Introduction

The Department of Public Expenditure and Reform’s “Code of Practice for the Governance of State Bodies” (August 2016) requires all public bodies to have a written Code of Conduct for the Chief Executive and staff*.  The following code sets out in written form the agreed standards of principle and practice that should inform the conduct of the Chief Executive and staff of the HRB in the performance of their duties. 

A copy of this Code of Business Conduct is given to all staff when they start work at the HRB and they are required to confirm that they have read and understood this Code and will comply with it.  This Code is made available on the HRB’s website and a copy can be provided directly to any member of the public who requests it.

This Code is reviewed on a regular basis.

About the HRB

The Health Research Board (HRB) current stated mission is

 To support research that improves people’s health, promotes evidence-informed care and creates solutions to societal challenges

The HRB’s values are:

• Leadership
• Independence
• Accountability
• Quality
• Responsiveness
• Collaboration
• Inclusiveness

Objective of this Code

In many cases the decisions as to what is ethical or fair are clear-cut and will be obvious to a reasonable person.  There may be circumstances, however, in which a doubt or ambiguity arises.  This written Code of Business Conduct is designed to assist in those circumstances and as a guide by which the Chief Executive and individual staff may observe the highest standards of ethical behaviour.

It is not possible to provide for every situation in the Code of Business Conduct.  If there is a doubt about the probity of any particular situation the Chief Executive should consult with the Chairperson, and individual staff should consult with their line managers, Chief Executive or the Chairperson where appropriate.

General Principles

The Chief Executive and staff should observe to highest standards of honesty and integrity.  To ensure this they should adhere to the following principles:

Integrity

The Chief Executive and staff should

Conform to the procedures laid down in the Health Research Board (Establishment) Order 1986 (S.I. NO. 279 of 1986) as amended in relation to conflicts of interest which states

13. (1) Where a member of the Board, the Chief Executive, an employee of the Board, a member of a committee or any other person engaged by the Board has a pecuniary or other beneficial interest in, or material to, any matter which falls to be considered by the Board or a committee of the Board, he or she shall comply with the following requirements:

1. he or she shall disclose to the Board or committee the nature of his or her interest in advance of any consideration of the matter,
2. he or she shall neither influence nor seek to influence a decision in relation to the matter,
3. he or she shall take no part in any consideration of the matter,
4. he or she shall withdraw from the meeting for so long as the matter is being discussed or considered by the Board or committee and shall not vote or otherwise act as a member, Chief Executive or employee in relation to the matter

(2) For the purposes of this article, but without prejudice to the generality of sub article (1), a person shall be regarded as having a beneficial interest if:

1. he or she or any member of his or her household, or any nominee of his or her or any member of his or her household, is a member of a company or any other body which has a beneficial interest in, or material to, a matter referred to that sub article,
2. he or she or any member of his or her household is in partnership with or is in the employment of a person who has a beneficial interest in, or material to, such matter,
3. he or she or any member of his or her household is a party to any arrangement or agreement (whether or not enforceable) concerning land to which such a matter relates,
4. any member of his or her household has a beneficial interest in, or material to, such a matter

(3) For the purposes of this article a person shall not be regarded as having a beneficial interest in, or material to, any matter by reason only of an interest of his or her or of any company or of any other body or person mentioned in sub article (2) which is so remote or insignificant that it cannot reasonably be regarded as likely to influence a person in considering, discussing or in voting on, any question with respect to the matter, or in performing any function in relation to that matter.

(4) Where a question arises as to whether or not a course of conduct, if pursued by a person, would be a failure by him or her to comply with the requirements of sub article (1), the question shall be determined by the Chairperson.

(5) Where a disclosure is made to the Board or committee pursuant to sub article (1), particulars of the disclosure shall be recorded in the minutes of the meeting concerned.

(6) The Board may adopt additional rules in relation to members, the Chief Executive, staff and members of committees to prevent a conflict of interest in the carrying out of the Board’s functions.

• The Chief Executive and all staff who are holders of designated posts (i.e. members of the Executive Team and certain members of the Management Team) submit annually a declaration in compliance with Standards in Public Office legislation
• Avoid the giving or receiving of corporate gifts, hospitality, preferential treatment or benefits which might appear to affect the ability of the donor or the recipient to make independent judgement on business transactions
• Ensure that purchasing activities of goods/services is in accordance with Public Procurement Guidelines issues by the Office of Government Procurement
• Support a culture of claiming expenses only as appropriate to business needs and in accordance with good practice in the public sector generally
• Ensure that the HRB’s accounts and annual reports accurately reflect business performance and are not misleading or designed to be misleading
• Avoid the use of the HRB’s resources or time for personal gain, or for the benefit of persons / organisations unconnected with the HRB or its activities
• Not acquire information or business secrets by improper means

Information

The Chief Executive and staff should

Support the HRB’s provision of access to general information relating to the HRB’s activities in a way that is open and enhances the HRB’s accountability to the general public

Respect the confidentiality of sensitive information held by the HRB.  This would constitute material such as

Commercially sensitive information (including but not limited to future plans or details of major organisational or other changes such as restructuring)

Personal information and

Information received in confidence by the HRB

Observe appropriate prior consultation procedures with third parties where, exceptionally, it is proposed to release sensitive information in the public interest

Comply with relevant statutory provisions relating to access to information including the General Data Protection Regulations (GDPR), Data Protection Acts and Freedom of Information Acts.

Obligations

The Chief Executive and staff should

Fulfil all regulatory and statutory obligations imposed on the HRB

Comply with detailed tendering and purchasing procedures as set out in the Public Procurement Guidelines issued by the Office of Government Procurement as well as complying with prescribed levels of authority for sanctioning any relevant expenditure

Ensure that there are adequate controls in place to prevent fraud including controls to ensure compliance with prescribed procedures in relation to claiming expenses for business travel

Acknowledge the duty of all to conform to the highest standards of business ethics

Loyalty

The Chief Executive and staff should

Acknowledge the responsibility to be loyal to the HRB and fully committed to all of its business activities while mindful that the HRB itself must at all times take into consideration the interests of the State and of its clients/stakeholders

Fairness

The Chief Executive and staff should

Comply with employment equality and equal status legislation

Commit to fairness in all business dealings

Value clients/stakeholders and treat all clients/stakeholders equally

Professionalism

When dealing with stakeholders, the Chief Executive and staff should be service-minded, courteous and accessible.  The HRB’s Customer Charter which is published on the HRB website outlines the standard of service that stakeholders may expect when contacting the HRB.

The Chief Executive and staff should follow the HRB’s policies and procedures at all times unless there are legitimate grounds for department from them in an individual case.

Work/External Environment

The Chief Executive and staff should

• Place highest priority on promoting and preserving the health and safety of fellow staff;
• Ensure that community concerns are fully considered; and
• Minimise and detrimental impact of the operations on the environment.

*For the purposes of this Code the term ‘Staff’ includes all employees of the HRB, temporary agency staff assigned to work at the HRB and HRB interns.