Transparency

he Modern Slavery Act 2015 makes provision about slavery, servitude and forced or compulsory labour as well as about human trafficking.

Whilst not all of the Act is directly relevant to business, section 54 “Transparency of Supply Chain” requires organisations that carry on business within the UK providing good and services to report annually on the steps that they have taken, within that financial year, to ensure that slavery and human trafficking are not taking place in their own business or supply chain.

Although publication in the Slavery Statement Registry (operated by the Home Office) is currently voluntary the government does intend to legislate for mandatory reporting under planned changes to the regime; it is considered good practice to make and publish an annual statement. You can read our full statement here.

We are committed to delivering good governance and has always expected its staff and directors to meet the highest standards of business conduct.

The Bribery Act 2010 came into force on 1 July 2011. The aim of the act is to tackle bribery and corruption in both the private and public sector.

The Act defines the following key offences with regard to bribery: 

• Active bribery (offering, promising or giving a bribe);
• Passive bribery (requesting, agreeing to receive or accepting a bribe); and
• Bribery of a foreign public official.

The Act also sets out a corporate offence of failing to prevent bribery by an organisation not having adequate preventative procedures in place.  One of the six principles of the Act demands that there is top level commitment in the organisation for preventing bribery. The Trust is committed to ensuring compliance with the Act and has a zero tolerance approach to fraud, corruption and bribery.

The Trust follows NHS best practice and has robust controls, policies and procedures in place to prevent fraud, corruption and bribery. To limit our exposure to bribery we have in place a Counter Fraud and Bribery Policy and Conflict of Interest Policy which includes information on gifts and hospitality.  In addition, we hold a register of interest for directors and staff and ask staff not to accept gifts or hospitality that will compromise them or the Trust. These apply to all staff and to individuals and organisations who act on behalf of the Trust.

The success of our anti-bribery approach depends on our staff playing their part in helping to detect and eradicate bribery. Therefore, we encourage staff, patients, service users and others associated with the Trust to report any suspicions of bribery and we will rigorously investigate any allegations. 

As a Trust, we are commitment to ensuring that the Trust is free from fraud, corruption and bribery and that all staff are aware of their responsibilities in relation to the prevention of bribery.

We have a duty to be open and transparent when things go wrong and there have been mistakes in a patient’s care that have led to harm. This is known as the Duty of Candour, and it helps patients to receive accurate, truthful information from hospitals and other healthcare providers. It also sets out some specific requirements that we must follow when things go wrong with care and treatment, including informing people about the incident, providing reasonable support, providing truthful information and saying sorry.

We are committed to talking to patients and their carers at a very early stage to understand what happened and, where necessary, learn the lessons that will prevent it happening again to improve the safety of our future patients. This is very much part of our culture.

If you have any questions, or you would like to raise a concern, talk to a member of staff in the service concerned. If you are unable to do so, you should contact our Patient Advice and Liaison Service (PALS) and they will be able to advise you. Call PALS on 020 3513 6150