
Publication
Regulatory investigations and enforcement: Key developments
The past six months have seen a number of key changes in the regulatory investigations and enforcement space.
Global | Publication | March 2017
NHS England has published new guidelines on managing conflicts of interest. The guidance will come into force on 1 June 2017. It will be applicable to Clinical Commissioning Groups, NHS Trusts and NHS Foundation Trusts, and NHS England.
The guidance covers common situations which can give rise to risk of conflicts of interest including gifts, hospitality and providing expertise outside employment, by:
Organisations should require staff to comply with the guidance and to proactively declare interests. An organisation will consider a range of actions from deciding no action is warranted to removing an individual from their role altogether if the conflict is so significant that they are unable to operate effectively in it.
The NHS England guidance has been aligned with The Association of the British Pharmaceutical Industry (ABPI) Code of Practice, particularly as it relates to the principles and rules for gifts and hospitality. Organisations are also required to seek to ensure that staff are subject to wider transparency initiatives such as the ABPI’s Disclosure UK.
Disclosure UK, launched in June 2016, is a searchable database detailing transfers of values made to healthcare professionals and healthcare organisations by pharmaceutical companies. The database is the means by which UK pharmaceutical companies comply with their transparency obligations under the ABPI Code of Practice.
Publication
The past six months have seen a number of key changes in the regulatory investigations and enforcement space.
Publication
In a recent determination, the Ombudsman rejected a scheme member’s claim that the trustees should have conducted due diligence on the receiving scheme before making a transfer in in 2014, as there was no duty of care on the trustees at the time of transfer.
Publication
The Court of Appeal has confirmed that proof of disclosure to third parties is not required for data protection law breaches and that individuals’ rights are breached by unlawful “processing” alone.
Subscribe and stay up to date with the latest legal news, information and events . . .
© Norton Rose Fulbright LLP 2025