E13: Ethics Policy (Anti-bribery and corruption)

Anti-bribery and corruption

With the introduction of the UK Bribery Act 2010, ORMS has introduced appropriate procedures which are rigorously applied and reviewed to ensure that it is fully compliant with the provisions of the Bribery Act.

Our Anti-bribery and corruption statement is contained in E13 Ethics Policy; Conflicts of interest, Gifts and Hospitality are considered in E13a: Conflict of Interest Policy

This statement applies to any individual employee, agent or other person or body acting on behalf of ORMS Ltd.

Standards

ORMS embraces the values and high professional standards enshrined in the Nolan Principles and requires that these should be upheld by all employees of ORMS at all times. Regardless of whether ORMS is a private company, we support these principles. Many of our customers are public sector organisations and we need to demonstrate the same ethical values in our dealings with them and the wider community of training and health care professionals.

As a reminder, the Nolan Principles are:

  1. Selflessness – Holders of public office should act solely in terms of the public interest.
  2. Integrity – Holders of public office must avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work. They should not act or take decisions in order to gain financial or other material benefits for themselves, their family, or their friends. They must declare and resolve any interests and relationships
  3. Objectivity – Holders of public office must act and take decisions impartially, fairly and on merit, using the best evidence and without discrimination or bias.
  4. Accountability – Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.
  5. Openness: – Holders of public office should act and take decisions in an open and transparent manner. Information should not be withheld from the public unless there are clear and lawful reasons for so doing.
  6. Honesty: – Holders of public office should be truthful.
  7. Leadership: – Holders of public office should exhibit these principles in their own behaviour. They should actively promote and robustly support the principles and be willing to challenge poor behaviour wherever it occurs.

ORMS accepts that it has an obligation to all those with whom it has dealings – and this includes students, employees, suppliers, other institutions and organisations and the wider communities that ORMS serves – to observe and meet these standards. ORMS’ reputation and the trust and confidence of those with whom it deals are important attributes, the protection of which is of fundamental importance.

Obligations incumbent upon staff

Staff must act honestly, diligently and in good faith, placing the interests of ORMS at the forefront of their minds. The actions of staff must always seek to promote and protect the reputation of ORMS and decisions taken by staff must be to the benefit to ORMS and not for any improper or personal motive. Staff should avoid any action (or inaction) which would bring the reputation of ORMS into disrepute, would have the potential to do so or which might be perceived as doing so.

In carrying out their duties, staff must adhere to the seven Nolan principles of public life.

Staff must also adhere to all relevant regulations, policies and procedures published and updated by ORMS and available at https://intranet.orms247.co.uk/ .

Anti-bribery and corruption statement

  1. ORMS prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company.
  2. This prohibition applies to any individual employee, agent or other person or body acting on behalf of ORMS in order to gain any commercial, contractual or regulatory advantage for ORMS or to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.
  3. With the introduction of the UK Bribery Act 2010, ORMS has taken steps to introduce appropriate procedures which are rigorously applied and reviewed to ensure that it is fully compliant with the provisions of the Bribery Act.

Conflicts of Interest

Conflicts of interest, Gifts and Hospitality are considered in E13a: Conflict of Interest Policy

Research Ethics

Although ORMS does not primarily carry out research, where staff are representing ORMS and undertaking personal research, the following principles apply. We do not use live animals in any aspect of medical training.

  1. Researchers should be aware that all research carried out should be to the highest ethical standards possible, that it complies with all relevant laws including, where appropriate, laws of other countries; appropriate due diligence is undertaken to minimise risk; and finally, that it adheres to all relevant policies or codes of good practice.
  2. Researchers should ensure engagement in research does not cause unnecessary harm to participants, stakeholders, the environment, the economy and other living beings.
  3. The principles of beneficence and non-maleficence are fundamental to all research activity. Beneficence is the requirement to promote the interests and well-being of others. It is the ethical principle of ‘doing good’ in the widest sense. Non-maleficence is the principle of ‘not doing harm’. Both principles must be applied to all entities directly or indirectly affected by the research. In practice these principles frequently conflict, for example as in animal versus human welfare.
  4. Researchers have a moral obligation to attempt to minimise the risk of physical and/or mental harm to themselves, human and animal participants, research subjects, stakeholders and the environment which may result from their research.
  5. ORMS is committed to the principles of reduction, refinement and replacement of the use of animals in research. On each project it will ensure that the numbers of animals used is minimised and that procedures, care routines and husbandry are regularly reviewed and refined to maximise welfare. ORMS is committed to the development of alternative methods such as computer modelling, tissue culture and research with non-animal techniques wherever possible. Where the use of animals remains essential, ORMS is committed to a culture of care and respect for animal welfare.
  6. Advice to researchers on matters and procedures related to research ethics can be obtained from the Directors.

Confidentiality

Staff should be mindful of confidentiality and must not make public or private statements, outside of ORMS, regarding confidential business, without first seeking the permission of a Director

Hospitality, Gifts and Gratuities

Gifts and Hospitality are considered in E13a: Conflict of Interest Policy Failure to Comply

Non- compliance

Members of staff in material breach of the ethics policy or related procedures will be investigated and may be subject to disciplinary action.