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Key Documents NHS Lothian | Our Organisation

An Anti-Bribery Statement from the Board

Lothian NHS Board conducts its business with integrity, transparency and fairness.

We are committed to the prevention of bribery and corruption as we recognise the importance of maintaining our reputation and the confidence of our stakeholders, particularly patients, the general public, those with whom we conduct business, and our employees.

We do not accept bribery and corruption in the conduct of our activities and functions, either within the organisation or in our relationships with any external parties.  We will not work with others who do not share our commitment to preventing bribery and corruption.

If you have any concerns with regard to bribery and corruption in relation to the Board’s activities, there are several ways in which you can raise this:

  1. Reporting any concerns to the Board’s Fraud Liaison Officer (Jim Old – telephone 0131 465 7772) or Counter Fraud Services (CFS Fraud Hotline – 08000 15 16 28)
  2. If the issue relates to the behaviour of a member of the Board, and compliance with the Board Member’s Code of Conduct, reporting the matter to the Public Standards Commissioner.
  3. As a Board employee, making use of the Whistleblowing Policy. You can call the Whistleblowing Alert and Advice Services for NHS Scotland – telephone 0800 008 6112.

Prof. John Connaghan
Board Chair

Calum Campbell
Chief Executive

It is a criminal offence to either make a bribe or to receive a bribe.  The Bribery Act 2010 sets out technical definitions for both, however in simple terms a bribe has the following elements:

– to give/ promise/ offer an advantage (financial or otherwise) to someone, OR

– to request/ agree to receive/ accept an advantage (financial or otherwise) from someone

AND, with the intention (by either the giver or receiver) to:

a) Encourage the recipient to improperly perform a function or an activity, OR

b) Reward the recipient who has already improperly performed a function or an activity.

It is also an offence when it is known by the giver or receiver that acceptance of the advantage would itself constitute improper performance of a relevant function or activity.  An example of this would be the offer or acceptance of hospitality & entertainment that goes beyond the limits of what is considered modest, normal and reasonable in the circumstances, as defined by the relevant code of conduct.

When bribery happens it leads to corruption.  This is where people abuse their position for their personal benefit/ reasons, rather than properly performing their role for the benefit of the Board and the stakeholders it serves.

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