Contents Page Section 1 Introduction 4 1.1 Objectives 5 1.2 Scope 5 2 5 Definitions 2.1 NHS Counter Fraud Authority 5 2.2 Fraud 6 2.3 Bribery and Corruption 6-8 3 Other Relevant Procedural Documents 8 4 Code of Conduct 8-10 5 Roles and Responsibilities 10 5.1 Role of the Governing Body / Committee 10 5.2 Accountable Officer 10 5.3 Chief Finance Officer (CFO) 11 5.4 Managers 11-12 5.5 Employees 13 5.6 Anti-Fraud Specialist (AFS) 13-14 5.7 NHS Counter Fraud Authority (NHSCFA) 14 5.8 Internal and External Audit 15 5.9 Human Resources 15 5.10 Information Management and Technology 15 6 The Response Plan 6.1 Reporting fraud, bribery and/or corruption 15-16 6.2 Sanctions and Redress 17 7 Consultation Process 17-18 7 Dissemination and Implementation 18 7.1 Dissemination 18 7.2 Implementation 18 8 Process for Monitoring Compliance and Effectiveness 18 9 Standards/Key Performance Indicators 18 10 References 18 Appendices Appendix A Desktop Guide 20 – Appendix B Referral Form 21 – Introduction One of the basic principles of public sector organisations is the proper use of public funds. The majority of people who work in the NHS conduct themselves in an honest and professional manner and they believe that fraud, bribery and
Contents Section Page 1 Introduction 4 1.1 1.2 2 2.1 Objectives Scope Definitions NHS Counter Fraud Authority 5 5 5 5 2.2 Fraud 6 2.3 3 4 5 5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 5.9 5.10 6 6.1 6.2 Bribery and Corruption Other Relevant Procedural Documents Code of Conduct Roles and Responsibilities Role of the Governing Body / Committee Accountable Officer Chief Finance Officer (CFO) Managers Employees Anti-Fraud Specialist (AFS) NHS Counter Fraud Authority (NHSCFA) Internal and External Audit Human Resources Information Management and Technology The Response Plan Reporting fraud, bribery and/or corruption Sanctions and Redress 6-8 8 8-10 10 10 10 11 11-12 13 13-14 14 15 15 15 15-16 17 7 Consultation Process 17-18 7 7.1 7.2 Dissemination and Implementation Dissemination Implementation 18 18 18 8 Process for Monitoring Compliance and Effectiveness 18 9 Standards/Key Performance Indicators 18 10 References 18 Appendices Appendix A – Desktop Guide 20 Appendix B – Referral Form 21 Introduction One of the basic principles of public sector organisations is the proper use of public funds. The majority of people who work in the NHS conduct themselves in an honest and professional manner and they believe that fraud, bribery and
Anti%20Fraud%20Bribery%20and%20Corruption%20Policy%202017-18.docx