Anti-Fraud and Bribery Statement
We all have a responsibility to ensure the administration of public funds for the purpose of providing healthcare to the community we serve is carried out in an ethical manner. Fraud and Bribery have a detrimental effect and prevent us from providing the best quality services to our service users.
Our zero tolerance stance and tone is set out at the top of our organisation demonstrating that we take these threats seriously, as reflected in the Anti-Fraud, Bribery and Corruption policy (hyperlink to policy) ensuring we cultivate an Anti-Fraud and Bribery culture across our whole organisation.
The Governing Body and the Senior Management team recognises bribery is a practice that undermines the integrity of competition and the reputation of public and private bodies involved. We will uphold all laws relevant to countering bribery and corruption including those under the Bribery Act 2010 in respect of every aspect of our business. We are committed to ensuring our employees are trained appropriately in stopping and identifying risks of Bribery and we will regularly review our training to ensure it is relevant and current.
Any act of Bribery undertaken by a member or an employee will be treated extremely seriously.
We require that all contractors instructed by the CCG demonstrate a commitment to Bribery prevention in order to conduct business with us. This is both to ensure that public funds are protected and also to give the public confidence in our procurement process.
Our zero tolerance approach towards Fraud and Bribery supports our reputation for honesty and ethical practice. To demonstrate our commitment to prevent Fraud and Bribery from affecting our organisation, we contract with TIAA Limited to help us develop and implement our Anti-fraud, and Bribery corruption prevention procedures.
The role of TIAA includes regular monitoring and review of key relevant policies and procedures.
Suspicions of fraud and bribery can be referred by staff, patients, visitors or any others in instances where the NHS may have been defrauded either internally or externally. Every report we receive will be robustly investigated. We are committed to treating those who raise concerns with respect and will not tolerate retaliation against those who make a report in good faith.
What are Fraud and Bribery?
The Fraud Act 2006 makes it an offence for someone to make a false representation, fail to disclose information, or abuse a position, in order to make a gain or cause a loss.
Common frauds in the NHS include:
- Staff, contractors or agency workers falsifying timesheets or expense claims, using false qualifications, references or work history on applications and working whilst on sick leave.
- Patients altering prescriptions or receiving free NHS care to which they are not entitled.
- Duplicate or overinflated invoices submitted by suppliers, suppliers engaging in price fixing and suppliers falsifying performance records to inflate invoice value.
- Decision makers failing to declare an interest in a firm competing for a contract.
- Bogus invoices submitted by fraudsters and fake companies.
The Bribery Act 2010 defines a bribe as “a financial or other advantage” offered or received in return for “performing a relevant function improperly”. It is a criminal offence to accept, promise, offer or make a bribe.
Some examples of bribery payments:
- to secure or keep a contract / order.
- to gain an advantage over a competitor.
- to turn a blind eye.
- to prescribe or favour a particular drug or medical equipment supplier.
- to queue-jump waiting lists.
Under the Bribery Act it is also a corporate offence if the CCG cannot demonstrate they had “adequate procedures in place to prevent a bribe”.
How to Raise Concerns
If you have concerns about fraud, corruption or bribery in the NHS, information should be given directly to the CCG’s Local Counter Fraud Specialist or the CCG's Responsible Officer:
Lisa George, Counter Fraud Specialist:
- Email: lisa.george [at] tiaa.co.uk or lisa.george4 [at] nhs.net
- Mobile: 07825 827024
Helen Stratton, Chief Finance Officer & CCG's Responsible Officer:
- Email: helen.stratton [at] nhs.net
- Phone: 01603 595859
All allegations will be thoroughly and professionally investigated. If you feel unable to report your suspicions internally you may also raise your concerns with:
- NHS National fraud and Corruption Hotline: 0800 028 4060
- Public Concern at Work: 0207 404 6609
- NHS Whistleblowing Helpline: 08000 724 725
- Action Fraud: 0300 123 2040.
All calls are dealt with in the strictest of confidence and callers may remain anonymous if they prefer.