Bribery Act statement

Kent and Medway NHS and Social Care Partnership trust recognise that bribery is a hugely damaging practice that undermines competition and the reputation of public and private bodies involved.

This statement demonstrates the trust commitment to preventing bribery. The trust is committed to delivering good governance and has always expected its directors 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 1 July 2011 and the aim of the Act is to tackle bribery and corruption in both the private and public sector. The Act defines the following key offences with regard 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.

Kent and Medway NHS and Social Care Partnership trust has a set of robust controls, policies and procedures in place to prevent fraud, corruption or bribery. The trusts Counter Fraud Specialist can be contacted if staff have any concerns of fraud, corruption or bribery and the trust has an annual plan to mitigate the risks of fraud, corruption and bribery.

The trust has an Anti-Fraud, Bribery and Corruption Policy and guidance available to staff on the intranet that sets out procedures designed to prevent acts of bribery or corruption. This policy has been created with reference to the Bribery Act 2010 and with support from the Local Counter Fraud Specialist. Additionally the trust has policies that govern Standards of Business Conduct, Standing Financial Instructions and Standing Orders, Gifts and Hospitality, Disciplinary procedures and Whistleblowing as well as a Freedom to Speak Up Guardian.

One of the six principles of the Act demands that there is top level commitment in the organisation for preventing bribery. Kent and Medway NHS and Social Care Partnership trust is committed to ensuring compliance with the Act and discussions have been held at both the Board and its Audit 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 patients 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. If you have any concerns or queries in relation to this statement or our procedures in respect to bribery prevention please contact us.

Do you have concerns about a fraud or bribery taking place in the NHS?

NHS Fraud, Bribery and Corruption Reporting Line: 0800 028 40 60 calls will be treated in confidence and investigated by professionally trained staff. Online: www.reportnhsfraud.nhs.uk

Our nominated Counter Fraud Specialists are, David Kenealy NHS Counter Fraud Manager 07580 164709 david.kenealy1@nhs.net, Andrew Ede NHS Local Counter Fraud Specialist 07814 285 177 andrew.ede1@nhs.net or Cliff Cowell NHS Local Counter Fraud Specialist 0779 886 1481 cliff.cowell@nhs.net