As an NHS trust, we are sometimes required by regulators and commissioners to publish public statements and declarations.

We may also respond to key issues and relevant topics to support patients, staff and the local communities we serve. You can read more about these below.

Racism does not have a place in our organisation. In 2020 we published an anti-racist statement, publicly pledging our commitment to become anti-racist.

Under our standards of business conduct policy, it is the responsibility for all staff to ensure they are not placed in a position which risks or appears to risk conflict between their private interests and NHS duties.

You can see the latest declarations from our Board of Directors and Council of Governors on these pages:

Where our staff are offered gifts, hospitality or entertainment, these should be declined unless they are of low intrinsic value. Any which are accepted should be formally registered. View the latest gift and hospitality reports.

Under the Freedom of Information Act (2000), you can request any recorded information that is held by Pennine Care.

We publish all previous Freedom of Information requests received by Pennine Care and also publish our spending over £25,000.

Chief executive statement on the new 'failure to prevent fraud' offence and other financial crimes against the NHS

On 1 September 2025 a new fraud offence came into force. This is a corporate offence of ‘failure to prevent fraud’, which is part of the Economic Crime and Corporate Transparency Act 2023.

This new type of fraud occurs where someone connected with the organisation (what the Act calls an ‘associated person’) commits a fraud offence that intentionally benefits the Trust, or a related body, rather than just the individual, and where the Trust should have had reasonable procedures in place to prevent this from happening.

In these circumstances the legislation holds large organisations (including NHS organisations) criminally liable.

An ‘associated person’ can be any employee of Pennine Care, including volunteers, as well as contractors, subsidiaries, agents and other service providers or partner organisations.

Any breach of this new law could mean Pennine Care is criminally prosecuted and subject to an unlimited fine unless it has put reasonable anti-fraud measures in place even if these were intentionally ignored or by-passed.

I can assure everyone that this organisation takes its responsibilities very seriously and we have been working with our anti-fraud provider (MIAA - Mersey Internal Audit Agency) to ensure all ‘associated persons’ know their responsibilities in this area and that robust arrangements to prevent all forms of fraud, bribery or corruption are in place.

Visit the NHS Counter Fraud Authority website to read about the new legislation in more detail, or you can speak to our dedicated anti-fraud specialist whose contact
details can be found below and in our anti-fraud policy.

Tackling financial crime against the NHS

In addition to the new ‘failure to prevent fraud’ offence, there are other existing fraud, bribery and corruption offences in place, and now is a good time to re-affirm that Pennine Care takes a vigorous, zero tolerance, approach to those who commit any of these offences against the NHS.

Anyone who commits fraud against Pennine Care could be subject to any, and all, sanctions available (criminal, civil, disciplinary, and regulatory body). Pennine Care employs MIAA to undertake anti-fraud, bribery and corruption work and we will provide the necessary resources to enable our anti-fraud specialists to conduct criminal enquiries against any alleged perpetrators of such offences.

In addition, Pennine Care does not, and will not, pay bribes or offer improper inducements to anyone for any purpose; nor do we, nor will we, accept bribes or improper inducements. This approach applies to everyone who works for us, or with us. To use a third party as a conduit to channel bribes to others is a criminal offence. We do not, and will not, engage indirectly in, or otherwise encourage, bribery.

Counter measures

Pennine Care is committed to the prevention, deterrence and detection of fraud, bribery, and corruption. To this end, everyone associated with the Pennine Care is expected to play their part and act in accordance with both the law and all our policies and procedures.

Pennine Care adopts and implements the ‘reasonable procedures’ approach suggested by the new ‘failure to prevent fraud’ offence (and which are similar to the ‘adequate procedures’ introduced in relation to the Bribery Act 2010).

The approach will, amongst other steps, involve:

  • Top-level commitment: Active involvement and leadership from senior management, with a clear culture established and embedded from the top to ensure a ‘no tolerance’ approach towards fraud, bribery, and corruption.
  • Risk Assessment: Regular identification and evaluation of fraud and corruption risks across all levels of the organisation, including third-party and supply chain risks.
  • Proportionate risk-based prevention procedures: Tailored fraud controls that are suitable for the organisation’s specific fraud risk exposure and complexity.
  • Due diligence: Assessing the background, integrity, and reliability of individuals or entities performing services for or on behalf of the organisation.
  • Communication (including training): Ensuring staff, contractors, and associates understand fraud policies and risks through regular awareness training.
  • Monitoring and review: Continual evaluation of the effectiveness of fraud, bribery, and corruption prevention measures, with regular updates based on new risks or incidents.
Reporting concerns

If you have any concerns or suspicions regarding bribery, corruption, or fraud, please contact:

The Provider Selection Regime (PSR) is a set of rules that governs how NHS England, NHS trusts like Pennine Care, and local authorities procure healthcare services.

Visit our provider selection regime page for more information about the rules and process, and an annual summary of the contracts we have awarded.

We are committed to ensuring that no modern slavery or human trafficking takes place in any part of our business or our supply chain. Visit our safeguarding page to read our modern slavery statement.

We have a zero tolerance approach to discrimination, victimisation or harassment on the basis of a person’s gender identity. In 2021 we published a transgender and non-binary statement to publicly reinforce this approach.

We have published a full statement on the accessibility of this website and some of the work we are doing to improve it. Read our accessibility statement.

We are committed to being a fair and inclusive employer and monitor how we’re doing by publishing these reports:

Working closer together - Pennine Care and Greater Manchester Mental Health NHS

We have agreed that our two organisations will work together even more closely in the coming months and years to improve care for our patients, the communities we serve and make the best use of public money.

Read the full statement made jointly by our chairs and chief executives.