Counter-fraud and anti-bribery policy

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1 Counter-fraud and anti-bribery policy Responsible Officer Author Ben Bennett, Business Planning & Resources Director Corporate Office Date effective from May 2012 Date last amended November 2016 Review date November

2 Contents Section Page Number Introduction... 3 Definitions... 3 Scope... 3 Policy..4 Roles and responsibilities... 5 Training..6 Disciplinary Action... 6 Further information... 7 Review...7 Related policies... 7 Appendix A. 8 2

3 Introduction 1. This document sets out the policy and procedure for dealing with and reporting allegations of fraud or bribery. 2. NICE does not tolerate fraud and bribery and will take effective measures to eliminate it as far as possible to protect its interests and ensure the proper management of public funds. 3. NICE will foster an anti-fraud culture to ensure all staff are aware of the risks of fraud and bribery and understand what is not acceptable practice. NICE will ensure all those covered by the policy are aware of their responsibilities in reporting allegations of fraud or bribery and enable them to do so confidently in accordance with this policy and the Whistleblowing Policy. 4. NICE will ensure high standards of corporate and personal conduct and apply three fundamental public service values set out in its Standards of Business Code of Conduct: Accountability Probity Openness Definitions Everything done by those who work at NICE must be able to stand the tests of parliamentary scrutiny, public judgements on property and professional codes of conduct. Absolute honesty and integrity should be exercised in dealing with NHS patients, assets, employees, suppliers, contractors and customers. The actions of NICE should be sufficiently public and transparent to promote confidence between NICE and its patients, our employees and the public. 5. Fraud - any person who dishonestly makes a false representation to make a gain for himself or another or dishonestly fails to disclose to another person, information which he is under a legal duty to disclose, or commits fraud by abuse of position, including any offence as defined in the Fraud Act Bribery - Inducement for an action which is illegal, unethical or a breach of NICE policies. Inducements can take the form of gifts, loans, fees, rewards or other advantages. This can be defined as the offering or acceptance of inducements, gifts, favours, payment or benefit-in-kind which may influence the action of any person. Bribery does not always result in a loss. The corrupt person may not benefit directly from their deeds, but they may be unreasonably using their position to give some advantage to another. It is a common law offence of bribery to bribe the holder of a public office and it is similarly an offence for the office holder to accept a bribe. Scope 7. This policy relates to all forms of fraud and bribery and provides guidance and help to anyone who may identify suspected fraud or bribery and outlines sanctions available where an offence is suspected. 3

4 8. This policy applies to NICE staff (including those on secondment to other organisations) and the following groups of people working for or on behalf of NICE. This document describes these (non-staff) groups collectively as affiliates : committee chairs and members and remunerated expert advisers non-executive directors agency workers and contractors on temporary contract or employed through an agency to work for NICE secondees (those who are seconded to NICE from other organisations) unpaid student, volunteers or placement staff 9. It will be brought to the attention of all staff and affiliates as part of the induction process. It is incumbent on all of the above to report any concerns they may have concerning fraud and bribery. Policy 10. All staff and affiliates have a responsibility to protect the assets of NICE, from fraud, theft, or bribery. 11. NICE is committed to maintaining an honest, professional and open atmosphere within the work place, in order to fulfil the objectives of NICE. In doing so it is committed to the elimination of fraud or bribery and any allegations of an offence will be rigorously investigated. In all cases appropriate action will be taken against alleged offenders, including possible criminal prosecution and the recovery of any assets lost as a result of fraud. 12. Staff and affiliates should be alert to the risk of fraud and bribery including, but not exclusively, the following: Deception or falsification of records (eg expense claims) Corruption in procurement processes Misuse of sick leave (eg working elsewhere while on sick leave) Any attempt to fraudulently influence NICE guidance decisions. 13. Staff and affiliates having reasonable suspicions of fraud should report them in accordance with the procedure in Appendix A. It is recognised that, while cases of alleged theft are usually obvious, there may initially only be a suspicion regarding potential fraud or bribery and accordingly the matter should be reported to the Business Planning and Resources Director, the chair of the NICE Audit and Risk Committee, the Head of Internal Audit, or the Department of Health s (DH) Anti-Fraud Unit as detailed in Appendix A who will ensure that the correct procedures are followed. NICE will ensure that no individual will suffer any detrimental treatment as a result of reporting reasonably held suspicions. The Public Interest Disclosure Act 1998 gives statutory protection, within defined parameters, to staff who make disclosures about a range of subjects, including fraud and bribery, which they believe to be happening within the organisation employing them. Within this context, reasonably held means suspicions other than those which are raised maliciously and are subsequently found to be groundless. 14. Unfounded or malicious allegations will be subject to a full investigation and appropriate disciplinary action in accordance with NICE policies. 4

5 15. Bribing anybody or accepting a bribe is prohibited. This means that you must not offer or receive any promise, reward in any way or give a financial or other advantage to any person in order to induce that person to perform his/her function or activities improperly. Gifts or hospitality should not be accepted in relation to the development of NICE guidance or other products and any suspicion that an offer of gifts or hospitality is being made as an attempt to influence NICE guidance decisions should be promptly reported to the Business Planning and Resources Director or the chair of the NICE Audit and Risk Committee. Gifts and hospitality must not be accepted except as permitted under the NICE Gifts and Hospitality policy. 16. NICE procures goods and services ethically and transparently with the quality, price and value for money determining the successful supplier/contractor, not by receiving (or offering) improper benefits. NICE will not engage in any form of bribery in its procurement processes. 17. NICE may, in certain circumstances, be held responsible for acts of bribery committed by intermediaries acting on its behalf such as subsidiaries, clients, contractors, suppliers, agents, advisors, consultants or other third parties. The use of intermediaries for the purpose of committing acts of bribery is prohibited. 18. NICE will contractually require its agents and other intermediaries to comply with the Anti-Bribery Act 2010 and to keep proper books and records available for inspection by NICE or investigating authorities to enable Counter-Fraud and Anti-Corruption activities. Roles and responsibilities Chief Executive 19. The Chief Executive of NICE is liable to be called to account for specific failures in the NICE system of internal controls. However, responsibility for the operation and maintenance of controls falls directly to line managers and requires the involvement of all of NICE staff. Staff and affiliates 20. All staff and affiliates should be aware that fraud and bribery will normally, dependent upon the circumstances of the case, be regarded as gross misconduct which may result in dismissal. However, no such action will be taken before a proper investigation and a disciplinary hearing have taken place in accordance with NICE policies. Such actions may be in addition to the possibility of criminal prosecution. 21. Staff and affiliates will not request or receive a bribe from anybody, nor imply that such an act might be considered. This means that you will not agree to receive or accept a financial or other advantage from a former, current or future client, business partner, contractor or supplier or any other person as an incentive or reward to perform improperly your function or activities. 22. Staff and affiliates must act in accordance with the NICE Standards of Business Code of Conduct, Gifts and Hospitality and Conflicts of Interest policies which include guidance on the receipt of gifts or hospitality. 23. When a staff member or affiliate suspects that there has been fraud or bribery, they must report the matter to their line manager, the Business Planning and Resources Director or the chair of the NICE Audit and Risk Committee or directly to the DH Anti- Fraud Unit. 5

6 24. NICE wants all staff and affiliates to feel confident that they can expose any wrongdoing without any risk to themselves. In accordance with the provisions of the Public Interest Disclosure Act 1998, NICE has produced a whistleblowing policy. This procedure is intended to complement the NICE Anti-Fraud and Bribery Policy and code of business conduct and ensures there is full provision for staff to raise any concerns with others if they do not feel able to raise them with their line manager / management chain. Suspected fraud against the Department of Health and its Arms Length Bodies can also be reported anonymously through the NHS Fraud and Corruption Reporting Line or through NHS Protect s online form at Line managers 25. Line managers at all levels have a responsibility to ensure that an adequate system of internal control exists within their areas of responsibility and that those controls operate effectively. The responsibility for the prevention and detection of fraud and bribery therefore primarily rests with line managers. Business planning and resources director 26. The Business Planning and Resources Director, in consultation with the Chair of the Audit and Risk Committee or DH Anti-Fraud Unit as appropriate will decide whether there is sufficient cause to conduct an investigation, and whether the Police and External Audit need to be informed. He/she will ensure any losses arising from the fraud are recovered with decisions taken on a case by cases basis. DH Anti-Fraud Unit 27. Investigation of the majority cases of alleged fraud within NICE will be the responsibility of the DH Anti-Fraud Unit (AFU). The AFU is named in the current Regulation of Investigatory Powers Act (RIPA) bill, giving it additional powers to investigate cases and seek recovery of any monies lost. Chair of the audit and risk committee 28. The chair of the Audit and Risk Committee will be consulted on all serious cases of fraudulent activity and periodically commission reports from Internal Auditors to ensure the committee can receive assurance, on behalf of the Board, that counter fraud and anti-bribery controls at NICE remain robust with appropriate management oversight. Training 29. NICE will provide anti-bribery training to all relevant staff and affiliates and make them aware of our Anti-Fraud and Bribery Policy, including possible types of bribery, the risks of engaging in bribery activity, and how employees may report suspicion of bribery. This training may be provided by the DH Anti-Fraud Unit. Disciplinary Action 30. NICE disciplinary procedures may be applied where an employee is suspected of being involved in a fraudulent or other illegal act. 31. It should be noted, however, that the duty to follow disciplinary procedures will not override the need for legal action to be taken (e.g. consideration of criminal action). In the event of doubt, legal statute shall prevail. 6

7 Further information 32. Legislation relating to fraud and bribery is complex. If anyone has any concerns about the interpretation of the Acts they should contact the Business Planning and Resources Director or the chair of the NICE Audit and Risk Committee or the Head of Internal Audit as detailed in Appendix A for advice. 33. NICE may be required to report details of frauds to its sponsoring Department and to HM Treasury from time to time. This allows departments and agencies to learn from the experiences of others when reviewing and developing their own systems. It also aims to increase awareness of fraud risk in specific areas and suggests ways in which the risk can be managed and reduced. Review 34. This policy will be monitored by the Corporate Office and reviewed every 3 years. Related policies Whistleblowing Policy Standards of Business Code of Conduct Disciplinary Policy and Procedure Conflicts of Interest Policy Gifts and Hospitality Policy 7

8 Appendix A National Institute for Health and Care Excellence ACTION TO BE TAKEN IF YOU DISCOVER OR SUSPECT ANY FRAUDULENT ACTIVITY! This includes: Fraud Any deliberate intention to make a gain for themselves or anyone else, or inflicting a loss (or a risk of loss) on another.this could be through the falsification of any records or documents or obtaining any service(s) and/or failing to disclose information. Bribery Anything that induces or intends to induce improper performance. This covers offering, promising or giving a bribe, requesting, agreeing to receive or accepting a bribe, and failing to prevent bribery. Where someone is influenced by bribery, payment of benefit-in-kind to unreasonably use their position to give some advantage to another. What to do: If any of these concerns come to light you must immediately report your suspicions and what you have discovered to one of the following: 1. Your line manager 2. Ben Bennett, Business Planning and Resources Director 3. Jonathan Tross, Non- Executive Director and Chair of the Audit and Risk Committee 4. DH Anti-Fraud Unit, Pat Nolan or by k). 5. NHS Fraud and Corruption reporting line or NHS Protect s online form at They will liaise as necessary with: The Head of Internal Audit Jeremy Nolan, / / ) Patrick Nolan Investigations Manager DH Anti-Fraud Unit, Room GS02, Department of Health, Wellington House, Waterloo Road, London, SE1 8UG or Confidentiality will be maintained and all matters will be dealt with. You will not suffer any recriminations as a result of raising concerns You have protection under The Public Interest Disclosure Act Tell someone! DO Confidentiality will be respected. Any delay might cause the organisation to suffer further financial loss. Make a note of your concerns! Note all relevant details, what was said, the date time and names of all parties involved. Keep a record or copy any documentation that arouses your suspicion. DO NOT Confront the individual(s) with your suspicions. Try to investigate the matter yourself. Contact the police directly. Convey your suspicions to anyone other than those with the proper authority as listed. Discuss suspicions, case facts or the investigation with anyone unless advised otherwise by the AFU, and this includes colleagues in and outside of NICE. Do nothing! 8

9 Appendix B - Version Control Sheet Version Date Author Replaces Comment 2 October November 2016 Corporate Office Corporate Office Counter Fraud and Anti-Bribery Policy May 2012 Counter Fraud and Anti-Bribery Policy October 2013 Amended to reflect role of the DH AFU and to reference NHS Fraud and Corruption Reporting Line 9

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