Corporate publications

East Sussex Healthcare NHS Trust is committed to applying the highest standards of ethical conduct and integrity throughout its operations. We are also committed to delivering the highest standards of patient care and hence are focused on safeguarding the funds needed for this.

Bribery is defined within the Bribery Act 2010 as the giving or receiving of a financial or other advantage in exchange for improperly performing a relevant function or activity.

Under no circumstances is the giving, offering, receiving or soliciting of a bribe acceptable, and the Trust will not tolerate this in any form. This applies to all staff and non-executives, together with any external agents working or acting on behalf of the Trust.

The Trust’s zero tolerance approach to bribery, and commitment to the Bribery Act 2010, is set out in further detail within the Counter Fraud and Anti-Bribery Policy, and across a range of other Trust policies and procedural documentation. All staff, non-executives and other relevant parties are responsible for familiarising themselves with the requirements surrounding this and for complying with these at all times.

Any instances of non-compliance will be dealt with firmly and, in addition to possible internal disciplinary action, it is noted that a criminal offence under the Bribery Act 2010 could lead to up to 10 years imprisonment and/or an unlimited fine.

With regard to external parties, we will not do business with anyone who does not support the Trust’s anti-bribery commitments, and we reserve the right to terminate any existing contracts where there is evidence that acts of bribery have been committed.

If you are in any doubt as to whether any conduct could amount to bribery, or if you have any concerns or suspicions regarding bribery being committed, please refer to the contact details within the Trust’s Counter Fraud and Anti-Bribery Policy, or the Whistleblowing Policy. Such a response is critical to the success of the Trust’s anti-bribery measures and we will support anyone raising an issue, provided that you are acting in good faith.

Joe Chadwick-Bell
Chief Executive

Within 28 days of an appointment being made, NHS trusts are required to publish a notice to name the appointed external auditor; the length of the appointment; the advice, or a summary of the advice received from the auditor panel; and, where it has not accepted that advice, the reasons why not.

East Sussex Healthcare NHS Trust has appointed a local external auditor in line with the Local Audit and Accountability Act 2014. Following due process, Grant Thornton LLP has been appointed for a period of three years plus an option for two additional years commencing 1st April 2022. The appointment was made on the advice of an Auditor Appointment Panel who agreed the procurement process followed and recommended the appointment of the preferred bidder following evaluation. The Trust Board accepted the recommendation of the Panel and agreed the appointment at its meeting on 13th December 2022.

Our staff work hard to deliver the highest standards of healthcare to the people of East Sussex.

We provide safe and effective care to many thousands of people every year but sometimes, despite our best efforts, things can go wrong. By ‘being open’ we make a commitment to our patients, their families and carers to:

• Respect your privacy and confidentiality
• Explain exactly what went wrong, and where possible, why things went wrong
• Let you tell us about your experience and ask questions.
• Acknowledge any distress the incident may have caused and offer a sincere and compassionate apology for what has happened.
• Discuss what is going to happen next and tell you what we will be implementing to prevent it from happening again.
• Offer support and counselling services that may be able to help

You may feel anxious about talking through your experience with the people who have been treating you, especially if you need further treatment. We can assure you that this will not have a negative impact on your future care and you will continue to be treated with respect and compassion.

Talking through the issues may help you cope better in dealing with what has gone wrong if you understand why it went wrong in the first place.

If you do not feel comfortable discussing your concern with the staff involved with your care you can contact our Patient Advice and Liaison Service (PALS).

If something goes wrong for patients whilst under the care of the NHS, patients and their relatives must be informed in a timely way by that organisation.

This is known as the ‘Duty of Candour’. It is important we acknowledge when things go wrong, and ensure we learn from them to prevent them happening again where possible. We take the safety of our patients very seriously.

If something goes wrong for a patient in our care we will:

• Advise that an incident has occurred giving a truthful account of all the facts that are known, and apologise (this does not mean we accept liability) that this has happened
• Discuss what further enquiries will be undertaken by the Trust
• Record this information appropriately in a timely manner.

A letter containing the following information will be issued:

• An account of the information that was verbally delivered to you or your relative
• A detailed account of any further enquiries that will be undertaken
• The results of any enquiries already

Our commitment to minimising mixed sex (gender) accommodation

We remain committed to ensuring and protecting the privacy and dignity for all our patients. Part of this relates to sleeping accommodation.

In hospital, our sleeping accommodation is largely binary with male and female bays and a number of single side rooms. These are usually used either for infection control purposes or for other clinical reasons.

We will always try to treat patients in the “right” bed in the right specialty and will not mix except where it is in the overall best interest of the patient. This would usually relate to specialist treatment, for example intensive or critical care or specialist services such as acute stroke.

We monitor this very closely and report on it nationally to ensure transparency. If there is a need to mix, we will explain the reason why. We are committed to providing every patient with same gender accommodation, because it helps to safeguard their privacy and dignity when they are often at their most vulnerable.

We will not turn patients away just because a gender appropriate bed is not immediately available.

What does this mean for patients?

If you need help to use the toilet or take a bath (for example if you need a hoist or special bath) then you may be taken to a bathroom used at different times by different people including men, women, trans men and women and people who identify as non-binary. A member of staff will support you to ensure your privacy is maintained.

Our hospitals and services reflect society and you will meet people of a different gender to you during your stay with us. This may be on your ward or when moving around the hospital and will include our staff, other patients and visitors to patients.

You may also find that you will share some communal space, such as day rooms or dining rooms.

How will we measure success?

Every day we will make an assessment of all our areas and review any incident where same gender accommodation has not been provided. Should this occur, it will be rectified as soon as possible.

What do you do if you have concerns?

If you have any concerns or queries, please feel free to discuss this with the nurse in charge of your area or our Patient Advice and Liaison Service (PALS) team.

Vikki Carruth
Chief Nurse and Director of Infection Prevention and Control

As an NHS trust we are committed to working towards eradicating modern slavery and human trafficking. We will actively ensure this by an ongoing review of all of our strategies and business arrangements.

Modern slavery is the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. Individuals may be trafficked into, out of or within the UK, and they may be trafficked for a number of reasons including sexual exploitation, forced labour, domestic servitude and organ harvesting.

The Modern Slavery Act 2015 introduced changes in UK law and focused on increasing transparency in supply chains, to ensure they are free from modern slavery (that is, slavery, servitude, forced and compulsory labour and human trafficking). ESHT is committed to working with local partners to improve our practice in combatting slavery and human trafficking and to raise awareness, disrupt and respond to Modern Slavery.

Arrangements to prevent slavery and human trafficking

We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or any part of our business activity. As an organisation, our commitment to social and environmental responsibility is covered by our approach to modern slavery and human trafficking, which is part of our safeguarding strategy and arrangements. Our arrangements include the following:

Safeguarding

Our Child Safeguarding Policy and Procedures and Safeguarding Adults Policy and Procedures show our commitment to the eradication of modern slavery.

Workforce

We confirm the identities of all new employees and their right to work in the United Kingdom. Our Dignity and Respect at Work, Resolution and Freedom to Speak up policies additionally give a platform for our employees to raise concerns about poor working practice. Policies on recruitment, and raising concerns via the Freedom To Speak Up process also support good practice and protect workforce rights further.

Our online safeguarding training courses include role relevant modern slavery awareness. The trust promotes awareness of modern slavery via online e-learning and our staff extranet pages provides support and resources on modern slavery and human trafficking.

Suppliers and contracts

We comply with the Public Contracts Regulations 2015.

We use NHS Terms and Conditions for Goods and Services for specification and tender documents which require suppliers to comply with all relevant legislation and guidance, including the Modern Slavery Act 2015. We expect and require all our suppliers to comply with all local, national and international laws and regulations, and to have their own processes and policies regarding modern slavery and human trafficking that comply with our values.

NHS Supply Chain, a significant supplier to the trust, have a robust vendor vetting process, on-going inspections, supplier code of conduct and are working towards completing the Modern Slavery Assessment Tool for their suppliers. NHS Supply Chain is owned and operated via SCCL Ltd, a wholly owned subsidiary of NHS England

We use the statutory Crown Commercial Services (CCS) Pre-Qualification Questionnaire on procurements, which exceed the prescribed threshold. Bidders are required to confirm their compliance with the Modern Slavery Act 2015.

We’ve adopted the Government’s Social Value Model (Procurement Policy Note 06/20), which requires a minimum 10% weighting in all procurements dedicated to Net Zero and Social Value, including the elimination of Modern Slavery.

Our procurement team is qualified and experienced in managing contracts and we use our routine contract management meetings with our providers to ensure ongoing compliance with the contract terms.

This above statement on Modern Slavery, is made pursuant to section 52 of the Modern Slavery Act 2015 and therefore constitutes our slavery and human trafficking statement for 2023/24.

If you suspect someone could be a victim of modern slavery, contact Sussex Police on 999, 101 or through the Sussex Police website.

Alternatively, you can call the Modern Slavery Helpline on 08000 121 700, Crime Stoppers on 0800 555 111 or the Salvation Army confidential hotline on 0800 808 3733. All are open 24 hours a day, 365 days a year.

Our patient safety incident response framework (PSIRF) replaces the serious incident response framework, and outlines how we should respond to patient safety incidents for the purpose of learning and improvement.

It represents a significant shift in the way the NHS responds to patient safety incidents, centring on compassion and involving those affected; system based approaches to learning and improvement; considered and proportionate responses; and supportive oversight.

Quality Accounts are reports from NHS providers about the quality of the services we provide. The report is published annually, with the most recent version of our Quality Account available below.

Quality Accounts enable patients and their carers to make informed choices about providers of healthcare, enable the public to hold providers to account for the quality of the services they deliver and engage leaders in the quality improvement agenda.

The quality of our services is measured by looking at:

• patient safety
• how effective patient treatments are
• patient feedback about care provided

We develop the quality improvement priorities for the next year by asking members of the public their views which are considered alongside those from our clinicians and staff, with the final priorities agreed by our executive team. The priorities that are selected will feature in our Quality Account for the year ahead.

The Re-Use of Public Sector Information Regulations give the public and the private sector the right to re-use public sector information which the Trust produces as part of its Public Task.

The new Re-Use of Public Sector Information Regulations 2015 came into force on 18th July 2015 and replace the 2005 Regulations.

What are the RoPSI regulations?

The Re-Use of Public Sector Information (RoPSI) regulations govern the re-use of information created and used by Public Authorities in the UK as part of fulfilling their public task. Re-using the information means to use it for a purpose other than the initial public task it was produced for.

Access to the corporate information of Public Authorities is provided under Freedom of Information legislation. The RoPSI regulations do not change the provisions for accessing our information but provide the public and the private sector with a framework to re-use this information once it has been disclosed.

The RoPSI regulations are about encouraging the re-use of public sector information and governing how it is made available.

Further guidance on the RoPSI regulations has been created by the ICO and the National Archives:

What information is covered?

Public sector information is information which we produce as part of our public task. Our public task is our core roles and functions as defined by legislation and regulations. Information on our public task, such as the services we provide and our key functions, can be found in the ‘About us‘ section of our website.

Information which is not within the scope of our public task is not covered by RoPSI regulations.

Information is not covered by RoPSI regulations if it would be exempt from disclosure under information access legislation like the Freedom of Information Act or the Data Protection Act.

How to make a request for re-use

If you would like to make a request for re-use under the RoPSI regulations you need to contact us in writing (preferably by email), include your name and address for correspondence, specify the information you want to re-use, and specify the purpose you intend to use it for.

Costs and licensing

Please note that where East Sussex Healthcare NHS Trust permits re-use of information under the Re-Use of Public Sector Information Regulations 2015 it is licensed under the Open Government Licence.

East Sussex Healthcare NHS Trust will, as a matter of routine, not charge for the re-use of information beyond reasonable disbursement costs (printing, postage, etc.) as per our Freedom of Information process.

Please note that East Sussex Healthcare NHS Trust reserves the right to charge for re-use (such as where a small return on investment is reasonable) and to licence more restrictively where appropriate.

If our standard practice of allowing free-of-charge, Open Government Licence governed re-use will not apply to an application for re-use, this will be discussed with and communicated to the applicant as soon as it becomes apparent.

Appeals and complaints procedure

Internal complaints process
Please ensure that you submit any complaints in writing, state the nature of the complaint in detail, and explain what you hope the outcome of your complaint will be. Please ensure you send these to the address below within 40 working days of the date of our response to your request. We regret that we will not respond to any complaints outside of the 40 working day period.

Your complaint will be reviewed and a response sent to you within 20 working days of submission.

Complain to the ICO

If your complaint is not resolved to your complete satisfaction, you have the right to appeal to the Information Commissioner for a decision. The Information Commissioner’s Office can be contacted by way of letter addressed to:

• East Sussex Healthcare NHS Trust are fully committed to providing the highest standards of child and adult protection and have undertaken a recent review in light of the Care Quality Commission (CQC) report. As well as this we work closely with our Local Safeguarding Board partners to scrutinise the Safeguarding provision and Safeguarding cases within our organisation.
• The trust board is confident that the organisation meets the recommendations stated within the CQC report and makes the following declaration as requested by the Department of Health.
• The trust meets the statutory requirements in relation to the Criminal Records Bureau checks. The Trust has a fully implemented Recruitment and Selection policy in place. The policy sets out the process for criminal records checks which the Trust will undertake for the appointment and ongoing employment of all relevant individuals within the trust.
• Safeguarding policies and systems are up-to-date and robust, including a process for following up children and young people who miss outpatient appointments and a system for flagging when there are safeguarding concerns. The trust safeguarding policies are regularly reviewed providing information and assurance to the Board of Directors.
• The trust provides safeguarding training to all staff during their induction to the organisation and level 2 training to all patient/client facing staff who may be in regular contact with children, young people, their parents and adults. In addition level 3 training is provided to staff who work predominantly with children, young people and parents. Regular updates of level 2 and 3 training are provided as per our Safeguarding Children Training Strategy. Recently level 3 safeguarding adults training is being implemented along with safeguarding supervision to support clinical staff who are working with complex cases in the Acute and Community.
• The trust has named professionals who lead on issues in relation to safeguarding. They are clear about their role, have sufficient time and receive relevant support, supervision and training to undertake these roles.
• There is a Board level Executive Director for safeguarding. The Board reviews safeguarding across the organisation at least once a year and has robust audit programmes in place to assure it that safeguarding systems and processes are working effectively.
• The Board takes the issue of safeguarding extremely seriously and receives an annual report upon safeguarding provision and themes from a local and national perspective.