GovS 013 component 12: Policies and registers for gifts and hospitality and COI
Have policies and registers for gifts and hospitality and conflicts of interest
GovS 013 ref: 5.8
The organisation has a managing conflicts of interest policy and registers that include gifts and hospitality with reference to fraud, bribery and corruption, and the requirements of the Bribery Act 2010. The effectiveness of the implementation of the process and staff awareness of the requirements of the policy are regularly tested.
The Bribery Act 2010 Section 7 – Failure of a commercial organisation to prevent bribery (corporate offence). An organisation may avoid conviction if it can show that it had procedures and protocols in place to prevent bribery. A GREEN rating from the NHSCFA is not in itself assurance that the organisation has adequate procedures and protocols in place in order to rely upon this defence.
Organisations should consider the following (the list is not exhaustive):
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