Policy on Supplier Representatives Policy author Matthew Revell Accountable Executive Lead Jonathan Lofthouse Approving body Policy reference ROH/XXX/NNN [Assigned by Governance Team] POLICY APPROVAL DATE: ESSENTIAL READING FOR THE FOLLOWING STAFF GROUPS: May 2017 1 – All Trust Staff working in Theatres and Pharmacy POLICY 2 – Staff working in partnership with supplier IMPLEMENTATION DATE: representatives June 2016 DATE POLICY TO STAFF GROUPS WHICH SHOULD BE AWARE OF THE POLICY FOR BE REVIEWED: REFERENCE PURPOSES: June 2017 1 – Staff involved with purchasing or procurement DOCUMENT CONTROL AND HISTORY Version Date Date of Next Reason for change (e.g. full rewrite, No Approved implementation Review amendment to reflect new legislation, Date updated flowchart, etc.) 1 June 2017 New Policy Policy on Supplier Representation April 2017 2 | P a g e Policy on Supplier Representatives KEY POINTS 1. Supplier Representatives must not enter any area without an appointment. 2. Supplier Representatives must be registered on the Medical Industry Accredited System. 3. If the meeting is to discuss ANY new product or service then Procurement and Supplies must be informed. 4. Cold calling is not acceptable. 5. Pharmacy representatives must report to Pharmacy. 6. No electro-medical equipment can be used until tested by EBME. 7. Representatives visiting Theatre areas must comply with the Theatre protocol. 8. No sample products can be trialed until the appropriate trials and indemnity documentation has been completed. 9. Contractors undertaking work on the Trust’s sites must adhere to the Control of Contractors Policy. Do’s and Don’ts Do meet the supplier representative at an arranged point and don’t allow them to wander around clinical areas unaccompanied. Do challenge any supplier representative that you see in an area, ask for ID and the purpose of their presence. Don’t allow supplier representatives into stock rooms unaccompanied. Don’t provide any commercial information to a supplier’s representative – always refer them to Procurement and Supplies. Don’t allow trial equipment or products to be brought in without the appropriate trials and indemnity document has been completed. Don’t sign any contract or agreement that a supplier representative brings – refer them to Procurement and Supplies. Don’t accept gifts or hospitality without declaring on the Hospitality Register and gaining approval. PLEASE NOTE THAT THIS LIST IS DESIGNED TO ACT AS A QUICK REFERENCE GUIDE ONLY AND IS NOT INTENDED TO REPLACE THE NEED TO READ THE FULL POLICY Policy on Supplier Representation April 2017 3 | P a g e Policy on Supplier Representatives Contents Page Number 1. Introduction 5 2. Scope 5 3. Other policies to which this policy relates 5 4. Glossary and definitions 5 5. Policy development principles 5 6. Roles and responsibilities 5 7. Procedure 6 8. Consultation 6 9. Auditable standards/monitoring effectiveness 6 10. Training and awareness 12 11. Inclusion 12 12. Review 12 13. Reference documents and bibliography 12 14. Further enquiries 12 APPENDICES Appendix A Example of Third Party Paid Expenses Form 13 Appendix B Medical Industry Accredited Systems 13 Appendix C MIA Publicity Poster for ROH 33 Appendix D Draft section from Theatre Guidelines 34 Appendix E Map of Theatre Complex 40 Appendix F Equality Impact Assessment Template 43 Appendix G Policy Implementation Plan 50 Policy on Supplier Representation April 2017 4 | P a g e Policy on Supplier Representatives 1.0 INTRODUCTION The Trust appreciates the role that it’s current and potential suppliers play in supporting health practitioners in providing safe, effective and economic products and services to the patients in their care, and other staff working within the NHS in the delivery of their duties. This policy and any accompanying procedure will be available to Trust personnel through the Document Library and supplier personnel via the Procurement and Supplies Department. This version supersedes any previous versions of this document. The aim of this policy is to ensure a sound, transparent and professional relationship between the staff of the Trust and its suppliers and their commercial representatives. It provides information on how they are expected to behave and what behavior they can expect from the Trust’s staff; clinical and non-clinical. 2.0 SCOPE 2.1 The policy covers all areas of the Royal Orthopaedic Hospital (the Trust) and all premises that the Trust operates from. All staff of the Trust should be aware of this Policy. 3.0 OTHER POLICIES TO WHICH THIS POLICY RELATES 3.1 Control of Contractors Policy Theatre Policy and Standards 2016 (under revision) Incident Reporting Policy Counter Fraud Policy 4.0 GLOSSARY AND DEFINITIONS 4.1 Supplier Representatives means all supplier personnel. MIA - Medical Industry Accredited System 5.0 PRINCIPLES 5.1 This policy formally defines the responsibilities of the Trust and of its supplier representatives working together in the interests of patients. Supplier representatives will be required to pre-book for visits to the Trust and to have a defined purpose in attending. The Trust will also gain assurance on Medical Industry Accredited system issues which are handled by the MIA system. Suppliers will have the opportunity to review relevant Trust Policy on the web so as to be better placed to comply with the Trust’s ways of working. 6.0 ROLES AND RESPONSIBILITIES Policy on Supplier Representation April 2017 5 | P a g e 6.1 Role of the Director of Finance The Director of Finance has overall responsibility for ensuring good procurement practice throughout the Trust. 6.2 Role of the Head of Procurement and Divisional General Manager The Head of Procurement and Divisional General Manager is responsible for ensuring that Supplier Representatives are made aware of this policy, and for monitoring compliance of the reporting requirements contained within the Policy. 6.3 Role of Trust Managers and Budget Holders Trust Managers are responsible for ensuring that all staff are aware of the policy and adhere to the requirements contained within it. 6.4 Role of the Medical Devices Advisory Group The Group is responsible for: Receiving feedback on the effectiveness of the policy Reviewing content and updating the policy as required 6.5 Roles of individual staff 6.6 All staff members are responsible for: Adherence to the policy Promoting the policy to supplier representatives and Trust colleagues Notifying the Head of Procurement or Divisional General Manager when they become aware of the policy not being followed 7.0 PROCEDURE 7.1 All supplier representatives are required to register with the Medical Industry Accreditation (MIA) programme. This provides the Trust with assurances about the health status and personal record of the individual. 7.2 Relevant Trust Policies, Standards and Procedures will be uploaded to the MIA website and supplier representatives are required to comply with them 7.3 Supplier representative visits must be pre-arranged with the relevant unit manager prior to attendance on site 7.4 Once on site supplier representatives must present themselves at the agreed contact point where a named member of staff will be responsible for ensuring the visit is safe and mutually beneficial. 7.5 All visits must be recorded on the MIA website. 7.6 Any hospitality offered to staff must be declared. 8.0 CONSULTATION 8.1 Theatre Management Team Pharmacy Management Team Division 2 Board 9.0 AUDITABLE STANDARDS/PROCESS FOR MONITORING EFFECTIVENESS 9.1 Visits to the hospital Policy on Supplier Representation April 2017 6 | P a g e 9.2 Supplier Representatives will NOT be seen by Trust staff without prior appointment. ‘Cold calling’ is an inefficient use of staff and suppliers’ time – it is not permitted. All supplier representatives must be registered on the Medical Industry Accredited (MIA) system, details of which are attached at Appendix B. All contractors undertaking work on the Trust sites must adhere to the Trust’s Control of Contractors Policy. 9.3 Any Supplier Representative attempting to visit a Trust designated contact without having made a prior appointment should be politely but firmly refused and advised to call and make an appointment and register on the Medical Industry Accredited system. 9.4 When on site, all representatives are expected to comply with the Health and Safety at Work Act, as well as all Trust policies, procedures or guidance, as relevant at the time; e.g. the no smoking policy, the car parking policy etc. 9.5 Supplier Representative must wear a name badge showing the name of the company they are representing as well as their own name. 9.6 When on site, all representatives must comply with any instructions given to them by an authorised member of staff (e.g. in the event of an emergency situation such as a fire or major incident). 9.7 Supplier representatives should note that the Trust has an Incident Reporting Policy. Should anyone be affected (patient, staff, student, visitor, volunteer or contractor) by any behavioural actions from a commercial representative, an Incident Report will be raised and appropriate action taken by the Trust’s Senior Management. This is also the case should a representative be affected by any behavioural actions from a member of the Trust’s staff, a student, visitor, volunteer or contractor. Under the MIA agreement, the Trust reserves the right to make an entry on the individual MIA record of a representative, if necessary. 9.8 Appointments must be made via the appropriate departmental secretary or a Trust host directly. Any literature, product information or samples for consideration must be left with the host or with a representative of the Procurement and Supplies Department. 9.9 Any supplier representative wishing to visit a clinical area must obtain the prior consent of either the Clinical Service Manager, Clinical Service Lead, Matron or their appointed nominee(s), and must register the visit on the Medical Industry Accredited system.