Chief Executive’s Statement on Bribery and Corruption
The Bribery Act 2010
1. Introduction
The Bribery Act 2010 came into force on 1st July 2011, with the aim of tackling bribery and corruption in both the public and private sector.
All NHS organisations need to consider the impact of the Bribery Act carefully and take appropriate action to ensure that ‘adequate procedures’ are in place to prevent bribery or corruption in their organisation.
Staff should report any suspicions or allegations of fraud, bribery or corruption by one of the following methods:
- Via your Counter Fraud manager. The LCFS for Blackpool Teaching Hospitals NHS Foundation Trust is John Marsden and his contact number is 01253 953232 or via email
- Via the Trust’s Freedom to speak up: raising concerns (whistleblowing) policy;
- Via the NHS Fraud and Corruption Reporting Line on 0800 028 40 60;
- Via the online fraud reporting facility
Bribery and corruption is generally defined as giving someone a financial incentive, gift, favour, payment, benefit in kind or any other advantage to encourage a person to perform their functions or activities improperly or to reward that person for having already done so.
- The Act introduces new bribery offences, which are detailed as follows:
- To give, promise or offer a bribe;
- To request, agree to receive or accept a bribe, either in the UK or overseas;
- A corporate offence of failure to prevent bribery by persons working on behalf of a commercial organisation.
Organisations that are found guilty under the Act could face a large fine and imprisonment of the individuals involved.
However, an organisation can avoid conviction if it can show that it has “adequate procedures” in place to prevent bribery. What counts as “adequate” will depend on the bribery risks that the organisation faces and the nature, size and complexity of the organisation.
As a result, I can confirm that Blackpool Teaching Hospitals NHS Foundation Trust will commit sufficient time and resources to the development and embedding of an appropriate anti-bribery and corruption programme, which will include:
- A commitment to carry out business fairly, honestly and openly;
- A commitment to zero tolerance towards bribery and/or corruption;
- Acknowledging the consequences of breaching the policies for employees and managers and Trust Board members;
- To support key individuals and departments involved in the development and implementation of the Trust's bribery and corruption prevention procedures
2. Application of the Act
As a responsible employer, Blackpool Teaching Hospitals NHS Foundation Trust has a duty to ensure that all staff are aware of the risks associated with accepting a bribe.
As the Bribery Act became law on the 1st of July 2011 all staff are reminded of the expected standards of honesty, integrity and transparency, including the need to declare all gifts, hospitality, secondary employment etc.
All employees need to declare any conflict of interest and all Directors, senior management or “decision makers” have to make an appropriate declaration, even if that declaration is a “nil” declaration.
There are 11 types of declarations, plus a nil declaration option, and a register is kept of all declarations and I would encourage any staff member needing further information to contact the Trust’s Counter Fraud manager.
The declaration process will be an electronic system and will be available from June 2019 onwards, when information as to how to make a declaration will be cascaded to all staff.
It is essential that staff are aware of the standards of behavior that is expected of them. These standards are detailed within Trust policies and represent the ethics, professional conduct and probity standards that is required of all employees.
There are 11 different types of declaration, for example, staff are required to declare offers of hospitality, receipt of gifts, secondary employment, private practice and any financial interest in a business that has a commercial or sponsorship connection to to Blackpool Teaching Hospitals NHS Foundation Trust.
NOTE: The Declaration of Interests (Loyalty) extends to staff member’s spouse/ partner or close family member.
3. Further Information
The Counter Fraud manager has created a Bribery and Corruption page within the counter fraud area of the intranet. The site contains a number of informative documents and has recently been updated to take into account the Standards of Business Conduct policy, a number of associated guidance notes, general advice (including an explanation on adequate procedures to prevent bribery and corruption) and a number of new bribery and corruption videos that explains bribery and corruption in the workplace.
The link to the Bribery and Corruption Intranet page.
All staff are strongly encouraged to visit the Bribery and Corruption Intranet page and familiarise themselves with information contained therein.
Trish Armstrong-Child Chief Executive
