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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 provide clear guidelines on secondary employment and conflict of interest management within {{org_field_name}}, ensuring that all staff conduct themselves ethically, professionally, and in compliance with regulatory requirements.

This policy aligns with the Regulation and Inspection of Social Care (Wales) Act 2016, Social Care Wales Code of Professional Practice, Care Inspectorate Wales (CIW) guidelines, and UK employment legislation. It ensures that secondary employment and any potential conflicts of interest do not compromise care quality, service user safety, staff well-being, or the reputation of the organisation.

It establishes the responsibilities of employees and {{org_field_name}} in identifying, managing, and mitigating conflicts of interest, ensuring transparency and fairness in all employment-related matters.

2. Scope

This policy applies to:

• All employees of {{org_field_name}}, including care workers, office staff, and management.
• Contracted, part-time, and agency workers employed by {{org_field_name}}.
• Situations where an employee holds or wishes to obtain secondary employment.
• Any potential conflict of interest that could impact the integrity, safety, or reputation of {{org_field_name}}.

It covers:

• Approval process for secondary employment.
• Identifying and managing conflicts of interest.
• Workload management and working time regulations.
• Consequences of unapproved secondary employment or undisclosed conflicts.

3. Principles of Secondary Employment and Conflict of Interest Management

3.1 Approval Process for Secondary Employment

Employees who wish to take on secondary employment must obtain written approval from {{org_field_name}} to ensure that their additional work:

• Does not conflict with their primary role or responsibilities.
• Does not result in excessive working hours, leading to fatigue and reduced performance.
• Does not create a conflict of interest or a risk to service users or the organisation.

Application Process:

1. Employees must submit a formal written request to their line manager or HR department, detailing:
   • The name and nature of the secondary employer.
   • The role and responsibilities of the secondary employment.
   • The expected working hours.
   • Any potential overlap with their role at {{org_field_name}}.
2. The Registered Manager or HR team will review the request and assess potential risks to care delivery and employee well-being.
3. Employees will receive written confirmation of approval or rejection within 14 days of submitting their request.

Approval may be withdrawn if secondary employment is found to:

• Negatively impact performance or reliability.
• Pose a conflict of interest with {{org_field_name}}.
• Exceed working time regulations.

3.2 Identifying and Managing Conflicts of Interest

A conflict of interest occurs when an employee’s secondary employment, personal relationships, or outside interests compromise their ability to act impartially or jeopardise the integrity of their role within {{org_field_name}}.

Examples of conflicts of interest include:

• Working for a competitor or similar care provider in the same area.
• Providing private care to a service user of {{org_field_name}} outside of contracted hours.
• Holding financial or personal interests in an organisation supplying goods or services to {{org_field_name}}.
• Having a close personal relationship with a service user or their family, leading to preferential treatment or ethical concerns.

Employees must declare potential conflicts of interest immediately to their line manager, who will assess the situation and take appropriate action.

3.3 Managing Workload and Working Time Regulations

Employees must not exceed legal working limits, ensuring they remain fit for duty and able to provide high-quality care.

Key Rules:

• The Working Time Regulations 1998 state that no employee should work more than 48 hours per week on average, unless they opt out in writing.
• Employees must have adequate rest breaks between shifts to prevent fatigue-related risks.
• Sleep-in shifts and travel time must be factored into total working hours.
• If secondary employment results in excessive working hours, {{org_field_name}} reserves the right to:
  • Request a reduction in secondary employment hours.
  • Monitor performance and well-being.
  • Decline further requests for additional employment.

Health and Safety Considerations:
Excessive working hours can lead to fatigue, reduced concentration, and increased risk of errors, posing a serious threat to service user safety. Employees must ensure they:

• Get adequate rest between shifts.
• Avoid working consecutive long shifts that compromise care quality.
• Report concerns about work-life balance to management.

3.4 Consequences of Unapproved Secondary Employment or Undisclosed Conflicts

Failure to declare secondary employment or a conflict of interest may result in:

• Formal investigation and disciplinary action.
• Review of performance, well-being, and care delivery standards.
• Termination of employment if there is a serious breach of policy.

Disciplinary actions will align with the Disciplinary and Grievance Policy (DCW31).

3.5 Confidentiality and Data Protection Considerations

Employees must not share confidential information about service users, business operations, or internal procedures with external employers. Any breach of data protection laws or GDPR may result in legal consequences and disciplinary action.

Staff must:

• Refrain from discussing confidential information with third parties.
• Ensure work devices, emails, and documents are kept secure and used only for legitimate business purposes.
• Report any accidental data breaches immediately to the Data Protection Officer.

These measures safeguard service user confidentiality and business integrity.

3.6 Monitoring and Compliance with CIW Regulations

{{org_field_name}} is responsible for ensuring full compliance with CIW standards regarding staffing levels, work-life balance, and professional integrity.

Regular compliance checks include:

• Annual conflict of interest declarations completed by all employees.
• Routine staff well-being assessments to monitor workload pressures.
• Spot checks and audits to ensure secondary employment is not impacting service quality.
• Consultation with CIW inspectors where necessary to uphold best practice in employment and ethics.

Failure to adhere to CIW regulations may result in formal warnings, regulatory intervention, or disciplinary action.

4. Efficiency in Managing Secondary Employment and Conflicts of Interest

To ensure effective management, {{org_field_name}} implements:

• Digital tracking of secondary employment requests and approvals.
• Transparent reporting channels for conflicts of interest.
• Annual training for staff and management on ethical decision-making and work-life balance.
• Proactive well-being checks to monitor staff health and performance.
• Regular audits and compliance reviews, ensuring adherence to employment laws and CIW guidelines.

These proactive measures ensure that staff can maintain additional employment responsibly, while preserving care quality and regulatory compliance.

5. Related Policies

This policy should be read alongside:

• Staff Conduct and Code of Ethics Policy (DCW28)
• Health and Well-being Policy (DCW25)
• Safeguarding Adults from Abuse and Improper Treatment Policy (DCW13)
• Confidentiality and Data Protection (GDPR) Policy (DCW34)
• Disciplinary and Grievance Policy (DCW31)

6. Policy Review

This policy will be reviewed annually, or sooner if legislative updates or operational changes require amendments.

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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.