Conflicts of interest at a CCG – whistleblowing and professional conduct

Conflicts of interest at a CCG – whistleblowing and professional conduct

The client

Clinical Commissioning Group – Healthcare


Whistleblowing & Professional Conduct.

Our challenge was to investigate concerns raised by a whistleblower, who had made allegations about the professional behaviour of a colleague, conflicts of interest a the CCG and the treatment of whistleblowers at the CCG.


Verita was commissioned by the lay member and interim Head of Governance and Corporate affairs at the CCG to conduct an independent investigation into concerns raised by a whistleblower around conflicts of interest in the commissioning of primary care services by the CCG.


The review consisted of a series of interviews and an examination of documents provided by both the whistleblower and the CCG. The Verita team included partner Peter Killwick, director Amber Sargent and consultant Charlie de Montfort.


Our report concluded that the member of staff should have been protected by the CCG’s whistleblowing policy and public interest disclosure legislation.

Our team found that senior staff at the CCG said that they were not aware that the member of staff was making a whistleblowing complaint. However, we concluded that it is impossible to be sure whether the member of staff’s contract was terminated because he raised a concern about a conflict of interest.

We also made findings that have implications for all CCGs:

  • A lack of consistent, substantive workforce undermined the organisational memory of the CCG
  • The issues caused by the rapid workforce turnover is exacerbated by a lack of clarity of roles, responsibilities and boundaries
  • Poor administration around vital documents and an inconsistent understanding and enforcement of conflict of interest declarations.


Our recommendations covered reviewing the process of declaring conflicts of interest so that it can be ensured that all staff are clear about what should be declared, ensuring that all local enhanced schemes are sent to NHS England before they are implemented and clarifying roles and responsibilities.


All of our recommendations have been accepted by the Governing Body and an implementation plan has been developed to take the recommendations forward.


The Chair of the CCG said: “The CCG welcomes this report and will continue the work that has already started to adopt the recommendations for improvements to process and systems.”