Fraud and Bribery Statement from the Chief Executive
Portsmouth Hospitals University NHS Trust is committed to eliminating fraud, bribery and corruption within the NHS, protecting public resources for health and care. Fraud is an act of deception that is intended to make a gain or to cause a loss to another party. Bribery is generally defined as the giving or receiving of a financial or other advantage in exchange for improperly performing a relevant function or activity.
The Bribery Act 2010 came into force on 1 July 2011. The purpose of the Act is to prevent bribery and corruption in both the public and private sectors.
Bribery can be defined as the offering; promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal or a breach of trust. The Act has six principles, one of which is that there is top level commitment in the organisation to prevent and detect bribery. The Board of Directors is committed to this, and the Trust operates a zero-tolerance policy against fraud, bribery and corruption.
The Trust recognises the Economic Crime and Corporate Transparency Act 2023 which came into force on 1 September 2025 and has created the corporate offence of Failure to Prevent Fraud. This offence applies to all employees, contractors, and associated persons. The Trust are ensuring robust procedures are in place to prevent, detect, and investigate all forms of fraud and financial crime. We will always seek to pursue the strongest penalties against anyone involved in such activities.
Portsmouth Hospitals University NHS Trust employs a fraud specialist to provide a comprehensive programme to tackle fraud, bribery and corruption. The fraud specialist reports to the Chief Financial Officer and the Trust’s Audit Committee.
It is essential that everyone working for, or on behalf of, the Trust is aware of the standards of behaviour expected of them. These standards are set out in the Trust’s policies and procedures and reflect not only the law but the expectations of behaviour at Portsmouth Hospitals University NHS Trust.
As an NHS organisation we follow good NHS business practice and have robust controls in place to prevent fraud, bribery and corruption. As a Trust we cannot afford to be complacent and it is important that all our employees, contractors and agents comply with Trust policies and procedures, particularly regarding procurement and sponsorship.
On behalf of the Trust, I confirm our commitment to ensuring that all staff are aware of their responsibilities in relation to the prevention of fraud, bribery and corruption and that the risk of Trust exposure to any of these acts is mitigated.
We ask all who are involved with the work of the Trust – as employees, agents, trading partners, stakeholders and patients – to help us in our fight against fraud, bribery and corruption, and to contact us immediately if they have any concerns or suspicions. If you have any concerns or suspicions the Trust’s fraud specialist can be contacted in confidence.
Penny Emerit
IWT & PHU Group Chief Executive
October 2025