The Governing Body of NHS Somerset CCG recognises that bribery is a hugely damaging practice that undermines competition and the reputation of public and private bodies involved. This statement demonstrates our commitment to preventing bribery. It is our policy to act with integrity and we will not tolerate bribery and corruption. We will implement and enforce effective systems to counter bribery.
We have created an Anti Fraud, Bribery and Corruption Policy that sets out procedures designed to prevent everyone associated with us from undertaking acts of bribery or corruption. This policy has been created with reference to the Bribery Act 2010 and the Ministry of Justice’s statutory guidance.
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. Bribery and corruption under the Act are punishable for individuals by up to ten years' imprisonment and if the CCG is found to have taken part in corruption we could face an unlimited fine and incalculable damage to our reputation. We therefore take our legal responsibilities very seriously. Any act of bribery undertaken by a member or an employee of the CCG will result in disciplinary action and will be treated extremely seriously by the CCG Governing Body. We require that all contractors instructed by our organisation demonstrate a comparable commitment to bribery prevention in order to do business with us.
We believe a zero tolerance approach towards bribery supports our reputation for honest and ethical practice, and instils confidence in our patients and the wider public.
As part of our commitment to prevent bribery within the CCG, the Governing Body has a number of bribery prevention procedures which include:
- Anti-Fraud, Bribery and Corruption Policy;
- Policies that govern Standards of Business Conduct, Gifts and Hospitality, Disciplinary procedures, Working with the Pharmaceutical Industry and Whistleblowing;
- Standing Financial Instructions and Standing Orders;
If you have any concerns or queries in relation to this statement or our procedures in respect to bribery prevention please contact us at firstname.lastname@example.org
The CCG also has a Local Counter Fraud Specialist to support the organisation in taking measures to tackle fraud.
Mr David Freeman, Accountable Officer
1 April 2019