Standards of Business Conduct

Transcription

1 Standards f Business Cnduct Originatr Andy King Lcal Cunter Fraud Specialist/Jhn Ireland Assistant Directr f HR Lead Directr Janet King, Directr f HR and Facilities Versin Number 9 Versin/implementatin date June 10 ( Revised Sept 11) Ratified at HEB April 2010 ( Revised Sept 11) Review Date April 2016

2 Cntents Page Number 1 Intrductin 3 2 Scpe 3 3 Public Service Values 3 4 Principles f cnduct in the NHS 3 5 Pssible cnsequences f nt fllwing the guidelines 4 6 Respnsibilities 4 7 Gifts frm Suppliers 4 8 Gifts frm patients 5 9 Declaratin f Interests 5 10 Register f Interests 6 11 Preferential treatment in private transactins 6 12 Cntracts fr service 7 13 Favuritism in awarding cntracts 7 14 Secndary cntracts 7 15 Private practice 7 16 Cnflict f interest 8 17 Cmmercial spnsrship fr attending curses 8 18 Cmmercial spnsrship when advising n purchases 8 19 Cmmercial spnsrship f psts 8 20 Research cnduct 9 21 Ownership f intellectual prperty 9 22 Cmmercial in cnfidence Staff appintments Mnitring f plicy Equality impact assessment Review f plicy 11 Appendix 1 General Guidance fr Medical and Other Staff 12 Appendix 2 Appendix 3 Declaratin f interests frm Bribery Act Frimley Park Hspital NHS Fundatin Trust 2

3 1 Intrductin 1.1 This plicy has been frmulated by Frimley Park Hspital NHS Fundatin Trust in rder t implement the NHS Guidelines n Standards f Business Cnduct fr NHS Staff and details lcal prcedures. 1.2 The plicy cvers the standards f cnduct expected f all Trust emplyees, particularly where their private Interests may cnflict with their public duties. 1.3 It is the respnsibility f managers and staff t ensure that they are nt placed in a psitin which risks, r appears t risk, cnflict between their private interests and their NHS duties. 1.4 This plicy shuld be read in cnjunctin with the Trusts Anti Bribery Plicy. See Appendix 3. Page 14 Fr a brief précis. 2. Scpe 2.1 This plicy applies t all emplyees f the Frimley Park Hspital NHS Fundatin Trust (Including Bank, Agency and temprary staff). 2.2 In implementing this plicy, managers must ensure that all staff are treated fairly and within the prvisins and spirit f the Trust s Plicy. Special attentin shuld be paid t ensuring the plicy is understd by emplyees new t the NHS r Trust, r by staff wh may have an essential skills need in literacy r thse whse first language is nt English r fr persns with little experience f wrking life. 3. Public Service Values 3.1 T maintain public cnfidence, as a public sectr bdy, the Trust must be impartial and hnest in the cnduct f its business and its staff must remain beynd suspicin. 3.2 High standards f crprate and persnal cnduct, based n the recgnitin that patients cme first, have been a requirement thrughut the NHS since its inceptin. The three fundamental public service values are: Accuntability: Everything dne by thse wh wrk in the Trust must be able t stand the tests f parliamentary scrutiny, public judgements n prperty and prfessinal cdes f cnduct. Prbity: Abslute hnesty and integrity shuld be exercised in dealing with NHS patients, assets, emplyees, suppliers and custmers. Openness: The Trust s actins shuld be sufficiently public and transparent t prmte cnfidence between the Trust and its patients, ur emplyees and the public. 3.3 These standards are natinal benchmarks that infrm ur lcal plicies and prcedures. The arrangements made in this plicy have been designed t ensure cmpliance with the natinal standards. 4. Principles f Cnduct in the NHS 4.1 Trust staff are expected t: Frimley Park Hspital NHS Fundatin Trust 3

4 ensure that the interests f patients remain paramunt at all times be impartial and hnest in the cnduct f their fficial business use the public funds entrusted t them t the best advantage f the service, always ensuring value fr mney 4.2 It is als the respnsibility f staff t ensure that they d nt: abuse their fficial psitin fr persnal gain r t benefit their family r friends seek t advantage r further private business r ther interests, in the curse f their fficial duties 5. Pssible cnsequences f nt fllwing the guidelines 5.1 It is an ffence under the Bribery Act 2010 fr staff crruptly t accept any inducement r reward fr ding, r refraining frm ding anything, in his r her fficial capacity, r crruptly shwing favur, r disfavur, in the handing f cntracts. 5.2 Staff wh breach the prvisins f these acts render themselves liable t prsecutin (leading t a pssible unlimited fine and upt 7 years in jail term) and will als be subject t disciplinary prcedures, which may lead t their dismissal. 5.3 Under the Bribery Act, any mney, gift r cnsideratin received by an emplyee in public service frm a persn r rganisatin hlding r seeking t btain a cntract will be deemed by the curts t have been received crruptly unless the emplyee prves the cntrary 6. Respnsibilities Bard Members (Directrs and Nn-Executive Directrs) 6.1 The Directrs f the Trust are respnsible fr ensuring there are systems in place t ensure this and all related plicies are implemented acrss the Trust. 6.2 All Bard members are required t cmply with the requirements f the Cde f Cnduct and accuntability fr NHS Bards. Cnsultants 6.3 Cnsultants are required t cmply with all aspects f the plicy and t be aware that they have a respnsibly t cmply with ther prfessinal guidelines including thse f the General Medical Cuncil and in particular the cde f practice fr private patients. 6.4 All dealings with Pharmaceutical and ther cmpanies must be undertaken in an impartial manner t ensure that that they d nt abuse their fficial psitin fr persnal gain r t benefit their family r friends. Managers & Staff 6.5 Managers f the Trust are respnsible fr ensuring that these guidelines are brught t the attentin f all emplyees; als that machinery is put in place fr ensuring that they are effectively implemented within their areas f respnsibility. 6.6 All staff are cvered by this plicy, by all ther Trust plicies and by NHS s generic Standards f Business Cnduct fr NHS staff. 7. Casual Gifts/Hspitality frm Suppliers/ Cntractrs Frimley Park Hspital NHS Fundatin Trust 4

5 7.1 Casual gifts ffered by cntractrs, Pharmaceutical Cmpanies r thers e.g. at Christmas time shuld be plitely but firmly declined. Articles f lw intrinsic value such as diaries and calendars and pens r small tkens f gratitude frm patients r their relatives need nt necessarily be declined. In cases f dubt, staff shuld either cnsult their line manager fr authrisatin r plitely decline acceptance. Under n circumstances shuld mnetary gifts f cash be accepted. 7.2 Mdest hspitality prvided it is nrmal and reasnable (nt exceeding the threshld currently set at per ccasin) may be accepted e.g. lunches in the curse f wrking visits are acceptable, it shuld hwever be similar t the scale f hspitality which the NHS as an emplyer wuld be likely t ffer. Where a gift abve 35 is ffered, permissin must be sught frm a Directr regarding whether it may be kept. 7.3 Acceptance f mnetary gifts n a persnal basis is nt allwed 7.4 The HR Department maintains a recrd f gifts/hspitality received by staff (the Trust Secretary maintains ne fr the Directrs) and f declaratins f interest. Any gift r hspitality with a value exceeding the threshld r tw gifts t 35 each frm the same supplier within a 12 mnth perid must be declared by the emplyee prmptly (within 2 weeks f receipt) in writing fr inclusin in the register. Gifts belw the threshld d nt need t be declared. 7.5 Under n circumstances shuld any gift r hspitality be accepted where it wuld be in breach f an individual s prfessinal cde f cnduct. 8 Gifts frm Patients 8.1 Patients and members f the public wishing t express their appreciatin r t assist the wrk f the Trust with mnetary gifts may apprach clinicians, nurses, administratrs r ther staff wh in all cases must cmply with the fllwing principles and prcedures: 8.2 Acceptance f mnetary gifts n a persnal basis is nt allwed.small gifts, fr example a bx f chclates, may be accepted prvided that the guidelines set ut abve are fllwed 8.3 Members f the public, patients and relatives, may n ccasins, seek the advice f the staff regarding charitable dnatins and they shuld refer t the Administratin f Charitable Funds Prcedure. 9. Declaratin f Interests 9.1 It is the respnsibility f the emplyee t infrm the Trust if they, r a clse relative r assciate has a cntrlling interest and/r significant financial interest in a business (including a private sectr cmpany, public sectr rganisatin, r ther NHS emplyer and/r vluntary rganisatin), r in any ther activity r pursuit which may cmpete fr an NHS cntract t supply either gds r services t the hspital (e.g. private nursing hmes). 9.2 In such circumstances the Trust must ensure that its interest and the interest f patients are adequately safeguarded. 9.3 A declaratin f interest must ccur either when the emplyee cmmences emplyment r upn acquisitin f the interest. Frimley Park Hspital NHS Fundatin Trust 5

6 9.4 All Cnsultants and AfC staff at r abve band 8 will be required t make an annual declaratin using the frm detailed in Appendix 2. A frm will be sent t them each year. 9.5 All declaratins will be entered int a central register. 9.6 If a dctr refers a patient t a private nursing hme r ther establishment/service in which they have a business interest, the patient must be made aware f the interest prir t referral. 9.7 All staff wh have received a gift abve 35, and / r wh have an interest as defined in this plicy shuld make a declaratin by cmpleting the frm detailed in appendix 2 and returning it t the PA f the Directr f HR and Facilities by 31st March each year. 10. Register f Interests The Trust will maintain the fllwing registers f interest: Bard Members 10.1 All Bard members must cmply with the Cde f Cnduct fr NHS Managers The Cmpany Secretary will maintain a register f Trust Bard members interests. The register will include details f all directrships and ther relevant and material interests which have been declared by bth executive and nn-executive Bard members including any ther activity r pursuit which may cmpete fr an NHS cntract t supply gds r services t the Trust all utside emplyment, any link with suppliers and cmpetitrs.the register will be available fr public inspectin n request. All Staff The Directr f Human Resurces will hld a register f interests and declaratins fr all staff wh are nt Bard Members. The register will hld details f: Staff wh have an interest in any ther activity r pursuit which may cmpete fr an NHS cntract t supply gds r services t the Trust, and Staff wh risk a cnflict f interest by engaging in utside emplyment Declaratins f hspitality and spnsrship, e.g. suppliers Any ther matters declared by staff in accrdance with this plicy 10.4 All staff jining the Trust will be infrmed f this plicy n jining. Existing emplyees will be reminded f the plicy thrugh publicity in Infrm. The plicy will appear n the Trust intranet Staff wh believe that they may have develped a cnflict f interest whilst in the curse f their emplyment shuld advise their manager wh shuld raise this with a Directr. The manager will agree an apprpriate curse f actin with the emplyee. In any event, emplyees will be ntified in writing if any activity is cnsidered t generate a cnflict f interest, and infrmatin will als be given n the curse f actin t be taken by the emplyee. A member f staff wh is dissatisfied with the utcme f this may appeal against the decisin using the Trust s grievance prcedure 11. Preferential treatment in private transactins Frimley Park Hspital NHS Fundatin Trust 6

7 11.1 Emplyees must nt seek r accept preferential rates r benefits in kind fr private transactins carried ut with cmpanies with which they have had, r may have, fficial dealings n behalf f the Trust (this des nt apply t cncessinary agreements negtiated with cmpanies by NHS management, r by recgnised staff interests, n behalf f all staff, e.g. NHS staff benefits schemes). 12. Cntracts fr Services 12.1 All staff wh are in cntact with suppliers and purchasers (including external cnsultants), and in particular thse wh are authrised t sign Purchase Orders, r place cntracts fr gds, materials r services, are expected t adhere t the prfessinal standards f the kind set ut in the Ethical Cde f the Institute f Purchasing and Supply (IPS) All cntracts must be awarded via the Trust s Standing Orders and Standing Financial instructins. 13. Favuritism in Awarding Cntracts 13.1 Fair and pen cmpetitin between prspective cntractrs r suppliers fr Trust cntracts is a requirement fr Trust Standing Orders and f EC Directives n Public Purchasing fr Wrks and Supplies A private, public r vluntary rganisatin r cmpany bidding fr NHS business shuld nt be given any advantage ver its cmpetitrs, such as advance ntice f NHS requirements. This applies t all ptential cntractrs even if they have held a lng-running series f previus cntracts. Each new cntract shuld be awarded slely n merit, taking int accunt the requirements f the Trust and the ability f the cntractrs t fulfil them There must be n favuritism shwn t any current r previus emplyees, clse relatives r assciates in awarding cntracts t businesses run by them r emplying them. Cntracts can be awarded t such a business if wn in fair cmpetitin against ther tenders and if the interested party plays n part in the selectin prcess. Tendering and cntracting shuld fllw the Trust s Standing Financial Instructins. 14 Secndary Emplyment/ Wrking fr anther Health prvider 14.1 Emplyees wh carry ut any ther paid (r unpaid) wrk utside the Trust, must discuss this with their manager where this is likely t cause sme cnflict with their wrk with the Trust. The ttal weekly average hurs f wrk shuld nt nrmally exceed the limit under the Trust s Wrking Time Plicy. Where the manager assesses there t be a cnflict f interests r where the Trust s cnfidentiality requirements are jepardised, the emplyee will be required t give up the ther emplyment; their emplyment with the Trust may be terminated shuld they refuse t d s Cnsultants are required t seek the permissin f the Chief Executive if they wish t carry ut any wrk fr anther supplier in rder t avid a cnflict f interest. 15. Private Practice 15.1 Cnsultants are allwed t carry ut private wrk in accrdance with their cntract and as described in the cde f practice published by DH in January 2004 titled A cde f cnduct fr private practice fr NHS cnsultants.cnsultants shuld declare any private practice which may give rise t an actual r perceive cnflict f interest prir t the wrk being carried ut and als n an annual basis.in accrdance with Schedules 9 and 12 f the Cnsultant Cntract. Frimley Park Hspital NHS Fundatin Trust 7

8 15.2 Other Medical and Dental emplyees and ther clinical staff may undertake private wrk fr utside agencies, prviding they d nt d s within the time they are cntracted t the NHS, and they bserve the cnditins in paragraph abve and the duty f fidelity f emplyer is always maintained. All hspital dctrs are entitled t fees fr ther wrk utside their NHS cntractual duties defined in their cntract. All such wrk shuld be declared t the Trust prir t it being perfrmed and permissin sught in rder t avid pssible cnflicts f interest Dctrs and Dentists in training shuld nt undertake lcum wrk utside their cntracts where such wrk wuld be in breach f their cntracted hurs (see als EWTD plicy and pting ut). 16. Cnflict f Interest 16.1 Staff must nt be in any way directly r indirectly engaged in any ther business r undertaking where this is likely t be in cnflict with the interest f the Trust r where this may adversely affect the efficient discharge f their duties (see als 14.2). Such cnflicts f interest culd arise fr example in a bidding prcess r where additinal wrk culd invlve wrk/time pressures which culd cnflict with patient safety 16.2 They must state in writing if they think they may be risking a cnflict f interest in this area; the Chief Executive, Medical Directr and the Directr f Human Resurces will be respnsible fr judging whether the interests f patients culd be harmed, in line with the principles abve. 17. Cmmercial spnsrship fr attendance at curses and cnferences 17.1 Acceptance by staff f cmmercial spnsrship fr attendance at relevant cnferences and curses is acceptable (this can include travel, subsistence csts) but nly where the emplyees seeks permissin in advance frm the Head f Service, General Manager r Clinical Directr and the Trust is satisfied that acceptance will nt cmprmise purchasing decisins in any way. Such acceptance must be reprted t the PA f the Directr f HR and Facilities fr inclusin in the register 18. Cmmercial spnsrship when advising n purchases/services 18.1 On ccasins when the Trust cnsiders it necessary fr staff advising n the purchase f equipment t inspect such equipment in peratin in ther parts f the cuntry (r exceptinally, verseas) r when it is necessary t inspect a service, staff shuld seek prir permissin frm either the Head f Service, General Manager r Clinical Directr. Staff shuld be aware that excessive hspitality is unacceptable The purpse, aims and bjectives f any such visit will be reprted as abve and a recrd will be kept n the emplyee s persnnel file in the HR department fr audit purpses and reprted t the PA f the Directr f HR and Facilities fr inclusin in the register. 19. Cmmercial Spnsrship f Psts Linked Deals Frimley Park Hspital NHS Fundatin Trust 8

9 19.1 Where ther rganisatins whlly r partially spnsr a hspital pst, it shuld be made abundantly clear t the rganisatin cncerned, that the spnsrship deal will have n effect n purchasing decisins within the Trust. Where such spnsrship is accepted, mnitring arrangements will be established t ensure that purchasing decisins are nt being influenced by the spnsrship agreement. Prir apprval frm a Bard Directr is required. Such acceptance must be reprted t the PA f the Directr f HR and Facilities fr inclusin in the register 19.2 In all such cases the pay rate fr the pst will be determined by the Trust s nrmal criteria i.e. by the Agenda fr Change Jb Matching/Evaluatin prcess r by reference t the Medical and dental terms and cnditins f emplyment, nt by the funding ffered. Additinally, where the funding is time limited, the pst shuld be established and ffered n a fixed term basis. 20. Research Cnduct 20.1 Research activity within the Trust will prvide benefits t patients, staff and the rganisatin if it is planned and cnducted in cmpliance with all relevant legislatin, ethical cdes, cdes f practice, and NHS guidance. The Department f Health published the Research Gvernance Framewrk fr Health and Scial Care in June The purpse f the framewrk is t: safeguard the public ensure ethical and scientific quality f research, and prmte gd practice The framewrk sets ut the standards and mnitring arrangements fr all research undertaken in the NHS. It defines the respnsibilities f researchers, principal investigatrs, funding bdies and rganisatins which hst research r emply researchers. It sets ut required standards fr research and includes standards frm existing legislatin and regulatins, Department f Health, recgnised internatinal and natinal authrities, and prfessinal rganisatins Researchers are required t meet their respnsibilities as defined in the framewrk. It can be accessed in the Library, the R&D Office, and n the Department f Health Internet site ( These respnsibilities include, but are nt limited t: Develping prpsals that are ethical and seeking research ethics cmmittee apprval Cnducting research t the agreed prtcl and in accrdance with all apprpriate legal and prfessinal requirements and guidance e.g. n cnsent, financial transactins and data prtectin Ensuring participant welfare while in the study, and Feeding back results f research t participants Researcher are required t discuss their prpsal with the Trusts Research and Develpment Manager 21 Ownership f Intellectual Prperty 21.1 Frm time t time during the nrmal curse f emplyment an emplyee may generate IP which may have value in the delivery f better patient care. This IP can be in the frm f Frimley Park Hspital NHS Fundatin Trust 9

10 inventins, discveries, surgical techniques r methds, develpments, prcesses, schemes, frmulae, specificatins, r any ther imprvements which may give rise t certain rights such as patents, trade marks, service marks, design rights, cpyright, knwhw, trade r business names and ther similar rights (all f the freging rights being referred t as Intellectual Prperty Rights ) Where such IP is created in the curse f the individual s emplyment r nrmal duties then under UK law it will generally belng t the Trust, unless agreed therwise in writing between the individual and the Trust. In relatin t inventins ptentially subject t patent prtectin this applies nly if the duties f their emplyment wuld nrmally have been expected t give rise t inventins r if the nature f their respnsibilities and duties are such that they are under a special respnsibility t further the interests f the Trust. It is a cnditin f emplyment that emplyees d nt explit any IP rights withut the specific apprval f the Research and Develpment Cmmittee Cnsultant medical staff ( and a few thers wh have been given this specific authrity in writing) shall be free, withut prir cnsent f the Trust t publish bks, articles, etc and t deliver any lecture r speak, whether n matters arising ut f his/her NHS service r nt. It wuld be nrmal practice fr the results f the wrk t be shared with the Trust prir t publicatin, and any cnflict f interest declared. Other staff wuld need t btain the prir permissin f their manager. 22. Cmmercial In-Cnfidence 22.1 Staff must nt misuse r make available fficial cmmercial in-cnfidence infrmatin, particularly if its disclsure wuld prejudice the principles f a purchasing system based n fair cmpetitin. This principle applies whether private cmpetitin r ther NHS prviders are cncerned and whether r nt disclsure is prmpted by the expectatin f persnal gain This als applies t any Staff representatives wh btain such infrmatin as part f the cnsultatin prcess in such matters. 23. Staff Appintments 23.1 Member f the Bard and managers must nt canvass selectin panels fr the appintment f particular candidates wh are knwn persnally r related t them either directly r indirectly, if they d the selectin panel shall disqualify the candidate frm being appinted. Canvassing is defined as sliciting r putting pressure n thers fr their appintment-this des nt prevent managers frm intrducing pssible candidates and des nt prevent infrmal discussins taking place between an applicant and a manager 23.2 Members f the Trust Bard r managers may act as a referee fr such a pst thugh trust plicy is t take business references prir t seeking persnal references It is the respnsibility f any member f staff invlved in selectin interviews t infrm their manager if any relatinship exists between themselves and a candidate fr an appintment. Trust Bard members and senir fficers shuld disclse t the Trust Bard any relatinship between themselves and a candidate fr an appintment f which they are aware In all cases the Trusts recruitment and selectin prcedure must be adhered t. 24. Mnitring f Plicy Frimley Park Hspital NHS Fundatin Trust 10

11 This plicy will be mnitred by the Cmpany Secretarial and HR Departments wh will maintain the registers described. A summary f this infrmatin is reprted t the Trust Bard each year. 25 Equality Impact Assessment This plicy has been subject t an Equality Impact Assessment and is nt anticipated t have an adverse impact n any grup. 26. Review f the Plicy This plicy will be reviewed every 3 years r sner if new legislatin is intrduced Frimley Park Hspital NHS Fundatin Trust 11

12 Appendix 1 GENERAL GUIDANCE FOR MEDICAL AND OTHER STAFF Gifts in Kind Gifts f less than 35 (r if mre than 1 gift less than 35 frm the same supplier ) d nt need t be declared Acceptable Items f lw value such as diaries, calculatrs, pens etc Prbably acceptable but needs apprval N/A Unacceptable Gifts f significant value. Any gifts linked with purchasing agreements r prescribing prmises r invlvement in direct drug prmtin. Cash/Cheques Vuchers Payment fr specific services such as lectures r preparatin r written material ( nt part f Jb Plan). Payment fr cnsultatin services t the industry (e.g. prmtinal material). Such wrk must nt nrmally be dne in NHS time.lectures may be given in NHS time prvided that payment f n mre than 100 is made r else it is agreed by the Trust that the NHS wrk can be dne at anther time.preparatin shuld be dne in wn time. Gifts r inducements Research Advice shuld als be sught frm the Research and Develpment Manager t ensure the Trust receives apprpriate incme fr cnsultative services Hspitality Payment fr scientifically valid research apprved by ethical and research and develpment cmmittees where payments are made int prperly administered Trust Funds Refreshments during the curse f educatinal meetings t the standards n higher than that usually paid fr by the individual himself/herself Emplyment f staff n mnies frm the pharmaceutical industry fr the pursuance f such research. In such situatins the matter must be discussed with the general manager Spnsring fr travel t natinal r internatinal meetings r recgnised scientific r managerial value, within the parameters f the study leave plicy Direct payments t individual dctrs fr research unless apprved by Ethical and Research and Develpment Cmmittees Extravagant hspitality r travel unrelated t scientific/career issues. Payment fr spuses r partners t attend natinal/internatinal meetings as accmpanying persns. Frimley Park Hspital NHS Fundatin Trust 12

13 Appendix 2 Declaratin f Interests Frm Full Name- Jb Title- Year- Please list any Gifts/Hspitality received /training curses paid fr in this perid in this bx Please list any pssible cnflicts f interest in this Bx and in particular ther rganisatins fr which yu d paid r unpaid wrk r cnsultancy / fee earning wrk. Please list any Directrships r wnerships held in this bx Signed Date Please return t the Directr f HR and Facilities PA ( Nn Directr) r C Sec Office (Directr) Frimley Park Hspital NHS Fundatin Trust 13

14 Appendix 3. Bribery Act This plicy shuld be read in cnjunctin with the Bribery Act Which states: The Bribery Act 2010 which repeals existing legislatin has intrduced the ffences f ffering and r a receiving a bribe. It places specific respnsibility n rganisatins t have in psitin sufficient and adequate prcedures t prevent bribery and crruptin taking place. Under the act Bribery is defined as: Inducement fr an actin which is illegal, unethical r a breach f trust. Inducements can take the frm f: gifts, lans, fees, rewards r ther privileges. Crruptin is bradly defined as: The ffering r acceptance f inducements, gifts r favurs, payments r benefit in kind which may influence the imprper actin f any persn. Crruptin des nt always result in a lss. The crrupt persn may nt benefit frm their deeds: hwever they may be unreasnably using their psitin t give an advantage t anther. T demnstrate that the rganisatin has sufficient and adequate prcedures in place and t demnstrate penness and transparency all staff are required t cmply with the requirements f the Declaratin f Interest Plicy. Fr a mre detailed explanatin please see the Anti Bribery Plicy. Shuld members f staff wish t reprt any cncern r allegatins they shuld cntact their Lcal Cunter Fraud Specialist. Currently: Andy King (andrew.king@rsmtenn.cm) June Frimley Park Hspital NHS Fundatin Trust 14