NHS Blood and Transplant People First

Anti-fraud, Bribery and Corruption

NHSBT is committed to the prevention, deterrence and detection of fraud, bribery and corruption and maintaining an honest, open and well-intentioned culture. We have a zero tolerance to any such acts and we expect those organisations we work with to do the same. We are committed to its elimination and the rigorous investigation of cases and ensuring that appropriate sanctions for redress are pursued. This includes the use of criminal and civil law to fully recover any losses and the publication of cases.

The NHSBT Anti-fraud Bribery & Corruption policy applies to all employees including executive and non executive directors; agency workers and volunteers; it includes suppliers, members of the public and external stakeholders e.g. contractors. Also see the FAQ document for further information.

As part of Corporate governance compliance and transparency, NHSBT employees should identify and declare material interests (including gifts and hospitality) at the earliest opportunity for further information see below.

Bribery and Corruption

Bribery is a criminal offence. We do not, and will not, pay or accept bribes to offer improper inducements to anyone for any purpose.

Bribery offences include:
• bribery of another person
• accepting a bribe
• bribing a foreign official
• failing to prevent bribery

If we believe an individual has acted for personal gain, this will be investigated under the Disciplinary Policy and, if appropriate, may be referred to the police for criminal investigation and prosecution.

Fraud

To prevent fraud, we have strong systems of internal control which are reviewed by internal audit and NHS Protect; we continuously assess the risk of fraud, which is managed through the annual Counter Fraud plan.
We all have a responsibility to report suspected fraud; we will investigate cases and manage proven cases.

Common types of fraud can be and include*:
• Travelling and Subsistence Allowances
• Pay Related
• Procurement
• Personnel Management
• Payment Processes
• Income related
*This list is not exhaustive.

It is important that no employee suffers or is disadvantaged as a result of their suspicions. Victimisation or deterring employees from reporting their concerns, and the raising of malicious allegations will be investigated and managed under the Disciplinary Policy.

Reporting Potential Fraud

If you believe you have good reason to suspect an employee, donor, patient or other person of fraud or an offence involving NHSBT, you should contact one of the following:

· NHSBT Local Counter Fraud Specialist – 0113 820 5937 (internal 55937)

· NHS Protect - 0800 028 40 60

· HR Direct- (2)7700

It is important that no employee suffers or is disadvantaged as a result of their suspicions. Victimisation or deterring employees from reporting their concerns, and the raising of malicious allegations will be investigated and managed under NHSBT’s Disciplinary Policy

Declaration of interests (including gifts and hospitality)

NHSBT employees need to be transparent and declare interests, gift and hospitality. If you have any interest, gift or have received hospitality please complete this survey. Use this link as soon as you have something to declare.

NHSBT also complete a yearly exercise, where all employees Band 8 plus, Budget holder, approvers of £10k plus and Finance staff need to complete a declaration of interest.

Full guidance is given in the Anti-Fraud Bribery and Corruption policy and FAQs document about what gift or hospitality can be accepted and when declarations are required.

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