Code of Business Conduct

Does this document meet the requirements of the Equality Act 2010 in relation to Race, Religion and Belief, Age, Disability, Gender, Sexual Orientation, Gender Identity, Pregnancy & Maternity, Marriage and Civil Partnership, Carers, Human Rights and Social Economic Deprivation discrimination?  Yes

Document for Public Display: Yes

Evidence reviewed by Library Services: tbc

Introduction

Lancashire Teaching Hospitals NHS Foundation Trust and the people who work with and for us, collaborate closely with other organisations, delivering high quality care for our patients. These partnerships have many benefits and should help ensure that public money is spent efficiently and wisely. But there is a risk that conflicts of interest may arise.

Providing best value for taxpayers and ensuring that decisions are taken transparently and clearly, are both key principles in the NHS Constitution.  We are committed to maximising our resources for the benefit of the whole community.  As an organisation and as individuals, we have a duty to ensure that all our dealings are conducted to the highest standards of integrity and that NHS monies are used wisely so that we are using our finite resources in the best interests of patients.

Purpose

The purpose of the Code of Business Conduct is to ensure that everyone involved in the Trust maintains a high standard of propriety in the way they conduct themselves. This Code of Business Conduct is intended to ensure that the actions of those acting on behalf of the Trust are both lawful and in line with the high standards expected. This Code of Business Conduct also provides support and guidance for making appropriate judgement and decisions, to protect the Trust’s Staff and Governors from any suspicion of fraud, bribery or corruption.

The Code of Business Conduct applies at all times when individuals are carrying out Trust business or representing the Trust. The Code of Business Conduct does not relate to activities undertaken in a personal capacity, except where the personal conduct could reasonably be regarded as bringing the Trust as a whole, its division, departments or a particular office into disrepute.

Providing best value for taxpayers and ensuring that decisions are taken transparently and clearly, are both key principles in the NHS Constitution. We are committed to maximising our resources for the benefit of the whole community. As an organisation and as individuals, we have a duty to ensure that all our dealings are conducted to the highest standards of integrity and that NHS monies are used wisely so that we are using our finite resources in the best interests of patients.

This Code of Business Conduct will help our staff manage conflicts of interest risks effectively. It:

• Introduces consistent principles and rules
• Provides simple advice about what to do in common situations.
• Supports good judgement about how to approach and manage interests

Scope

Whilst the Code of Business Conduct makes reference to and contains basic information about some of the Trust’s policies, it is not intended to cover every situation; and should therefore be read in conjunction with the relevant policies and any additional professional conduct regulations that may be appropriate.

In particular, the Code of Business Conduct should be read in conjunction with:

• The Code of Conduct for Employees;
• The Anti-Fraud, Bribery and Corruption Policy;
• The Disciplinary Policy and Procedure;
• The Raising Concerns Policy;
• The Trust Constitution;
• The Board’s Standing Orders; and
• The Standing Financial Instructions.

These policies are available to view via the Trust’s Heritage system.
 

Key Terms

In this Code of Business Conduct, the following key terms apply:

'Staff'

At the Trust we use the skills of many different people, all of whom are vital to our work. This includes people on differing employment and engagement terms, who for the purposes of this Code we refer to as ‘Staff’ and are listed below:

• All salaried employees, full or part time, irrespective of role, grade or status
• Non-executive directors
• All prospective employees – who are part-way through recruitment
• Volunteers (including governors)
• Contractors and sub-contractors and others employed under a contract for service
• Agency and bank staff
• Committee, sub-committee and advisory group members (who may not be directly employed or engaged by the organisation)
• Employees of wholly owned subsidiary vehicles

Some staff are more likely than others to have a decision-making influence on the use of taxpayers’ money, because of the requirements of their role.

For the purposes of the Code of Business Conduct these people are referred to as ‘decision making staff.’

‘Decision making staff’ in this organisation are:

• Executive and non-executive directors (or equivalent roles) who have decision making roles which involve the spending of taxpayers’ money
• Those at Agenda for Change band 8d and above
• All consultants
• Procurement staff involved in decision making concerning the commissioning of services, purchasing of good, medicines, medical devices or equipment, and formulary decisions
• Administrative and clinical staff who have the power to enter into contracts on behalf of the organisation (or its subsidiaries)

In accordance with national guidance, these staff groups are considered to be employees who have significant influence and it is therefore important to ensure that transparency of any declarations made and action being taken to avoid situations of conflicts. 

‘Interests ’:

‘Interests’ fall into the following categories:

Financial interests: Where an individual may get direct financial benefit from the consequences of a decision they are involved in making.

Non-financial professional interests: Where an individual may obtain a non-financial professional benefit from the consequences of a decision they are involved in making, such as increasing their professional reputation or promoting their professional career.

Non-financial personal interests: Where an individual may benefit personally in ways which are not directly linked to their professional career and do not give rise to a direct financial benefit, because of decisions they are involved in making in their professional career.

Indirect interests: Where an individual has a close association with another individual who has a financial interest, a non-financial professional interest or a non-financial personal interest and could stand to benefit from a decision they are involved in making.

A ‘conflict of interest’ is:

A set of circumstances by which a reasonable person would consider that an individual’s ability to apply judgement or act, in the context of delivering, commissioning, or assuring taxpayer funded health and care services is, or could be, impaired or influenced by another interest they hold.

A conflict of interest may be:

•  Actual - there is a material conflict between one or more interests
• Potential – there is the possibility of a material conflict between one or more interests in the future

Staff may hold interests for which they cannot see potential conflict. However, caution is always advisable because others may see it differently and perceived conflicts of interest can be damaging. All interests should be declared where there is a risk of perceived improper conduct

Declaring Interests

All Staff (as defined in ‘key terms’ above) must declare any interest (including gifts and hospitality), or make a ‘nil declaration’, by completing a declaration form using the online register: https://lancsteaching.mydeclarations.co.uk.

Our online Register makes it easy for Staff to declare their interests and for greater transparency to the public, in line with NHS England guidance. This central register is a record of all interests, including offers or gifts, hospitality and sponsorship. Staff are responsible for making sure that their registered interests are kept up to date at all times.

The online register is accessible through the Intranet page on ‘Declare an Interest, Gift or Hospitality’: https://lancsteaching.mydeclarations.co.uk.

The online register includes a number of useful training materials, user guides and resources, including a video on how to use the online register: https://player.vimeo.com/video/259832236?autoplay=1

Declarations for all Staff must be made:

• on appointment;
• in addition, when new interests arise these must be formally declared as soon as possible but within 28 days of the interest arising.
• at the beginning of a new project/piece of work,
• whenever an individual’s role, responsibility or circumstances change in a way that affects the individual’s interest; and
• annually, which includes nil returns where there are no interests or changes to declare;
• during the recruitment process where it involves senior employees with new appointments

The requirement to complete a declaration form applies regardless of whether you consider there to be an actual, potential or perceived conflict – if in doubt, the Trust expects Staff to err on the side of caution and declare it, in order to protect the individual and organisation from accusations of wrongdoing.

The Trust will support Staff to understand that having interests is not in itself negative, but not declaring and/or managing them is. The Trust will prompt Staff annually to review declarations they have made and, as appropriate, update them or make a nil return. This prompt will be provided via an automated email to Staff via the online portal.

Any declarations made by Decision Making Staff will be made publicly available on the Trust website. If decision making staff have substantial grounds for believing that publication of their interests should not take place then they should contact the Company Secretary to explain why. In exceptional circumstances, for instance where publication of information might put a member of staff at risk of harm, information may be withheld or redacted on public registers. However, this would as an exception and information will not be withheld or redacted merely because of a personal preference.

After expiry, an interest will remain on the register for a minimum of 6 months and a private record of historic interests will be retained for a minimum of 6 years.

The Company Secretary is responsible for maintaining the register of interests (including gifts, hospitality and sponsorship) and for providing advice and support to Staff on how to declare interests. It is the responsibility of managers to ensure that all staff are aware of this guidance. Queries can be issued to the Company Secretary via the ‘Support’ tab on the online register or via email on Company.Secretary@lthtr.nhs.uk.

Members of the public may request to access the register in alternative formats, including on-site viewing at Trust HQ, through application to the Company Secretary.

In writing:

Company Secretary
Trust Executive
Royal Preston Hospital
Sharoe Green Lane
Preston
PR2 9HT ;

Telephone (switchboard): 01772 716565

Wider Transparancy Initiatives

The Trust fully supports wider transparency initiatives in healthcare, and staff are encouraged to engage actively with these.

Relevant staff are strongly encouraged to give their consent for payments they receive from the pharmaceutical industry to be disclosed as part of the Association of British Pharmaceutical Industry (ABPI) Disclosure UK initiative. 

 These “transfers of value” include payments relating to:

• Speaking at and chairing meetings
• Training services
• Advisory board meetings
• Fees and expenses paid to healthcare professionals
• Sponsorship of attendance at meetings, which includes registration fees and the costs of accommodation and travel, both inside and outside the UK
• Donations, grants and benefits in kind provided to healthcare organisations

Avoiding and Managing Conflicts of Interests

Although the interest may be declared, this does not remove the member of staff’s personal responsibilities for taking action to manage any actual or potential conflict that may rise, such as by removing themselves from a position or situation which may result in a potential breach of the Code of Business Conduct. Please note that declaring an interest is not in itself negative but failing to manage any potential or actual conflict of interest is.

Staff must avoid placing themselves in situations where they may be vulnerable to allegations of impropriety, and must remove themselves from situations where they risk breaching this Code of Business Conduct.

The important things to remember are that:

• A perception of wrong doing, impaired judgement or undue influence can be as detrimental as any of them actually occurring;
• If in doubt, it is better to assume a conflict of interest and manage it appropriately rather than ignore it;
• For a conflict to exist financial gain is not necessary.

It may not be possible to completely eliminate the risks of conflicts. Instead, it may be preferable to recognise the associated risks and put measures in place to manage the conflicts appropriately when they do arise. The range of management actions required to be taken varies from case to case: such as ranging from nothing, where no conflict of interest or impact is identified, through asking someone not to take part in a decision making process to removing them from part of their role, or, very rarely their whole role. Each case will be different and context-specific, and the Trust will always clarify the circumstances and issues with the individuals involved. Staff should maintain a written audit trail of information considered and actions taken.

Responsibilities of Staff and Managers and the Trust:

Staff responsibilities:

• Familiarise yourself with this Code of Business Conduct and follow it.
• Refer to the national guidance for the rationale behind this Code https://www.england.nhs.uk/wp- content/uploads/2017/02/guidance-managing-conflicts-of-interest-nhs.pdf
• Use your common sense and judgement to consider whether the interests you have could affect the way taxpayers’ money is spent
• Regularly consider what interests you have and declare these as they arise. If in doubt, declare.
• NOT misuse your position to further your own interests or those close to you 
• NOT be influenced, or give the impression that you have been influenced by outside interests
• NOT allow outside interests you have to inappropriately affect the decisions you make when using taxpayers’ money

Trust responsibilities:

• Ensure that this Code of Business Conduct and supporting processes are clear and help staff understand what they need to do.
• Identify a team or individual with responsibility for:
  • Keeping this Code under review to ensure they are in line with the guidance
  • Providing advice, training and support for staff on how interests should be managed.
  • Maintaining the register of interests.
• Auditing this Code and its associated processes and procedures at least once every three years.
• NOT avoid managing conflicts of interest.
• NOT interpret this Code in a way which stifles collaboration and innovation with our partners

Manager responsibilities:

Managers must:

• Ensure that all staff are aware of this guidance.
• Ensure that staffs involved in tendering or contracting do not give unfair advantage to one competitor over another or give the impression, by their action or inaction, that they are giving such an advantage.
• Ensure that staffs are aware that they should report offers of a gift, hospitality and sponsorship over £50 must be declared in the Register and notified to the Divisional Director or relevant Manager.
• Take care to ensure that the Trust does not appear to be compromised by acceptance of sponsorship by organisations which may at some time be competing to supply goods or services to the Trust.
• Ensure staff are aware that they are required to report any other employment and that they could breach their contract of employment by working for another employer without approval.
• Assess possible conflicts of interest when staff wish to carry out work outside the Trust.
• Take appropriate disciplinary action against employees who fail to declare an interest or are found to have abused their official position.

MANAGEMENT OF INTERESTS – COMMON SITUATIONS

Donations

The NHS has benefited substantially from donations and the Trust would not wish to discourage donations that improve the service that it provides to its patients. However, there are risks associated with the acceptance of donations from unsuitable sources or arising from donation of inappropriate items of equipment. The difficulties in accepting inappropriate donations can take a number of forms and these include:

• The creation of a sense of obligation on the part of either the giver or the recipient.
• The commitment to purchase, servicing, spare parts or consumables from a single source. This may also contravene European Union legislation.
• The appearance of partiality towards the giver, which the acceptance of a gift might imply to a firm’s competitors.
• The acceptance of equipment can carry with it revenue costs such as staffing, consumables and accommodation. Where an offer of equipment is received, this should be referred to the Chief Finance Officer.

Any donations offered to individuals (regardless of whether they have been accepted) should be declared using the appropriate declaration form on our online register: https://lancsteaching.mydeclarations.co.uk.

The relevant declaration form on the online register used to declare the donation will be subject to review and includes the following information:

• Staff name and their role with the organisation.
• A description of the nature and value of the donation, including name of donor.
• Date of receipt (or confirm it was declined).
• Confirmation as to whether employee was directly actively involved in fundraising and whether he/she has obtained permission from the organisation.
• Details as to whether the donation has been made to a specific charitable fund and, if so, the name of the charitable fund.
• Confirmation as to whether employee has received any donations personally.
• Any other relevant information (e.g. circumstances surrounding the donation, action taken to militate against a conflict, details of any approvals given to depart from the terms of this Code).

Management of Interests – Advice in Specific Contexts

Strategic decision making groups

In common with other NHS bodies, the Trust uses a variety of different groups to make key strategic decisions about things such as:

• Entering into (or renewing) large scale contracts.
• Selection of medicines, equipment, and devices.
• Making procurement decisions.
• Awarding grants.

The interests of those who are involved in these groups should be well known so that they can be managed effectively. For this organisation these groups include:

• Board of Directors
• Board Committees
• Executive Committee
• Divisional Boards

These groups should adopt the following principles:

• Members of such groups should consider conflicts of interest when appointing new members.
• Chairs should consider any known interests of members in advance, and begin each meeting by asking for declaration of interests with these recorded accordingly in the minutes.
• Members should take personal responsibility for declaring interests at the beginning of each meeting and as they arise.
• ‘Declaration of Interests’ should be a standing agenda item for every meeting.
• Any new interests identified should be added to the organisation’s register(s).

If a member has an actual or potential interest the chair, on the advice of the Company Secretary, should consider the following approaches and ensure that the reason for the chosen action is documented in minutes or records:

• Requiring the member to not attend the meeting.
• Excluding the member from receiving meeting papers relating to their interest.
• Excluding the member from all or part of the relevant discussion and decision.
• Noting the nature and extent of the interest, but judging it appropriate to allow the member to remain and participate.
• Removing the member from the group or process altogether.

Procurement

Procurement should be managed in an open and transparent manner, compliant with procurement and other relevant law, to ensure there is no discrimination against or in favour of any provider. Procurement processes should be conducted in a manner that does not constitute anti-competitive behaviour - which is against the interest of patients and the public.

Those involved in procurement exercises for and on behalf of the organisation should keep records that show a clear audit trail of how conflicts of interest have been identified and managed as part of procurement processes. At every stage of procurement steps should be taken to identify and manage conflicts of interest to ensure and to protect the integrity of the process.

The Lancashire Procurement Cluster (LPC) procures goods and services for and on behalf of the organisation and the LPC is hosted by East Lancashire Hospitals NHS Trust. As such, those involved in procurement exercises for and on behalf of the organisation should adhere to this Code of Business Conduct and the arrangements in the Standards of Conduct Policy (Procurement section) in place at East Lancashire Hospitals NHS Trust, as amended from time to time.

Concerns and Consequences for Breach

There will be situations when interests will not be identified, declared or managed appropriately and effectively. This may happen innocently, accidentally, or because of the deliberate actions of staff or other organisations. For the purposes of this Code of Business Conduct these situations are referred to as ‘breaches’.

Staff that have any concerns relating to a declaration of interest or a suspected breach should  report it to the Company Secretary’s office as soon as possible. If staff feel unable to do this they can contact the Freedom to Speak up (FTSU) team on freedomtospeakup@LTHTR.nhs.uk. Staff should report any suspected breaches or suspicions or allegations of fraud, bribery or corruption without fear of reprisals (see Raising Concerns at Work policy).

Any concerns of fraud, bribery or corruption should be reported to the Trust’s Chief Finance Officer or directly to the Trust’s Anti-Fraud Specialist on 0151 285 4500. Alternatively referrals can be reported through the confidential fraud hotline on 0800 028 4060 or online through the NHS Counter Fraud Authority at: www.cfa.nhs.uk/reportfraud. Further guidance on reporting concerns can be found under the Anti-Fraud, Bribery & Corruption policy or the Raising Concerns policy.

The organisation will investigate each reported breach according to its own specific facts and merits, and give relevant parties the opportunity to explain and clarify any relevant circumstances.

Following investigation the organisation will:

• Decide if there has been or is potential for a breach and if so the what severity of the breach is.
• Take appropriate action as required (as set out below).
• Consider who else inside and outside the organisation should be made aware
• Assess whether further action is required in response – this is likely to involve any staff member involved and their line manager, as a minimum.

Failure to comply with and meet the standards and requirements contained in this Code of Business Conduct may result in disciplinary action against the member of Staff, or action for breach of contract, or in the case of governors action for breach of the Governor Code of Conduct. Breaches of this Code of Business Conduct may also equate to criminal offences and the Trust’s Anti- Fraud Specialist or other relevant authorities may be notified. Where appropriate, the Trust will report any breaches by regulated healthcare professionals to the relevant regulator if it believes that the staff member has acted improperly, so that these concerns can be investigated.

Sanctions should not be considered until the circumstances surrounding breaches have been properly investigated. However, if such investigations establish wrong-doing or fault then the organisation can and will consider the range of possible sanctions that are available, in a manner which is proportionate to the breach. This includes:

• Employment law action against staff, which might include
  • Informal action (such as reprimand, or signposting to training and/or guidance).
  • Formal disciplinary action (such as formal warning, the requirement for additional training, re-arrangement of duties, re- deployment, demotion, or dismissal).
• Reporting incidents to the external parties described above for them to consider what further investigations or sanctions might be.
• Legal action, such as investigation and prosecution under fraud, bribery and corruption legislation.
• Contractual action, such as exercise of remedies or sanctions against the body or staff which caused the breach.
• Legal action, such as investigation and prosecution under fraud, bribery and corruption legislation.

An anonymised report on breaches, impact of these, and actions taken is prepared and presented to the Audit Committee as and when they occur, and made available on the Trust’s website for inspection by the public.

Audit and Monitoring

This Code of Business Conduct will be reviewed every three years unless an earlier review is required. This will be led by the Company Secretary. Compliance against this Code will be monitored through the online portal.  The Audit Committee shall receive an annual report on declarations of interest, gifts and hospitality, including  compliance with this code. 

Training

The online register also includes a number of useful training materials, user guides and resources, including a video on how to use the online register: https://player.vimeo.com/video/259832236?autoplay=1 The Trust also provides training on declaring interests via the Corporate Induction and the Staff Handbook.

The Company Secretary is responsible for providing advice and support to Staff on how to declare interests. Queries can be issued to the Company Secretary via the ‘Support’ tab on the online register or via email on Company.Secretary@lthtr.nhs.uk.

Document Information - Attachments

Appendix 1 - Equality, Diversity & Inclusion Impact Assessment Form

Other Relevant / Associated Documents

TP-148 Corporate Advertising and Sponsorship Policy

HRP-02 Raising concerns at work policy and procedure - Freedom to speak up (incorporating whistleblowing)

HRP-13 Disciplinary Policy & Procedure

TP-73 Anti-fraud, bribery & corruption policy

HRP-38 Code of conduct for employees

Standing Financial Instructions

Standing orders (board of directors)

Supporting References / Evidence Based Documents

References in full 

HM Government (2010) The Bribery Act 2010. https://www.legislation.gov.uk/ukpga/2010/23/contents

HM Government (1994) The Medicines (Advertising) Regulations 1994. https://www.legislation.gov.uk/uksi/1994/1932/contents/made

NHS England (2017) Managing Conflicts of Interest in the NHS Guidance for staff and organisations. https://www.england.nhs.uk/wp-
content/uploads/2017/02/guidance-managing-conflicts-of-interest-nhs.pdf

ABPI The Code of Practice for the Pharmaceutical Industry (2021)
https://www.abpi.org.uk/publications/code-of-practice-for-the-pharmaceutical-industry-2021/ 

Consultation with Staff and Patients

Senior Leadership Team  - Date Consulted - March 2023

Executive Team  - Date Consulted - March 2023

Board of Directors  - Date Consulted - April 2023

Distribution Plan

Dissemination lead: Jennifer Foote

Previous document already being used? Yes

If yes, in what format and where? Heritage

Proposed action to retrieve out-of-date copies of the document: Removal from Heritage

To be disseminated to: Trust wide

Document Library: Yes - Heritage

Proposed actions to communicate the document contents to staff

This document will be disseminated as follows:

• Include in the LTHTR weekly Procedural documents communication– New documents uploaded to the Document Library
• Include on ‘my declarations’ online portal
• All existing staff and all new starters going forward will receive log-in details to the ‘my declarations’ online portal
• Include on intranet ‘Declarations’ page
• Include on website ‘Declarations’ page
• Via Trust Global Email
• Via NewsBite
• Via Mandatory Training

Appendix 1

Equality, Diversity & Inclusion Impact Assessment Form

Department/Function: Corporate
Lead Assessor: Jennifer Foote
What is being assessed?: Code of Business Conduct
Date of assessment: March 2023

What groups have you consulted with? Include details of involvement in the Equality Impact Assessment process.

Equality of Access to Health Group 
Staff Side Colleagues
Service Users
Staff Inclusion Network/s
Personal Fair Diverse Champions
Other (Inc. external orgs)
Please give details: None – N/A

What is the impact on the following equality groups?

Positive:

Advance Equality of opportunity
Foster good relations between different groups
Address explicit needs of Equality target groups

Negative:

Unlawful discrimination, harassment and victimisation
Failure to address explicit needs of Equality target groups

Neutral:

It is quite acceptable for the assessment to come out as Neutral Impact.
Be sure you can justify this decision with clear reasons and evidence if you are challenged

Equality Groups

Race (All ethnic groups): Neutral 
Disability (Including physical and mentalimpairments): Neutral
Sex: Neutral
Gender reassignment: Neutral
Religion or Belief (includes non-belief): Neutral
Sexual orientation: Neutral
Age: Neutral
Marriage and Civil Partnership: Neutral
Pregnancy and maternity: Neutral
Other (e.g. caring, human rights, social): Neutral

In what ways does any impact identified contribute to or hinder promoting equality and diversity across the organisation?

N/A

If your assessment identifies a negative impact on Equality Groups you must develop an action plan to avoid discrimination and ensure opportunities for promoting equality diversity and inclusion are maximised. This should include where it has been identified that further work will be undertaken to further explore the impact on equality groups.  This should be reviewed annually.

How the NHS Constitution Applies to this Document

Which Principles of the NHS Constitution apply?

1. The NHS provides a comprehensive service, available to all.
2. Access to NHS services is based on clinical need, not an individual’s ability to pay.
3. The NHS aspires to the highest standards of excellence and professionalism.
4. The patient will be at the heart of everything the NHS does.
5. The NHS works across organisational boundaries.
6. The NHS is committed to providing best value for taxpayers’ money.
7. The NHS is accountable to the public, communities and patients that it serves.

Which staff pledges of the NHS Constitution apply?

1. Provide a positive working environment for staff and to promote supportive, open cultures that help staff do their job to the best of their ability.
2. Provide all staff with clear roles and responsibilities and rewarding jobs for teams and individuals that make a difference to patients, their families and carers and communities.
3. Provide all staff with personal development, access to appropriate education and training for their jobs, and line management support to enable them to fulfil their potential.
4. Provide support and opportunities for staff to maintain their health, wellbeing and safety.
5. Engage staff in decisions that affect them and the services they provide, individually, through representative organisations and through local partnership working arrangements. All staff will be empowered to put forward ways to deliver better and safer services for patients and their families.
6. To have a process for staff to raise an internal grievance.
7. Encourage and support all staff in raising concerns at the earliest reasonable opportunity about safety, malpractice or wrongdoing at work, responding to and, where necessary, investigating the concerns raised and acting consistently with the Employment Rights Act 1996.

Which aims of the Trust apply?

1. To offer excellent health care and treatment to our local communities.
2. To provide a range of the highest standard of specialised services to patients in Lancashire and South Cumbria.
3. To drive innovation through world-class education, teaching and research.

Which ambitions of the Trust apply?

1. Consistently deliver excellent care.
2. Great place to work.
3. Deliver value for money.
4. Fit for the future.