarification of any of these issues may be sought from the office of the Head of Procurement.

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