NHS Scotland: Standards of Business Conduct

6. Annex B: Alignment with NHS Board Standing Financial Instructions (SFIs)

This Annex clarifies how the Standards of Business Conduct (SBC) interfaces with each NHS Board’s Standing Financial Instructions (SFIs), Standing Orders and Scheme of Delegation, to avoid duplication and ensure consistent implementation across Scotland.

6.1 Status and Relationship

The SBC is a national governance and transparency framework dealing with declarations, publication and management of interests, gifts and hospitality, outside roles, sponsorship and meeting conduct.

SFIs are Board-specific financial governance instruments setting delegated limits, approval routes, procurement controls, audit requirements and record-keeping standards. The SBC does not change SFI limits or authorities.

Where the SBC references procurement, sponsorship, expenditure, travel/subsistence or record‑keeping, those activities must be undertaken within each Board’s SFIs, Standing Orders and Scheme of Delegation.

6.2 Operational Cross-References (Use in Local Policies)

• Procurement: apply SFI rules on fair competition, prevention of supplier advantage, evaluation integrity and full auditability in line with the Board’s Standing Orders and procurement policies.
• Sponsorship: ensure value‑for‑money, propriety and financial controls per the Board’s SFIs; sponsorship must never be contingent on current or future procurement decisions.
• Gifts & Hospitality: declaration, review and retention processes must support SFI audit trails (accuracy, completeness, retention periods and accessibility for internal/external audit).
• Approvals/Expenditure: any approval involving spend, commitment, sponsorship, travel or subsistence must follow SFI delegated limits and authorisation pathways.
• Publication of Interests: where staff interests are published for defined senior roles, maintain source records and change logs to SFI audit standards, including annual validations and rectification routes.

6.3 What Boards Do Not Need To Change

NHS Boards do not need to amend SFIs to adopt the SBC. The SBC supplements SFIs by providing behavioural and transparency standards; SFIs retain local financial governance.

Boards should signpost the SBC in governance manuals or intranet pages, and ensure local procedures (e.g., procurement checklists, sponsorship templates, declarations systems) contain links back to the SBC and SFIs.

6.4 Minimal Local Actions for Consistent Rollout

We propose the following text to local governance manuals or policy index pages:

“This Standards of Business Conduct framework operates alongside the Board’s Standing Financial Instructions (SFIs), Standing Orders and Scheme of Delegation. Nothing in this framework alters financial approval limits, procurement responsibilities or delegated authorities. All procurement, sponsorship, expenditure, record‑keeping and publication of interests under this framework must comply with the Board’s SFIs, including audit and accountability requirements.”

In addition to this Boards should ensure the declarations system captures sufficient structured data to enable SFI‑compliant audit trails (timestamps, reviewer, actions taken).

We will also need to ensure sponsorship agreements and procurement plans include an explicit statement of SFI compliance and are retained in the corporate records management system.

6.5 Assurance and Audit

Internal Audit may test SBC compliance (e.g., declaration completeness, timeliness, management actions) alongside SFI compliance tests. Evidence should be readily available and consistently formatted.

Annual reporting to the Audit & Risk Committee should summarise declaration metrics, publication scope, exceptions and remedial actions, aligned to SFI audit expectations.