Tackling fraud

The Bribery Act 2010 came into force on 1 July 2011 with the aim of tackling bribery and corruption in both the private and public sectors. Bribery is defined as the giving or receiving of a financial or other advantage in exchange for improperly performing a relevant function or activity.

University Hospitals Bristol and Weston NHS Foundation Trust is committed to applying the highest standards of ethical conduct, following good NHS business practice and having robust controls in place to prevent bribery. 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 the trust will not tolerate this in any form.

The Trust’s zero tolerance approach to bribery and corruption is set out in further detail within the Counter Fraud Policy and the Declarations of Interests Policy, and across a range of other trust policies and procedural documentation. This applies to all staff and non-executives, together with contractors and agents working or acting on behalf of the trust.

All are responsible for gaining an understanding of the requirements, the standard of conduct expected of them and ensuring that they comply at all times with all of our policies and procedures. This includes those in relation to procurement, hospitality and the acceptance of gifts.

Bribery and corruption under the act are punishable for individuals as a criminal offence by up to 10 years imprisonment and if the trust is found to have taken part in the corruption the trust could face an unlimited fine and face incalculable damage to our reputation. The trust therefore takes its legal responsibilities very seriously.

The success of the Trust’s anti-bribery measures depends on all employees, and those acting for and on behalf of the Trust, playing their part in helping to detect and eradicate bribery. Therefore, all employees and others acting for, or on the behalf of the Trust are encouraged to report any suspected bribery in accordance with the procedures set out in the Counter Fraud Policy and the Register of Interests, Gifts and Hospitality Policy, which incorporates anti-bribery and corruption guidance.

Any act of bribery undertaken by a member or employee of the trust will result in disciplinary action, referral of the matter to appropriate law enforcement, and will be treated with a similar level of importance by the Trust’s Board. If you are in any doubt as to whether any conduct could amount to bribery, or if you have any concerns or suspicions regarding bribery being committed, please contact the Trust’s Director of Finance, and Counter Fraud Champion.

Should there be any concerns or suspicions regarding bribery being committed by a Director of the Trust, please contact the Group Chief Finance and Estates Officer.

You can also contact the Trust’s Local Counter Fraud Specialists: sarah.smith@uhbw.nhs.uk or ian.halkerd@uhbw.nhs.uk 

Anyone with suspicions or concerns about fraud, bribery or corruption affecting the NHS in England and Wales, can report to the NHS Counter Fraud Authority (NHSCFA) by calling the 24/7 Crimestoppers freephone line 0800 028 4060, or by using the online NHSCFA reporting form.

The Bribery Act 2010 came into force on 1 July 2011 with the aim of tackling bribery and corruption in both the private and public sectors. Bribery is defined as the giving or receiving of a financial or other advantage in exchange for improperly performing a relevant function or activity.

North Bristol NHS Trust is committed to applying the highest standards of ethical conduct, following good NHS business practice and having robust controls in place to prevent bribery. 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 the trust will not tolerate this in any form.

The Trust’s zero tolerance approach to bribery and corruption is set out in further detail within the Counter Fraud Policy and the Declarations of Interests Policy, and across a range of other trust policies and procedural documentation. This applies to all staff and non-executives, together with contractors and agents working or acting on behalf of the trust.

All are responsible for gaining an understanding of the requirements, the standard of conduct expected of them and ensuring that they comply at all times with all of our policies and procedures. This includes those in relation to procurement, hospitality and the acceptance of gifts.

Bribery and corruption under the act are punishable for individuals as a criminal offence by up to 10 years imprisonment and if the trust is found to have taken part in the corruption the trust could face an unlimited fine and face incalculable damage to our reputation. The trust therefore takes its legal responsibilities very seriously.

The success of the Trust’s anti-bribery measures depends on all employees, and those acting for and on behalf of the Trust, playing their part in helping to detect and eradicate bribery. Therefore, all employees and others acting for, or on the behalf of the Trust are encouraged to report any suspected bribery in accordance with the procedures set out in the Counter Fraud Policy and the Declarations of Interests Policy, which incorporates anti-bribery and corruption guidance.

Any act of bribery undertaken by a member or employee of the trust will result in disciplinary action, referral of the matter to appropriate law enforcement, and will be treated with a similar level of importance by the Trust’s Board. If you are in any doubt as to whether any conduct could amount to bribery, or if you have any concerns or suspicions regarding bribery being committed, please contact the Trust’s Director of Finance, and Counter Fraud Champion.

Should there be any concerns or suspicions regarding bribery being committed by a Director of the Trust, please contact the Group Chief Finance and Estates Officer.

You can also contact the Trust’s Local Counter Fraud Specialists: sarah.smith@uhbw.nhs.uk  or ian.halkerd@uhbw.nhs.uk 

Anyone with suspicions or concerns about fraud, bribery or corruption affecting the NHS in England and Wales, can report to the NHS Counter Fraud Authority (NHSCFA) by calling the 24/7 Crimestoppers freephone line 0800 028 4060, or by using the online NHSCFA reporting form.

University Hospitals Bristol and Weston NHS Foundation Trust is committed to applying the highest standards of ethical conduct, following good NHS business practice and having robust controls in place to prevent fraud, bribery and corruption.

The Economic Crime and Transparency Act 2023 (ECCT Act) enshrines a corporate criminal offence, the ‘failure to prevent fraud’ offence. This offence is intended to hold large organisations, such as the Trust, to account if they profit from fraud. The ECCT Act came into effect on 1 September 2025.  Under the offence, large organisations may be held criminally liable where an employee, agent, subsidiary or other “associated person” commits a fraud that benefits the organisation.

An ‘associated person’ includes employees, agents, subsidiaries, or any other person performing services "for or on behalf" of the organisation. Companies within an organisation's supply chain are not associated persons unless they are providing services for or on behalf of the organisation.

In the event of a prosecution, the Trust will have to demonstrate that reasonable fraud prevention measures were in place at the time the fraud was committed; the ‘reasonable procedures’ defence, similar to the defence required in the Bribery Act 2010.

We have implemented and continually maintain reasonable, risk-based procedures designed to prevent and deter acts of fraud committed by persons associated with the Trust. These measures, include communication of our zero-tolerance approach to fraud, risk assessments, governance oversight, training, due diligence, monitoring, and continuous improvement, in line with Government ECCTA 2023 guidance and our commitment to good governance.

If you are in any doubt as to whether any conduct could amount to fraud, or if you have any concerns or suspicions regarding fraud being committed, please contact the Trust’s Local Counter Fraud Specialists: sarah.smith@uhbw.nhs.uk or ian.halkerd@uhbw.nhs.uk

Anyone with suspicions or concerns about fraud, bribery or corruption affecting the NHS in England and Wales, can report to the NHS Counter Fraud Authority (NHSCFA) by calling the 24/7 Crimestoppers freephone line 0800 028 4060, or by using the online NHSCFA reporting form. 

North Bristol NHS Trust is committed to applying the highest standards of ethical conduct, following good NHS business practice and having robust controls in place to prevent fraud, bribery and corruption.

The Economic Crime & Transparency Act 2023 (ECCT Act) enshrines a corporate criminal offence, the ‘failure to prevent fraud’ offence. This offence is intended to hold large organisations, such as the Trust, to account if they profit from fraud. The ECCT Act came into effect on 1 September 2025.  Under the offence, large organisations may be held criminally liable where an employee, agent, subsidiary or other “associated person” commits a fraud that benefits the organisation.

An ‘associated person’ includes employees, agents, subsidiaries, or any other person performing services "for or on behalf" of the organisation. Companies within an organisation's supply chain are not associated persons unless they are providing services for or on behalf of the organisation.

In the event of a prosecution, the Trust will have to demonstrate that reasonable fraud prevention measures were in place at the time the fraud was committed; the ‘reasonable procedures’ defence, similar to the defence required in the Bribery Act 2010.

We have implemented and continually maintain reasonable, risk-based procedures designed to prevent and deter acts of fraud committed by persons associated with the Trust. These measures, include communication of our zero-tolerance approach to fraud, risk assessments, governance oversight, training, due diligence, monitoring, and continuous improvement, in line with Government ECCTA 2023 guidance and our commitment to good governance.

If you are in any doubt as to whether any conduct could amount to fraud, or if you have any concerns or suspicions regarding fraud being committed, please contact the Trust’s Local Counter Fraud Specialists: sarah.smith@uhbw.nhs.uk or ian.halkerd@uhbw.nhs.uk

Anyone with suspicions or concerns about fraud, bribery or corruption affecting the NHS in England and Wales, can report to the NHS Counter Fraud Authority (NHSCFA) by calling the 24/7 Crimestoppers freephone line 0800 028 4060, or by using the online NHSCFA reporting form.