SPONSORSHIP AND ADVERTISING POLICY. The sponsorship of external activities and external organisations sponsoring NHS Leicester City

Transcription

1 SPONSORSHIP AND ADVERTISING POLICY The sponsorship of external activities and external organisations sponsoring NHS Leicester City Reference number: Corporate 010 Title: Sponsorship and Advertising Policy - The sponsorship of external activities and external organisations sponsoring NHS Leicester City Version number: (February 2009) / Version 1, draft 6 Policy Approved by: NHS LC Trust Board Date of Approval: 25 th June 2009 Date Issued: August 2009 Review Date: Within three years of approval date Document Author: Jonathan Cross Communications Consultant Director: Karen Tiller, Acting Director of Marketing, Communications & PPI

2 Contents Page Executive Summary 3 1. Introduction 4 2. Definitions 4 3. General principles NHS Leicester City paying to promote External organisations paying NHS Leicester City General principles on sponsorship and advertising Specific areas Sponsorship of staff Sponsorship of meetings and events Personal responsibility of staff Casual gifts Hospitality Declaration of interests Outside employment Commercial Sponsorship for attendance at courses Receiving fees Equality and Human Rights Internal process Appendices Appendix 1: Establishing a Partnership Appendix 2: Sponsorship contract checklist Appendix 3: Template sponsorship approval form References 22 Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

3 Executive Summary This Sponsorship and Advertising Policy brings together a large amount of national policy and guidance to set a framework for how NHS Leicester City co-ordinates and controls sponsorship by external organisations and how we regulate our own support of external events and activities. It sets out an internal process for how we handle requests for sponsorship and advertising, including those from the pharmaceutical industry, and how we oversee our own investment in this area. The policy sets out general principles, based on national guidelines, which will govern our approach as well as providing more specific detailed areas. It also provides checklists for establishing productive partnerships with external organisations and sets out the internal process required that is necessary to monitor these agreements. It is proposed that internal approval regarding sponsorships and advertising is co-ordinated through the Marketing, Communications and PPI directorate, with additional expertise, support and guidance being obtained from elsewhere within the organisation, particularly, Medicines Management and Public Health. In following this policy, NHS Leicester City will be in a stronger position to leverage its impact on improving the health of local people, strengthening resources and enhancing relationships with key stakeholders. Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

4 1. Introduction 1.1 NHS Leicester City has a vision to improve health and improve local health services which will involve working with a range of partnership organisations to achieve Excellence for All. The organisation delivers this responsibility reflecting national and local priorities, ensuring value for money within a limited resource. Commercial sponsorship, typically but not restricted to the pharmaceutical industry, offers the potential to increase that resource. However, a range of safeguards are necessary in order to remove risk and conflict that may arise. Similarly, the organisation may wish to use resources to support or promote certain activities in the community but again strict controls are vital if tax-payers money is to be used effectively, efficiently and in the best interests of the public. 1.2 This Sponsorship and Advertising Policy sets out the local and national context for best practice when working in partnership with other organisations. It is based on a range of documents including new national guidelines such as the NHS Communications Partnership Guidelines (2007), the NHS Code of Practice for Promotion of Services (2008) and the Department of Health Best Practice Guidance on Joint Working between the NHS and Pharmaceutical Industry and Other Relevant Commercial Organisations (2008). A full list of source references is contained at the end of this paper. 1.3 This policy has been drawn up for the organisation in its role as a commissioning organisation, but the principles contained within are considered applicable to all staff in Provider Services and NHS independent contractors (GPs, dentists, pharmacists and opticians). While independent contractors are not directly employed by the organisation, they may wish to consider adopting the policy as good practice and using it as a reference source to other corporate and professional guidelines that exist (see Section Seven References). 2. Definitions 2.1 Commercial sponsorship is defined in the Department of Health paper Commercial Sponsorship ethical standards for the NHS (2000) as including: NHS funding from an external source, including funding of all or part of the costs of a member of staff, NHS research, staff, training, pharmaceuticals, equipment, meeting rooms, costs associated with meetings, meals, gifts, hospitality, hotel and transport costs (including trips abroad), provision of free services (speakers), buildings or premises. 2.2 Advertising is defined by the Chartered Institute of Marketing as: Promotion of a product, service, or message by an identified sponsor using paid-for media. Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

5 3. General principles 3.1 This section sets out a set of general principles that will govern NHS Leicester City s approach to decisions on entering into sponsorship and advertising agreements. It begins with guidelines to help inform NHS Leicester City over decisions to pay to externally promote our services or activities. It then sets out principles for when external parties wish to pay to support our activities or services. This section concludes with general principles which would cover both of these activities whether NHS Leicester City is paying for sponsorship and advertising or receiving support. NHS Leicester City paying to promote our services or activities 3.2 Guidance on advertising by the NHS is contained within the NHS Code of Practice for Promotion of Services (2008), a document aimed at providers of NHS services but one which could equally apply to commissioners. The Code focuses upon promotion and comments on how excessive expenditure could be perceived by the public, stating: Providers will be expected to recognise the potential effect on the reputation of the NHS of disproportionate expenditure on promotional activity. The cost of TV or cinema promotion is very unlikely to be justifiable. 3.3 The guidance states that in general it is not appropriate for the NHS to pay to sponsor an external activity. However, if this organisation wishes to pursue a possible opportunity, the guidance recommends the following should be considered: Whether it is justifiable to divert money from core business needs Negotiating rights and benefits of the partnership that are most useful for you Ensuring you are happy with the price of the sponsorship Making sure you maximise the use of your rights to get most benefits Other sponsors, in case they conflict with NHS aims and objectives 3.4 It is crucial that any decision for the organisation to pay to promote our services or activities through sponsorship or advertising is based on a sound business case which sets out clear objectives and proposed costs and benefits. These benefits should be for the organisation and the health of the people in Leicester City. The business case should be closely allied to the vision and priority objectives for NHS Leicester City. External organisations paying to support our activities and services Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

6 3.5 Code of Practice for Promotion of Services guidance states that for the NHS selling advertising space, for example, on the back of appointment cards, on plasma screens or in other NHS-owned spaces, is a straightforward transaction. However, the public will make assumptions about the transaction and it is recommended that consideration be given to the following: Who will see this advertising, and what message does it communicate about the relationship of the NHS to the advertiser? Who will audiences think benefits most? Have you compared the costs (time, resources etc) of selling advertising space to the benefits? Are the benefits sufficient to justify the risks? Do you risk losing control of the process by working with a third-party? A written contract should be put in place and you should consider excluding certain types of advertiser (for example, tobacco, no win, no fee solicitors, etc.) 3.6 The following national principles apply when considering undertaking sponsored activities by external organisations under the NHS Communications Partnership Guidelines (2007): NHS organisations may enter into commercial sponsorship arrangements, however they (as with other communications partnerships) should avoid entering into arrangements with organisations perceived to be in conflict with health, for example, tobacco companies. NHS organisations need to ensure they are not put under any undue obligation to a sponsor (or that they become open to the accusation), that core business functions are not affected and that they remain impartial. A written contract should be put in place. The sponsor s support should be seen as adding significant benefit to an existing health promotion message or campaign. There should be no overt commercial advantage to the sponsor in terms of the direct sale of products or brands as a result of their association with the NHS and their involvement should be seen as secondary to the aims of the NHS. The risks of being overly dependent on funding include the possibility that the sponsor withdraws support. Organisations should consider how the project would be funded if this happened. Organisations should weigh up the time taken to manage the sponsorship against the potential benefits. Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

7 3.7 There is general guidance on income generation activities within the NHS set out in the paper, NHS Income Generation guidance Best Practice (2006). Income generation covers schemes which: Must be profitable and provide a level of income that exceeds total costs. If the scheme ran at a loss it would mean that commercial activities were being subsidised from NHS funds, thereby diverting funds away from NHS patient care. However, each case will need to be assessed individually. The guidance illustrates what is meant by income generation by showing how NHS bodies might create income if the organisation had any spare capacity after delivering on core objectives. The most common such schemes quoted in the guidance relate to car parking charges, occupational health, catering services and retail outlets. The income generation guidelines with regards to sponsorship give a clear message that: NHS bodies may enter into commercial sponsorship arrangements to raise additional income, however they should avoid entering into arrangements with organisations that are perceived as being in conflict with health, for example tobacco companies. In all cases NHS bodies, members of NHS staff and independent contractors should use local arrangements to publicly declare sponsorship or any commercial relationship linked to the supply of goods or services and be prepared to be held to account for it. General principles on sponsorship and advertising which apply to NHS Leicester City for us paying for sponsorship / advertising and for external organisations paying to partner us 3.8 The Code of Conduct: Code of Accountability in the NHS (2nd rev ed, 2004), states: There are three crucial public service values which underpin the work of the health service: Accountability - everything done by those who work in the NHS must be able to stand the test of parliamentary scrutiny, public judgments of propriety and professional codes of conduct Probity - there should be an absolute standard of honesty in dealing with the assets of the NHS: integrity should be the hallmark of all personal conduct in decisions affecting patients, staff and suppliers, and in the use of information acquired in the course of NHS duties Openness - there should be sufficient transparency about NHS activities to promote confidence between the organisation and its staff, patients and the public. 3.9 As the NHS evolves and begins to work in new and different ways, there are increasing opportunities to benefit the public through working in partnership with Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

8 other organisations. Partnerships can be formed with organisations that include other parts of the NHS, local authorities, other public sector bodies, charities or commercial organisations The NHS Communications Partnership Guidelines (2007) establishes a set of general principles for working with partners including the areas of sponsorship and advertising. These principles will help NHS Leicester City make judgements on the appropriateness of partners, in cases where the Trust is approaching an organisation or responding to a partnering idea. A set of recommended questions that Trusts should ask before embarking on a partnership, whether sponsorship or advertising, is shown in Appendix One In addition, the organisation should consider the following specific set of guidelines to help staff, principally in relation to working with pharmaceutical companies: Any proposed collaboration should be without prejudice to the organisation s formal policies, financial instructions and standing orders and within the spirit and letter of Department of Health Guidance and relevant codes of practice. Any officers or other staff of the organisation taking part in collaborative working with commercial companies must in addition comply with their own professional code of conduct. All collaborations should be on the basis of a prior written agreement. The agreement shall explicitly state what resources the external organisation intends to supply and what outcomes they expect including any proposals to publicise the collaboration; what resources are expected from the organisation and what outcomes are expected by the organisation. Potential partners shall not advertise, or imply, the organisation s participation as an endorsement of their products, packages or company without the explicit written permission of NHS Leicester City. Where a company is providing drugs, materials or equipment free or below the normal NHS price as part of a clinical/research/evaluation initiative this will be accompanied by a detailed proposal drawn up in conjunction with the Public Health directorate of NHS Leicester City. Particularly this proposal will detail the plan for the continuance of prescribing beyond the period of the initiative. If there is competition in the market place a tendering process may be required as defined by the financial instructions of the organisation. Work should proceed on a project by project basis, not on the basis of an ongoing formal relationship. An opt-out clause should be part of each written agreement. Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

9 Where projects or initiatives are in areas where more than one company has an interest, these projects should where possible involve more than one sponsor. Projects with a single sponsor must be specifically indicated as such in the process for approval. The organisation shall not enter into linked deal arrangements whereby sponsorship is linked to the purchase of particular products or to supply from particular sources. Each formal collaborative project with pharmaceutical companies should be tested against the framework of this code of practice, and be considered for a process and financial audit exercise. Such proposals shall be initially submitted to the Medicines Management Team and ultimately to the Director of Marketing, Communications and PPI for consideration and, if appropriate, subsequently to the Professional Executive Committee (PEC) and/or Board for approval. The organisation shall maintain a register of all sponsorship received from commercial companies in relation to activities of the organisation. The Board at an open meeting annually prior to the closure of accounts for the financial year will formally consider this register and consider any requirements to amend this policy. The register, held by the Marketing, Communications and PPI directorate, will be made available for scrutiny on request. Relevant details will be in the Annual Report An overall view on working with the pharmaceutical industry is summarised in the Department of Health Best Practice Guidance on Joint Working between the NHS and Pharmaceutical Industry and Other Relevant Commercial Organisations (2008). This states: Joint working between the pharmaceutical industry and the NHS must be for the benefit of patients or the NHS and preserve patient care. Any joint working between the NHS and the pharmaceutical industry should be conducted in an open and transparent manner. All such activities, if properly managed, should be of mutual benefit, with the principal beneficiary being the patient. The length of the arrangement, the potential implications for patients and the NHS, together with the perceived benefits for all parties, should be clearly outlined before entering into any joint working. Further consideration of working with the pharmaceutical industry and new guidance is contained within the Royal College of Physicians publication in February 2009 of Innovating for Health: Patients, physicians, the pharmaceutical industry and the NHS (see Reference section for weblink). 4. Specific areas Sponsorship of staff 4.1 Where a staff post is funded with the help of commercial sponsorship: Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

10 The post holder should be informed the post is the subject of sponsorship and provided with details of the sponsor Requests for information by the sponsor should be made directly to the relevant directorate and responsibility for collation and disclosure does not involve the post holder Arrangements for the post will ensure against breaches of confidentiality, reduction of patient choice or compromise on the clinical judgement of the staff member. There will be no pressure on the staff member to recommend any sponsor s products or services to patients unless they are judged to be the most suitable. Sponsorship of Meetings and Events 4.2 Meetings, events or conferences organised by NHS Leicester City personnel may be sponsored by a commercial company or companies subject to the approval of the Director of Marketing, Communications and PPI. Publicity at the event by the company is allowed but should be separate from the educational content or purpose of the meeting. Promotion of the sponsor should be secondary to promotion of the event. Content of the meeting will be selected independently of the sponsor. Sponsorship of speakers and attendees should be decided independently and payment should not be arranged directly between the company and the speakers. A proper acknowledgement of the support received will be made. Personal responsibility of staff 4.3 In general, it is the responsibility of staff to ensure they are not placed in a position, which risks, or appears to risk, conflict between their private interests and their organisational duties. Under the Prevention of Corruption Acts (1906 and 1916) it is an offence for employees corruptly to accept: any gifts or consideration as an inducement or reward for doing, or refraining from doing, anything in their official capacity; or showing favour or disfavour to any person in their official capacity any money, gift or consideration received by an employee in public service from a person or organisation holding or seeking to obtain a contract will be deemed by the courts to have been received corruptly unless the employee proves the contrary. Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

11 Casual gifts 4.4 Casual gifts offered by contractors or others may not be in any way connected with the performance of duties so as to constitute an offence under the Prevention of Corruption Act. Such gifts should nevertheless be politely but firmly declined. Articles of low intrinsic value such as diaries or calendars need not necessarily be refused. In cases of doubt, staff should either consult their manager or politely decline acceptance. A register of gifts is held by the corporate office where gifts over the value of 25 must be declared. Hospitality 4.5 Modest hospitality, provided it is normal and reasonable in the circumstances, for example, lunches in the course of working meetings, may be acceptable, though it should be similar to the scale of hospitality which the NHS as an employer would be likely to offer. Staff should decline all other offers of gifts, hospitality or entertainment, in line with Section 4.4. Declaration of interests 4.6 All personnel employed by or acting on behalf of the organisation should declare any situation where they or a close relative or associate has a significant financial interest in a business or any other activity or pursuit which relates to NHS activity. The organisation will hold a register in which individuals involvement with commercial companies is recorded both on behalf of NHS Leicester City and in an independent capacity when sponsorship or payment is involved. Payment in this instance includes receipt of gifts etc. This register will be monitored via the organisation s corporate governance arrangements and held by the Corporate Office. Outside employment 4.7 NHS Leicester City personnel are advised not to engage in outside employment that may conflict with their corporate work or be detrimental to it. They are requested to make known to the Director of Finance if they think they may be risking a conflict of interest. Commercial sponsorship for attendance at courses and conferences 4.8 Acceptance by staff of commercial sponsorship for attendance at relevant conferences and courses is acceptable but only where the member of staff has had this approved by their lead Executive Director who can be satisfied that acceptance will not compromise the responsibilities and the actions of the staff member. Receiving Fees Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

12 4.9 Where working with a commercial company would normally be part of the individual's organisational role, no payment for this activity is anticipated. Staff approached to speak at commercial company sponsored events will be bound by the principles above with regard to confidentiality and conflict of interests. All such activities should be recorded on the organisation s register of interests. Concerns about potential conflicts of interest should be raised with the relevant Executive Director. Where such approaches are made, it is recommended that the guidance from the Royal College of Physicians is followed: inordinate or excessive hospitality is not accepted the invitation should be from an organisation separate from and not at the request of the sponsoring company. that fees and travelling expenses are received from the organisation hosting the event and not the company. that the purpose of the meeting is not predominantly promotional and that the educational or scientific principles are clearly outlined expenses do not extend to others beyond the speaker Equality and Human Rights 4.10 This policy has been developed with support and input from the NHS Leicester City Equality and Human Rights directorate which confirmed (January 2009) that a full Equalities Impact Assessment was not required. 5. Internal process This policy paper has summarised relevant national legislation regarding sponsorship and advertising and introduced specific local policies in this regard. In summary, the internal process for colleagues within the organisation should follow the steps set out below: Establish a business case such areas to be considered include: Why is this partnership approach relevant (see Appendix 1)? What benefits will it bring to both partners? What are the key objectives and success criteria? What is the vision of success for this partnership? What are the risks (see organisation s risk management strategy)? How can the risks be minimised? What are the true costs involved? Does the business case comply with relevant national policy relating to advertising and sponsorship? Would these proposals transgress any relevant legislation such as data protection or confidentiality issues? Will other individuals/ Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

13 teams/ organisations be affected by these plans and do you need their consent? What are the timescales involved? Who will monitor this agreement? Work through this Sponsorship and Advertising Policy (sections 3 and 4 of this policy) how does the business case fit in with recommended national guidelines? How does the case fit with any relevant professional codes of practice? If there is conflict, what changes can be made to ensure compliance? Individual/team to agree the business case with line manager/executive director where appropriate Present the business case to other individuals/teams with an interest in the initiative for approval. With projects relating to partnerships with the pharmaceutical industry, there is likely to be significant interest and input needed from the Prescribing, Medicines Management and Public Health teams. The Assistant Director of Medicines Management to consider whether case should go to the Medicines Management Committee. Complete the template sponsorship approval form (Appendix 3). Present the sponsorship approval form to the organisation s Marketing Manager for approval. The Marketing Manager may defer a decision to the Director of Marketing, Communications and Public and Patient Involvement (PPI). The Director of Marketing, Communications and PPI to consider whether the proposal needs to go to the Quality Committee (overseeing the risk management process), Provider Services Committee, Corporate Management Team, Professional Executive Committee and/or the Board for final approval. Complete any relevant purchase order/invoicing and contract (see Appendix 2) and ensure compliance with the PCT s procurement/tendering policies where appropriate Update the organisation s register of gifts (corporate office) or register of sponsorship received from commercial companies where appropriate. This register of sponsorship to be held by the Marketing, Communications and PPI directorate. Undertake the event/activity/scheme/sponsorship agreement and ensure the initiative is monitored throughout and delivers on agreed objectives Confirm payments and ensure delivery against agreed budget Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

14 Appendix 1 ESTABLISHING A PARTNERSHIP: COMMUNICATIONS PARTNERSHIP CHECKLIST - THE NHS COMMUNICATIONS PARTNERSHIP GUIDELINES (2007) This checklist highlights the key questions you should ask of any potential communications partnership. 1. What do you want to achieve? What are your objectives? Who is your target audience? What insights do you have into how they think and behave? What outcome do you want to achieve? How will you evaluate the activity to see if it has been successful? 2. Is a communications partnership the best way to achieve your objectives? Have you considered what other options are open to you? 3. Do your objectives fit with those of your potential partner? Make sure there is no conflict of interest in what you each aim to achieve. 4. Do perceptions of the partner s business and brand fit with perceptions of the NHS? Research shows that people have a gut reaction of approval or disapproval when they see the NHS in partnership with another organisation. If they perceive a mismatch between the partner s business and values and those of the NHS, they are likely to either question or reject the partnership. 5. How will your audience perceive the relationship between the NHS and your partner? In any partnership there will be benefits to both sides. However, the public expects the NHS to benefit at least equally from any partnership. The public is also generally uncomfortable with the idea of a partner being paid by the NHS. As well as considering how your target audience will perceive the partnership, you should consider how it might be perceived by the general public and the most critical audiences (such as the media). 6. Does your partnership give any organisation a commercial advantage? People expect the NHS to be fair. Be aware of the potential accusation of giving commercial advantage to one organisation over another. If you are actively looking for a partner, make sure you give all the organisations in a given field an opportunity to get involved. 7. What risks does your communications partnership present and how serious are they? Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

15 In any partnership relationship you will need to weigh up the benefits of the partnership against the potential risks; for example, the benefit of reaching a hard to reach audience via an association with a potentially controversial partner. Be aware that you may need to justify the partnership to the public, stakeholders and the media. Identifying risks up front can help you plan to deal with them. 8. Have you followed all the necessary processes? When considering a partnership you will need to ensure that you follow your organisation s own internal processes*, including the need to get the partnership signed off. Once you have decided to go ahead with a partnership, you should get a written agreement addressing key issues including costs, timings and responsibilities. 9. How will you use the NHS logo to get the most out of the partnership? The way the NHS is represented in communications has a significant impact on perceptions of both the NHS and the communications partnership. The NHS logo should always be used in accordance with the NHS identity guidelines. Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

16 Appendix 2 SPONSORSHIP CONTRACT CHECKLIST The following is a checklist of contents that should be considered for inclusion within a contract, taken from the NHS Income Generation guidance Best Practice (2006): 1. Definitions/interpretation 2. Financial Period meaning of 3. Scope of the agreement: exclusions exclusivity geography 4. What each party is contracting to do under the agreement 5. Performance Review, scope, timing, reporting 6. Powers conferred upon each party by other under the agreement if any 7. Collection and payment of any monies receivable including recovery of sums due 8. Payment periods 9. Production of Annual Audited Accounts Auditors Fees 10. Inspection of Documents for audit purposes 11. Termination by both parties including break clause 12. Payment of rates, taxes, utilities, cleaning, refuse disposal 13. Repair 14. Dispute resolution 15. Assignment and Sub-contracting 16. Insurance scope 17. Indemnity against public liability, fire etc 18. Default 19. Partnership (Does the agreement constitute a partnership?) 20. Notices (serving of) 21. Intellectual Property Rights and intellectual property rights indemnity if appropriate 22. Contract period/renewal provisions 23. Price adjustment on extension of contract period 24. Contracts (Rights of Third Parties) Act Any confidentiality or data protection requirements 26. Environmental assessment and risk management 27. Consequences of expiry or termination (including any necessary transfer provisions) 28. Equipment 29. Installation/removal of items 30. Inspection/use of premises (including security requirements) 31. Warranties and representations 32. Corrupt gifts and payments of commission 33. Discrimination and human rights 34. Force majeure Appendix Waiver 36. Variation 37. Governing law Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

17 TEMPLATE SPONSORSHIP APPROVAL FORM Name of employee leading on the sponsorship proposal Contact phone Contact Contact address Title of sponsorship proposal Name and details for proposed partner organisation(s) Description of sponsorship proposal (please attach separate sheet if necessary) Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

18 Outline of project action plan Outline of exit strategy Benefits to NHS Leicester City Benefits to the health of the local population How does this proposal fit in with the vision, values of key priorities of NHS Leicester City? Costs detail all relevant spend by the organisation or projected income from partner organisation Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

19 Are there any recurrent costs which would need to be picked up by NHS Leicester City? Risks identified and proposals to tackle any risks Have you checked your proposal against NHS Leicester City s Sponsorship and Advertising Policy? Does your proposal comply with all relevant NHS Leicester City internal policies and guidance including purchasing / tendering processes? Does your proposal comply with all relevant national legislation covering issues such as data protection, confidentiality etc? Does your proposal need approval from other personnel within NHS Leicester City other than the signatories below? Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

20 I know of no potential embarrassment that would accrue to NHS Leicester City as a result of this proposal. Signed by originator of sponsorship proposal. Signature: Date: The following agree to support the proposal Signature of line manager / executive director: Date: Signature of Assistant Director of Medicines Management (if project pharma related): Date: Signature of Marketing Manager / Director of Marketing, Communications and PPI: Date: Date of internal committee / PEC / Board which is to consider the proposal if deemed necessary by any of the above signatories. Date: Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21

21 7. References Website links are as follows: Chartered Institute of Marketing Code of Conduct: Code of Accountability in the NHS (2nd rev ed, 2004) dguidance/dh_ Department of Health Best Practice Guidance on Joint Working Between the NHS and Pharmaceutical Industry and Other Relevant Commercial Organisations (2008) Department of Health paper Commercial Sponsorship ethical standards for the NHS (2000) s/digitalasset/dh_ pdf NHS Code of Practice for Promotion of Services (2008) NHS Communications Partnership Guidelines (2007) NHS Income Generation guidance Best Practice (2006) dguidance/dh_ Royal College of Physicians (February 2009) Innovating for Health: Patients, physicians, the pharmaceutical industry and the NHS Pharmaceutical-Industry.aspx Standards of Business Conduct for NHS Staff (1993) This circular on Standards of Business Conduct for NHS Staff was issued in 1993 (HSG(93)5) regarding the general standards which should be maintained by staff working in the NHS. eguidelines/dh_ Sponsorship and Advertising Policy Version 1, Draft 6 Page of 21