The Bribery Act 2010 came into effect on 1st July 2011 with the aim of tackling bribery and corruption in both the private and public sectors. Bribery is generally defined as the giving or receiving of a financial or other advantage in exchange for improperly performing a relevant function or activity. The maximum penalty for bribery is 10 years imprisonment, with an unlimited fine.
NHS Digital is a publicly funded organisation and is committed to applying the highest standards of ethical conduct and behaviour which includes having robust controls in place to prevent fraud, bribery and corruption. However, as an organisation we cannot afford to be complacent and under no circumstances is the giving, offering, receiving or soliciting of a bribe acceptable and NHS Digital therefore adopts a zero tolerance approach to all forms.
In order to minimise the risk of unfounded allegations of bribery or corruption, if staff are offered hospitality or gifts or are considering offering any to another person they should refer to current policy for details of the circumstances in which this would be acceptable and the level which can be given or received; advice can be sought from Governance and Compliance if required. Staff are reminded that all hospitality and gifts received, offered or declined should be declared using the form accessible from the policy and eStore.
Staff members with suspicions that fraud, bribery or corruption might be taking place should report it to the NHS Digital Fraud Manager. Further details on how to raise a concern can be found in the Anti-Fraud, Bribery and Corruption Policy. Reports can also be made anonymously and further information is contained within the whistleblowing policy.
NHS Digital expects its suppliers and those working on its behalf, to adhere to these standards and may seek to terminate contracts with any suppliers found by a court of law to have been guilty of corruption.
The success of the organisation’s anti-fraud, bribery and corruption measures depends on all employees, and those acting for the organisation playing their part in helping to prevent, detect and deter fraud, bribery and corruption.
Chief Financial Officer