The counter fraud, bribery and corruption policy explains how NHS Essex prevents, detects and responds to fraud, bribery, corruption and other forms of economic crime. The policy sets out the responsibilities of staff, managers and senior leaders, as well as the processes for reporting concerns and investigating suspected wrongdoing.
For more information, read the full policy by downloading the accessible Word document at the end of this page.
Who the policy applies to
This policy applies to:
- all NHS Essex staff, including temporary, bank and agency workers
- contractors working on behalf of NHS Essex
- staff from partner organisations working on behalf of the Integrated Care Board
- external organisations and individuals who have a business relationship with NHS Essex
The policy applies to anyone who may have access to NHS resources, services or information.
Purpose of the policy
The counter fraud, bribery and corruption policy aims to:
- raise awareness of fraud, bribery and corruption risks
- promote a culture of openness and accountability
- support staff to report concerns confidently
- protect NHS resources from misuse
- ensure allegations are investigated appropriately
- support the recovery of losses where wrongdoing has occurred
- ensure appropriate sanctions are applied when offences are proven
NHS Essex’s approach
NHS Essex has a zero-tolerance approach to fraud, bribery and corruption.
The organisation is committed to:
- preventing economic crime wherever possible
- investigating all reasonable concerns
- taking disciplinary, civil or criminal action where appropriate
- recovering money or assets lost through fraud
- learning lessons to strengthen controls and prevent future incidents
What is fraud?
Fraud occurs when someone acts dishonestly with the intention of making a gain for themselves or causing a loss to another person or organisation.
Examples include:
- making false claims or statements
- failing to disclose information when legally required
- abusing a position of trust
- using false documents or qualifications
- obtaining services dishonestly
What is bribery and corruption?
Bribery involves offering, giving, requesting or accepting money, gifts or other advantages to influence decisions or actions improperly.
Corruption occurs when someone abuses their position for personal gain or to benefit others.
NHS Essex expects all staff and partners to act with honesty, integrity and transparency at all times.
Responsibilities
Everyone has a role in protecting NHS resources.
All staff must:
- act honestly and with integrity
- follow NHS Essex policies and procedures
- complete mandatory counter fraud training
- report concerns about suspected fraud, bribery or corruption
- cooperate with investigations when required
Managers must:
- maintain effective controls within their teams
- ensure staff understand fraud risks
- support completion of mandatory training
- report concerns immediately
- avoid carrying out their own investigations
The Local Counter Fraud Specialist (LCFS)
The LCFS leads counter fraud work within NHS Essex and is responsible for:
- investigating allegations of fraud, bribery and corruption
- providing advice and guidance
- carrying out risk assessments
- supporting prevention and awareness activities
- reporting progress and outcomes to senior leaders
Reporting concerns
If you suspect fraud, bribery or corruption:
- report your concerns as soon as possible
- preserve any relevant information or evidence
- seek advice from the Local Counter Fraud Specialist
You should not:
- investigate the matter yourself
- confront the person involved
- discuss your concerns with others who do not need to know
- contact external organisations directly about the allegation
Staff who raise genuine concerns in good faith are protected under whistleblowing legislation and NHS Essex’s Freedom to Speak Up arrangements.
Investigations and sanctions
Where allegations are substantiated, NHS Essex may take:
- disciplinary action
- civil action to recover losses
- criminal prosecution
- referral to professional regulators
The organisation will seek to recover NHS funds wherever possible and use lessons learned to strengthen controls and reduce future risk.
Staff training
All staff are required to complete mandatory counter fraud training.
Training helps staff recognise fraud risks, understand reporting procedures and contribute to a culture where fraud, bribery and corruption are not tolerated.
Policy review
This policy came into effect on 1 April 2026 and is due for review in April 2028.
For more information, read the full policy by downloading the accessible Word document below.