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Chief Executive Statement - Bribery Act

Papworth Hospital NHS Foundation Trust (Papworth Hospital) is committed to applying the highest standards of ethical conduct and integrity in its business activities in the UK and overseas.  Every employee and individual acting on behalf of Papworth Hospital is responsible for maintaining the organisation’s reputation and for conducting Trust business honestly and professionally.

Papworth Hospital considers that bribery and corruption has a detrimental impact on Trust business by undermining good governance.  We benefit from carrying out our functions in a transparent and ethical way and helping to ensure that there is honest, open and fair competition in the NHS.  Where there is a level playing field, Papworth Hospital can lead by example and deliver excellent services to our patients.

Transparent, fair conduct helps to foster deeper relationships of trust between Papworth Hospital and our partners.  It is vital for our reputation and future growth.  Papworth Hospital does not tolerate any form of bribery, whether direct or indirect, by, or of, its staff, agents or consultants or any persons or entities acting for it or on its behalf.  The Board and senior management are committed to implementing and enforcing effective systems throughout Papworth Hospital to prevent, monitor and eliminate bribery, in accordance with the Bribery Act 2010.

Papworth Hospital has issued revisions to key policies/procedures including, the Standards of Business Conduct, Standing Orders and Standing Financial Instructions outlining our position on preventing and prohibiting bribery.  The provisions in these policies/procedures apply to all employees, as well as agency workers, consultants and contractors acting for on behalf of the Trust.
 
A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.  Employees and others acting for or on behalf of the organisation are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments.

As part of its anti-bribery measures, the organisation is committed to transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure.  Such expenditure must be authorised in advance, in accordance with the procedures set out in the organisation’s policies. A breach of the organisation’s Standards of Business Conduct procedure by an employee will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct, and immediate dismissal.  Employees and other individuals acting for the organisation should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for the organisation.

Papworth Hospital will not conduct business with service providers, agents or representatives that do not support the organisation’s anti-bribery objectives.  We reserve the right to terminate  contractual arrangements with any third parties acting for, or on behalf of, the organisation with immediate effect where there is evidence that they have committed acts of bribery.

The success of the organisation’s anti-bribery measures depends on all employees, and those acting for the organisation, playing their part in helping to detect and eradicate bribery. Therefore, all employees and others acting for, or on behalf of, the organisation are encouraged to report any suspected bribery to their Head of Department, Director of Finance, the Trust Local Counter Fraud Specialist or through the Trust’s Whistleblowing Policy.  Papworth Hospital will support any individuals who make such a report, provided that it is made in good faith.

 

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