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Policy Statement

The Trust is committed to ensuring that high standards of public service values are maintained across all its activities. This includes demonstrating high ethical standards of personal conduct.

The Trust will take all reasonable steps to ensure that staff do not place themselves in a position where they may be deemed by others to have been unduly or corruptly influenced in making a business decision or can be deemed by others to have been influenced to provide preferential treatment.

The Trust’s Standing Orders require the Board to have an explicit procedure covering gifts and hospitality.


The Principles of Conduct in the NHS mean that all staff are expected to:

  • be impartial and honest in the conduct of their official business, and
  • not abuse their official position for personal gain or to benefit their family or friends.


This Policy is also in accordance with the Trust’s own Values;

  • ‘Patients First’
  • ‘Personal Responsibility’
  • ‘Passion for Excellence’
  • ‘Pride in our Team’



Staff should not place themselves in a position where they maybe deemed by others to have been influenced in making a business decision or where they can be deemed by others to have been influenced to provide preferential treatment.

It is therefore essential that staff and Non-Executive Directors understand the personal requirements they must observe before considering accepting any hospitality or gifts in the course of their NHS duties.

Whilst acting in an official capacity staff must not corruptly accept gifts as an inducement or reward for doing, or refraining from doing, anything, or showing favour or disfavour to any person or organisation with whom the Trust has, or may potentially have, a contractual relationship.

The NHS has adopted the ‘Code of Conduct for NHS Managers (October 2002) which generally covers wider issues but includes the requirement for honesty and integrity and is thus applicable to this Policy.

The Bribery Act 2010, which came into force in July 2010, replaces and repeals the previous primary legislation relating to bribery and corruption in the UK including the Prevention of Corruption Acts 1906 and 1916.

Effectively the Bribery Act 2010 creates two general offences covering the offering, promising or giving of, an advantage, and requesting, agreeing to receive or accepting of an advantage.

All staff have a personal responsibility to ensure they are not placed in a position which risks, or appears to risk, a conflict between their private interests and their NHS duty.

A breach of the Bribery Act 2010 and this Policy may leave an individual liable to prosecution and may also lead to the termination of their employment and the loss of superannuation rights in the NHS. The Act also created a new offence of failure by the organisation to prevent a bribe being paid for or on its behalf, hence the Trust will take all reasonable steps to prevent a breach of the Act.

If a Trust staff member is concerned about another member of staff’s motivation for accepting gifts or hospitality, or feels there has been a breach of this policy then it may be a matter that requires investigation. This must be reported as soon as possible.

A breach of this policy could be deemed as a case of suspected fraud and/or corruption. The Trust wishes to encourage anyone having reasonable suspicions of fraud or corruption to report them. To this end, the Trust’s Counter Fraud Policy encourages staff not to turn a blind eye or to remain silent but to report genuinely held concerns about Fraud and Corruption to the Trust’s Local Counter Fraud Specialist where they will be treated with discretion.

All instances of fraud and corruption will be dealt with in accordance with the Trust’s Counter Fraud and Policy and Response Plan. Additionally, if Trust staff member does raise a genuine concern, the Raising Concerns at Work Policy applies in addition to the Counter Fraud Policy.


Policy Details

Download: PDF version
Compiled by: Head of Corporate Affairs
Ratified by: Trust Executive Committee
Date Ratified: March 2016
Date Issued: August 2016
Review Date: March 2019
Target Audience: All staff
Contact name: Liz Davies, Acting Company Secretary


See also:

  • Register of Interests Policy
  • Standing Orders
  • Fraud and Corruption Policy