Anti-Bribery Policy

Purpose of this policy

This policy sets out our responsibilities, and the responsibilities of those working for us, in preventing bribery and corruption. It also provides information and guidance on how to recognise and deal with bribery and corruption issues.

The Bribery Act 2010 imposes extensive obligations on organisations to ensure they have adequate procedures in the place to prevent bribery from occurring in their organisation.

The NHS Confederation is committed to complying with the Act and this policy and guidance notes explain the steps we have put in place. 

Scope

This policy applies to everyone working at or with the NHS Confederation.

It applies to:

• all staff, including chief executives, directors, senior managers, employees (whether permanent, fixed-term or temporary), seconded staff, homeworkers, agency workers and volunteers
• consultants and contractors
• trustees and committee members.

Any employing or contracting manager must ensure that all temporary staff, consultants, or contractors are aware of this policy.

By the NHS Confederation we mean the NHS Confederation charity, any subsidiary companies and any hosted networked organisation. The NHS Confederation has designated the Director of People & Governance as the individual who is responsible for ensuring that the NHS Confederation implements this policy.

This policy should be read in conjunction with the organisation’s Anti-Fraud Policy, Conflicts of Interest Policy, Whistleblowing Policy and Gifts and Hospitality Policy.