The Bribery Act 2010 came into effect on 1 July 2011. Bribery is generally defined as giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so. The maximum penalty for bribery is 10 years imprisonment, with an unlimited fine. In addition the Act introduces a corporate offence of failing to prevent bribery by an organisation not having adequate preventative procedures in place. The organisation may avoid conviction if it can show that it had procedures and protocols in place to prevent bribery. The corporate offence is not a stand-alone offence, but always follows from a bribery and/or corruption offence committed by an individual associated with the company or organisation in question.
As a result, and in line with national guidance from the NHS Counter Fraud Authority, the Interim Shared Accountable Officer and Chief Finance Officer of NHS West Lancashire have signed a statement to say that the CCG will commit sufficient time and resources to the development and embedding of an appropriate anti-bribery programme to ensure the CCG is not subject to bribery.