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Anti-fraud and bribery

The Tavistock and Portman NHS Foundation Trust recognises that bribery is an illegal and hugely damaging practice that causes waste and misuse of public funds and undermines the reputation of the Trust and the wider NHS.

This statement demonstrates the Trust’s commitment to reducing fraud, bribery and corruption. The Trust is committed to delivering good governance and has always expected its Trust Board members and staff to meet the highest standards of business conduct. The Trust expects staff to act with integrity and we will not tolerate bribery and corruption.

The Bribery Act 2010 came into force on 1st July 2011 and the aim of the Act is to tackle bribery and corruption in both the private and public sectors. The Act defines the following key offences with regards to bribery:

  • Active bribery (offering, promising or giving a bribe);
  • Passive bribery (requesting, agreeing to receive, or accepting a bribe); and
  • Bribery of a foreign public official.

The Act also sets out a corporate offence of failing to prevent bribery by an organisation not having adequate preventative procedures in place.

The Tavistock and Portman NHS Foundation Trust has a set of robust controls, and procedures in place to prevent fraud, corruption or bribery. The Trust’s Local Counter Fraud Specialist (LCFS) can be contacted if staff have any concerns of fraud, corruption or bribery. The Trust also has an annual plan to mitigate the risks of fraud, corruption, and bribery.

The Trust has an anti-fraud, bribery and corruption procedure that sets out measures designed to prevent acts of bribery or corruption. This procedure has been created with reference to the Bribery Act 2010. Additionally, the Trust has policies that govern how conflicts of interest are declared and managed, how staff can raise concerns under the ‘Freedom to Speak Up’ process, as well as Standing Financial Instructions and Standing Orders which set out how the Trust procures and pays for goods and services.

One of the six principles of the Act requires that there is top level commitment in the organisation for preventing bribery. The Tavistock and Portman NHS Foundation Trust is committed to ensuring compliance with the Act and discussions have been held at both the Trust Board and its Integrated Audit and Governance Committee to ensure that the requirements of the Act are fully complied with.

The Trust believes a zero-tolerance approach towards bribery supports our reputation for honesty and ethical practice and instils confidence in our service users and the wider public. The Trust would like to re-affirm its commitment to ensuring that the Trust is free from fraud, corruption, or bribery and that all staff are aware of their responsibilities in relation to the prevention of fraud, corruption or bribery.

The Trust procures goods and services ethically and transparently with considerations around quality, price and value for money the sole determinants for the successful supplier / contractor., No person representing the Trust or involved in the procurement of goods or services may accept any bribe or other inducement, either personally or on behalf of the organisation to influence any procurement decisions.

Read our anti-fraud and bribery procedure for further information.

Reporting concerns

Any information about suspicions of fraud, bribery, or corruption can be reported to:

The LCFS, who implements the NHS Counter Fraud Strategy within the Trust. All concerns reported will be treated in the strictest confidence and any information will be professionally assessed and evaluated.

Local Counter Fraud Specialist: Kirsty Clarke,

Email: Kirsty.clarke@rsmuk.com / Kirsty.clarke8@nhs.net

Alternatively, you can pass the information to:

The NHS Counter Fraud Authority at www.cfa.nhs.uk/reportfraud or by calling 0800 028 4060 (available 24/7).