Fraud Prevention Statement
Managing Director’s statement
Economic Crime and Corporate Transparency Act 2023 - corporate 'failure to prevent fraud'
On Monday 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 offence has significant implications for organisations operating in the UK, including companies and NHS organisations and health bodies.
The new offence states that a company or organisation can be held criminally liable if a connected or associated person (such as an employee, volunteer, associate, contractor, agent, supplier, employees of subsidiary companies, related charities or partner organisations) commits fraud with the intention of benefiting the organisation, or a related body, and the organisation cannot demonstrate it had reasonable fraud prevention procedures in place to prevent fraud from occurring.
This approach aims to promote a strong anti-fraud culture within businesses and organisations, including this company and the NHS.
Suppliers, contractors, third-party associates, and external joint venture partners are deemed to be an “associated person” with Atlas; therefore, your commitment to robust fraud prevention measures is essential in ensuring we do not breach the legislation.
Therefore, the following is requested from all associated persons and partners:
Compliance with the 'failure to prevent fraud' legislation
- If your organisation meets the legal definition of a “large organisation”, as set out in the ECCTA (i.e. meeting two or three out of the following criteria: more than 250 employees, more than £36 million turnover, more than £18 million in total assets), it is imperative that you comply with the legislative requirements, just as we are doing, and that you take immediate to ensure reasonable fraud prevention procedures are in place
- The official government guidance on the failure to prevent fraud offence should be reviewed to understand the scope and requirements of the legislation and to assess current procedures against the outlined principles of fraud prevention
- Independent legal advice is recommended to ensure your organisation is fully prepared and compliant with the new requirements
As an essential partner/supplier to Atlas, we may ask you to confirm what measures you have put in place.
Best practice for all organisations
Even if your organisation does not meet the legal criteria for direct application of the reasonable anti-fraud compliance measures, as set out in the ECCTA, all partners are expected to demonstrate best practice in preventing fraud. This includes:
- Conducting a thorough fraud risk assessment to identify potential vulnerabilities within your operations, supply chains, and partnerships
- Implementing robust internal controls and reporting mechanisms to mitigate fraud risks and detect suspicious activity early
- Providing robust anti-fraud awareness training for employees to ensure they can identify and report suspicious activities. Knowing who to report concerns to
- Establishing accessible whistleblowing mechanisms that encourage employees to report concerns in a safe and confidential manner
- Adhering to the NHS Suppliers’ Code of Practice to ensure actions align with the NHS's values and principles in preventing fraud, bribery, and corruption
Again, we may ask you to confirm what measures you have put in place.
Atlas is committed to maintaining a strong and ethical environment for delivering healthcare and other services to the NHS. By working together and upholding the highest standards of integrity, valuable company and NHS resources can be protected and used for their intended purpose – patient care.
Thank you for your cooperation in this important matter. Continued partnership in preventing fraud is appreciated.
Sarah Senior Managing Director
