Maidstone and Tunbridge Wells NHS Trust is committed to eliminating fraud, bribery, and corruption within the NHS, protecting public resources for health and care. The Trust does not tolerate any form of fraud, bribery, and corruption by its staff, agents, or consultants or any other persons or entities acting for or on its behalf. The Trust board and senior management are committed to implementing and enforcing effective systems throughout the Trust to prevent, deter, monitor, and eliminate fraud, bribery, and corruption.

The Trust’s Anti-Fraud, Bribery and Corruption Policy and Procedures applies to all Trust employees, bank and locum staff, patients, consultants, contractors, suppliers, internal and external stakeholders.

Fraud

Fraud involves dishonestly making a false representation, failing to disclose information or abusing a position held, with the intention of making a financial gain or causing a financial loss. The gain or loss does not have to succeed for fraud to have been perpetrated, as long as the intent is there. The Fraud Act 2006 came into force on 15 January 2007 and applies in England, Wales and Northern Ireland.

Under the Failure to Prevent Fraud offence, which comes into force on 1 September 2025, an organisation will be criminally liable where a fraud offence is committed by an employee, agent, or other ‘associated’ person, with the intention of deriving a benefit for the organisation or a related body; and, the organisation did not have ‘reasonable’ fraud prevention procedures in place. It does not need to be shown that managers ordered or knew about the fraud. The Trust falls within the scope of the offence as a large organisation.

Bribery

A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company, whether directly or indirectly, to induce or influence that individual or company to perform public or corporate functions or duties improperly. Employees and others acting for or on behalf of the Trust are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments.

To minimise the risk of unfounded allegations of bribery or corruption, if staff are offered hospitality or gifts or are considering offering any to another person they should refer to the Trust’s Conflicts of interest policy and procedure [RWF-COR-COR-POL-2]. This provides details of the circumstances in which this would be acceptable and the level which can be given or received. Staff are reminded that all hospitality and gifts received, offered or declined should be declared using the form accessible from the policy.

The Trust does not tolerate offences of fraud, bribery, or corruption, and will investigate any suspected acts of fraud, bribery, or corruption, misappropriation or irregularity and take full and appropriate action against any wrongdoing.

Reporting Your Concerns

Any information about suspicions of fraud, bribery, or corruption can be reported in confidence to the Trust’s Counter Fraud Team:

Andy Ede, Head of Investigations

• Email: andrew.ede1@nhs.net
• Mobile: 07919 595930

Hannah Wenlock, Anti-Crime Specialist

• Email: hannah.wenlock@nhs.net
• Mobile: 07919 595930

Genuine suspicions of fraud, bribery, and corruption may also be reported in confidence to the NHS Counter Fraud Authority’s Fraud and Corruption Reporting Line on 0800 028 40 60 or via https://cfa.nhs.uk/reportfraud.

Steve Orpin

Deputy Chief Executive / Chief Finance Officer