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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Secondary Employment and Conflict of Interest Policy

1. Purpose

The purpose of this policy is to establish clear guidelines on secondary employment and conflicts of interest within {{org_field_name}}, ensuring compliance with the latest Care Inspectorate Wales (CIW) regulations, employment legislation, and best practices in social care governance. The policy aims to safeguard the integrity of our care provision by ensuring that secondary employment does not compromise staff performance, regulatory compliance, or the well-being of our residents.

2. Scope

This policy applies to all employees of {{org_field_name}}, including full-time, part-time, agency, temporary, and contracted staff. It covers the principles of secondary employment, the process for disclosure and approval, potential conflicts of interest, and the responsibilities of employees and management. The policy ensures that staff commitments outside of {{org_field_name}} do not lead to conflicts with their roles, duties, or responsibilities.

3. Related Policies

This policy should be read in conjunction with:

• CHW04 – Good Governance Policy: Ensuring transparency in employment practices.
• CHW27 – Staff Supervision, Training, and Development Policy: Maintaining staff competence and performance.
• CHW23 – Lone Working and Staff Safety Policy: Managing staff workload and fatigue to ensure safety.
• CHW31 – Disciplinary and Grievance Policy: Addressing breaches of employment terms related to secondary employment.
• CHW30 – Equality, Diversity, and Inclusion Policy: Ensuring non-discriminatory practices in employment.

4. Policy Statement

{{org_field_name}} recognises that employees may engage in secondary employment or business interests outside of their primary role. However, it is essential that such employment does not compromise the quality of care, create a conflict of interest, or lead to breaches of working time regulations. All employees are required to disclose any secondary employment to ensure compliance with regulatory requirements and maintain professional integrity.

5. Secondary Employment Guidelines

Employees may undertake secondary employment provided that:

• It does not interfere with their contractual obligations, responsibilities, or performance at {{org_field_name}}.
• It does not create a conflict of interest with their duties or responsibilities.
• It does not breach the Working Time Regulations 1998, ensuring adequate rest periods between shifts.
• It does not pose a risk to health and safety by causing excessive fatigue or stress.
• It does not involve working for a direct competitor or in a role that compromises confidentiality or business interests.

6. Disclosure and Approval Process

To ensure transparency and compliance, employees must adhere to the following process:

1. Declaration of Secondary Employment: Employees must complete a Secondary Employment Disclosure Form and submit it to HR before engaging in any additional work.
2. Management Review: The Registered Manager and HR will assess the impact of the secondary employment on performance, health and safety, and conflicts of interest.
3. Approval or Denial: Employees will receive written confirmation of approval or reasons for rejection within 10 working days.
4. Ongoing Monitoring: Employees must notify HR of any changes to their secondary employment to ensure continued compliance.

7. Conflict of Interest Management

A conflict of interest arises when an employee’s secondary employment or personal interests could compromise their duties at {{org_field_name}}. Examples include:

• Working for another care provider in a similar role without disclosure.
• Holding a financial interest in a business that provides goods or services to {{org_field_name}}.
• Accepting gifts or incentives from suppliers that may influence decision-making.
• Engaging in private care services for current or former residents outside of organisational agreements.

To prevent conflicts of interest:

• Employees must disclose any potential conflicts to HR immediately.
• Staff in managerial or procurement roles must not have financial interests in companies dealing with {{org_field_name}}.
• Employees must not use organisational resources or confidential information for personal gain.

8. Managing Secondary Employment and Conflicts Efficiently

To ensure compliance and minimise risks, {{org_field_name}} implements the following measures:

• Employee Training: Regular training sessions on ethical working practices and conflict of interest management.
• Monitoring Working Hours: HR tracks staff hours to prevent excessive workloads and ensure adherence to the Working Time Regulations.
• Fair Review Processes: Transparent and fair assessment of secondary employment requests.
• Whistleblowing Protection: Encouraging employees to report any concerns regarding conflicts of interest confidentially.
• Annual Compliance Audits: Reviewing staff declarations and employment records to ensure ongoing adherence.

9. Responsibilities

• Employees: Responsible for disclosing secondary employment and any conflicts of interest, ensuring they do not compromise their duties.
• Registered Manager: Reviews and approves secondary employment applications, ensuring compliance with care standards.
• HR Department: Maintains records, monitors compliance, and ensures working hours align with regulations.
• Senior Management: Oversees policy implementation and ensures fair and consistent enforcement.

10. Compliance with CIW Regulations

This policy aligns with CIW’s expectations, including:

• Ensuring transparency in employment practices to maintain professional integrity.
• Protecting resident well-being by preventing staff fatigue and conflicts of interest.
• Maintaining high standards of care by ensuring employees are focused and committed to their roles.
• Preventing undue influence on care provision by ensuring secondary employment does not compromise ethical decision-making.

11. Policy Review

This policy will be reviewed annually or updated in response to changes in employment law, CIW regulations, or operational needs. Any amendments will be communicated to all staff to ensure continued compliance.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.