Modern Slavery Statement
Modern slavery is the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation.
Individuals may be trafficked into, out of or within the UK, and they may be trafficked for a number of reasons including sexual exploitation, forced labour, domestic servitude and organ harvesting.
The Home Office estimates there are 13,000 victims and survivors of modern slavery in the UK; 55% of these are female and 35% of all victims are trafficked for sexual exploitation.
In accordance with the Modern Slavery Act 2015, Bedfordshire Hospitals NHS Foundation Trust incorporates clauses within our terms and conditions to ensure that modern slavery, i.e. slavery and human trafficking, is not taking place in any part of our business or our supply chains.
Bribery and Corruption & Conflicts of Interest
Bribery and corruption are also a key concern to the NHS. They involve the offering, promising or giving a payment of benefit-in-kind to influence others to use their position in an improper way to gain an advantage. Bribery does not have to involve cash, or an actual payment exchanging hands, and the corrupt person may not benefit directly from their deeds, however, they may be unreasonably using their position to give some advantage to another.
The risk of bribery is more common in some roles than others. For example, staff in a procurement team might be offered bribes when large contracts are being awarded.
It is an offence to give or receive a bribe, or even offer or agree to accept a bribe, even if the bribe is never paid. The three main offences under the Bribery Act 2010 most relevant to the NHS are:
- Giving a bribe: offering, promising or giving a bribe to another person for them to perform a relevant function or activity improperly;
- Receiving a bribe: requesting, agreeing to receive or accepting a bribe to perform a function or activity improperly; and
- Corporate offence: failure of a commercial organisation to prevent bribery.
The NHS takes bribery and corruption very seriously. If you feel someone is trying to unduly influence you or your decisions, please talk to the LCFS as soon as possible.
Below are some examples of the types of bribery and corruption committed against the NHS.
Conflicts of Interest
NHS England define a conflict of interest as, ‘a set of circumstances by which a reasonable person would consider that an individual’s ability to apply judgement or act, in the context of delivering, commissioning, or assuring taxpayer funded health and care services is, or could be, impaired or influenced by another interest they hold’.
There are several types of conflicts that could arise:
- Direct financial interest: when a staff member obtains a direct financial benefit from the consequences of a decision they are involved in making, which is most likely to arise from the award of a contract to a company or other business with which that staff member is involved;
- Indirect financial interest: when a close relative, or another individual a staff member has a ‘close association with, would stand to benefit from the decision.
- Non-financial or personal conflicts: where a staff member receives no financial benefit from the decision, but could be influenced by other external factors such as increasing their professional reputation, promoting their professional career or by gaining some other intangible benefit or kudos;
- Conflict of loyalties: competing loyalties may occur between the organisation to which a staff member owes a primary duty (i.e. the Trust) and some other person or entity. This could:
- inhibit free discussion, such as at board or committee meetings;
- result in decisions or actions that are not in the interests of the Trust; and
- risk appearing that the Trust has acted improperly.
Conflicts may be actual, in that there is a material conflict between interests, or potential, where there is a possibility of a material conflict in the future.
In line with the NHS Standard Contract 2021/22 General Conditions (Full Length) the Trust is now required to publish the name and position of any Decision-Making Staff (Band 8a and above) that failed to complete a declaration of interest or a nil return within the contract year. (NHS England Conflicts of Interest guidance – section 4.5).