Bribery Act Statement

NHS Kent and Medway Integrated Care Board (ICB) recognises that bribery is a hugely damaging practice that undermines competition and the reputation of public and private bodies involved.

This statement demonstrates the ICB’s commitment to preventing bribery. The ICB is committed to delivering good governance and has always expected its ICB Board members and staff to meet the highest standards of business conduct. The ICB expects staff to act with integrity and we will not tolerate bribery and corruption.

The Bribery Act 2010 came into force on 1st July 2011 and 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 regards 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.

NHS Kent and Medway ICB has a set of robust controls, policies and procedures in place to prevent fraud, corruption or bribery. The ICB’s Counter Fraud Team can be contacted if staff have any concerns of fraud, corruption or bribery and the IC has an annual plan to mitigate the risks of fraud, corruption, and bribery.

The ICB also has an Anti-Fraud, bribery and corruption policy available to staff on the intranet that sets out procedures designed to prevent acts of bribery or corruption. This policy has been created with reference to the Bribery Act 2010. Additionally, the ICB has policies that govern how conflicts of interest are declared and managed, disciplinary procedures, and ‘Freedom to Speak Up’, as well as Standing Financial Instructions and Standing Orders.

One of the six principles of the Act demands that there is top level commitment in the organisation for preventing bribery. NHS Kent and Medway ICB is committed to ensuring compliance with the Act and discussions have been held at both the ICB Board and its Audit and Governance Committee to ensure that the requirements of the Act are fully complied with.

The ICB believes a zero-tolerance approach towards bribery supports our reputation for honesty and ethical practice, and instils confidence in our patients and the wider public. The ICB would like to re-affirm its commitment to ensuring that the ICB is free from fraud, corruption or bribery and that all staff are aware of their responsibilities in relation to the prevention of fraud, corruption or bribery. If you have any concerns or queries in relation to this statement or our procedures in respect to bribery prevention, please contact us.

If you have any concerns about a fraud or bribery taking place in the NHS you can contact Andrew Ede, Anti-Crime Manager, tel 07814 285177 or email

Alternatively you can contact tge NHS Counter Fraud Authority Reporting Line on 0800 028 40 60 or visit the Counter Fraud Authority website

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