NHS Scotland: Standards of Business Conduct

7. Annex C: Alignment with Once for Scotland Workforce Policies

To explain how the Standards of Business Conduct (SBC) aligns with, supports, and supplements the Once for Scotland (OfS) Workforce Policies, and to clarify boundaries so the SBC does not duplicate, replace, or conflict with national workforce policy requirements.

7.1 Status and Relationship Between SBC and OfS Policies

The Standards of Business Conduct is a national governance and transparency framework covering:

• Conflicts of interest
• Gifts & hospitality
• Sponsorship
• Secondary employment
• Declarations and publication of interests
• Meeting conduct and decision‑making integrity

The OfS Workforce Policies provide nationally standardised HR and employment processes across NHS Scotland (e.g., Recruitment & Selection, Secondary Employment, Disciplinary, Whistleblowing).

The SBC does not change any OfS policy rules, HR procedures, approval processes, or statutory obligations.

Where the SBC touches on areas that are also covered by workforce policy (e.g., secondary employment approval, conduct expectations, whistleblowing routes), OfS policies take operational precedence.

7.2 Operational Interfaces and Cross‑References

Secondary Employment

SBC requires staff to declare outside roles/interests, but approval of secondary employment continues to follow the OfS Secondary Employment Policy.

SBC adds a governance transparency layer by categorising outside roles as interests and setting publication rules (for senior staff), but does not alter approval tests or processes.

Recruitment & Selection

SBC requires staff involved in recruitment to declare actual or perceived conflicts.

The OfS Recruitment & Selection policy governs:

• Panel formation
• Fair recruitment practice
• Eligibility checks
• Required documentation

The SBC supplements this by clarifying when an interest means a staff member should withdraw from decision‑making.

Disciplinary

SBC makes clear that failure to comply may lead to disciplinary action, but any sanctions or processes must be undertaken under the OfS Disciplinary Policy.

SBC sets the conduct standard; OfS defines the employment process.

Whistleblowing

SBC references the need for transparent reporting routes around concerns of misconduct, fraud, corruption or conflicts.

The Once for Scotland Whistleblowing Policy remains the formal mechanism for raising protected disclosures.

Induction (Once for Scotland Onboarding & Induction Policy)

SBC requires that new staff declare their interests within the first month.

OfS induction policy governs what onboarding must include; SBC content should be embedded into induction packs and local onboarding.

What the Standards of Business Conduct Does Not Do

• It does not introduce new HR approval steps.
• It does not create new disciplinary grounds beyond what the OfS Disciplinary Policy covers.
• It does not change workforce contractual terms or employment processes.
• It does not duplicate OfS policy content; instead, it signposts and complements it.

7.3 Minimal Local Actions for Consistent Implementation Across Boards

Health Boards should:

Insert the following standard wording into local HR governance manuals:

“The Standards of Business Conduct framework operates alongside the Once for Scotland Workforce Policies. Where conduct, approval, or employment matters arise, the Once for Scotland national policy takes operational precedence. The SBC provides additional transparency and governance requirements and must be applied in conjunction with the relevant OfS policy.”

Boards will also need to ensure staff declaration systems link to relevant OfS policies (Secondary Employment, Recruitment & Selection, Disciplinary, Whistleblowing).

Embed SBC awareness in:

• Induction
• Recruitment training for panel chairs/members
• Management development programmes
• Ensure managers understand that:
• SBC deals with transparency and governance,
• OfS deals with employment procedures.

7.4 Assurance and Audit

Internal Audit may test SBC compliance (declaration completeness, timeliness, decision‑making integrity) alongside HR audits of OfS policy compliance.

HR Directors should ensure that where SBC non-compliance leads to potential misconduct, the case is managed solely under the OfS Disciplinary Policy.

Annual reports to governance groups may include:

• Trends in declarations
• Conflicts managed
• Secondary employment issues
• Cases escalated under OfS Whistleblowing or OfS Disciplinary procedures