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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Bribery and Fraud Prevention Policy

1. Purpose

The purpose of this policy is to set out {{org_field_name}}’s commitment to preventing, detecting, reporting and responding to bribery, fraud, corruption, financial abuse, conflicts of interest and dishonest misuse of organisational or service-user funds. This policy supports compliance with the Bribery Act 2010, the Fraud Act 2006, the Theft Act 1968 where relevant, the Proceeds of Crime Act 2002 where relevant, the Economic Crime and Corporate Transparency Act 2023 where applicable, the Health and Social Care Act 2008, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, the Care Quality Commission (Registration) Regulations 2009, CQC Fundamental Standards and the organisation’s safeguarding, governance and financial-control responsibilities within supported living services.

2. Scope

This policy applies to all employees, including permanent, temporary, agency staff, volunteers, contractors, and any individuals working on behalf of {{org_field_name}}. It covers all forms of bribery, fraud, and corruption that may arise within the organisation or in relation to third parties.

This policy also applies to directors, nominated individuals, senior managers, consultants, suppliers, contractors, agency providers, volunteers, agents, intermediaries and any other person or organisation acting for or on behalf of {{org_field_name}}. For the purposes of this policy, “associated persons” includes anyone who performs services for or on behalf of {{org_field_name}}, whether paid or unpaid. Where the concern relates to a person who uses the service, their money, property, benefits, tenancy, financial arrangements or risk of exploitation, this policy must be read alongside the Safeguarding Adults from Abuse and Improper Treatment Policy (SL13) and Managing Service User Finances Policy (SL41).

3. Related Policies

• Good Governance Policy (SL04)
• Safeguarding Adults from Abuse and Improper Treatment Policy (SL13)
• Staff Conduct and Code of Ethics Policy (SL28)
• Whistleblowing (Speaking Up) Policy (SL29)
• Managing Service User Finances Policy (SL41)
• Recruitment and Selection Policy
• Disciplinary Policy
• Complaints Policy
• Data Protection and Confidentiality Policy
• Mental Capacity Act and Best Interests Policy
• Duty of Candour Policy
• CQC Notifications Policy
• Risk Management Policy
• Financial Controls / Expenses / Purchasing Policy
• Gifts, Hospitality and Conflicts of Interest Register

4. Policy Statement

{{org_field_name}} is committed to a culture of honesty, integrity, transparency, accountability and openness. We have zero tolerance of bribery, fraud, corruption, financial abuse, theft, dishonesty, facilitation payments, improper inducements, undeclared conflicts of interest, falsification of records, misuse of service-user money, misuse of organisational funds or any attempt to gain an improper personal, professional or commercial advantage.

The Registered Manager, senior leadership team and, where applicable, the nominated individual and directors are responsible for ensuring that proportionate controls are in place to prevent, identify and respond to bribery and fraud risks. These controls include risk assessment, segregation of duties, authorisation limits, financial audits, staff training, safe recruitment, supplier due diligence, investigation procedures, whistleblowing arrangements and governance reporting.

Any suspected bribery, fraud, theft, financial abuse or exploitation involving a person who uses the service must be treated as a potential safeguarding concern and managed in line with the Safeguarding Adults from Abuse and Improper Treatment Policy (SL13), local safeguarding adults procedures, CQC notification requirements and police reporting requirements where applicable.

5. Definitions

5.1 Bribery

Bribery is offering, giving, receiving, or soliciting something of value to influence an action or decision. This includes:

• Offering cash, gifts, hospitality, or favours in exchange for preferential treatment.
• Accepting or requesting bribes in return for services or advantages.
• Facilitation payments (unofficial small payments to speed up processes).

5.2 Fraud

Fraud is wrongful or criminal deception intended to result in financial or personal gain. Examples include:

• False claims for services or expenses.
• Misuse of company funds or assets.
• Providing false information for financial gain.

5.3 Corruption

Corruption is the abuse of entrusted power or position for private, personal, organisational or commercial gain. This includes dishonest behaviour, improper influence, favouritism, concealment of conflicts of interest, manipulation of records, or misuse of authority.

5.4 Financial Abuse

Financial abuse includes theft, fraud, exploitation, coercion or misuse of a person’s money, benefits, bank cards, property, possessions, tenancy, appointeeship, Lasting Power of Attorney arrangements or financial decision-making. In supported living, financial abuse may include borrowing money from a person who uses the service, accepting personal gifts or loans, using a person’s bank card, pressuring a person to buy items, misusing appointeeship arrangements, withholding money, or failing to account for a person’s funds.

5.5 Facilitation Payments

Facilitation payments are unofficial payments or benefits made to speed up or secure a routine process or service. Facilitation payments are prohibited by {{org_field_name}}.

5.6 Conflict of Interest

A conflict of interest occurs where a person’s private, financial, family, professional or other interests could influence, or appear to influence, their decisions or actions on behalf of {{org_field_name}}. Conflicts must be declared immediately and recorded on the Conflicts of Interest Register.

5.7 Associated Person

An associated person is any individual or organisation that performs services for or on behalf of {{org_field_name}}, including staff, directors, managers, agency workers, volunteers, consultants, contractors, suppliers, agents and intermediaries.

5.8 Service-User Money, Property and Possessions

Service-user money, property and possessions include cash, bank cards, benefits, personal allowance, savings, online banking access, PIN numbers, valuables, belongings, shopping cards, vouchers, tenancy-related payments and any financial records belonging to a person who uses the service.

6. Preventative Measures

6.1 Staff Awareness and Training

• All staff must receive anti-bribery, fraud prevention, financial abuse awareness and whistleblowing information during induction and refresher training at least annually.
• Staff whose roles involve service-user money, appointeeship support, shopping, financial records, invoices, payroll, expenses, procurement or supplier management must receive additional role-specific training and competency checks.
• Training must include examples relevant to supported living, including misuse of service-user money, pressure from relatives or third parties, accepting gifts, falsifying mileage or timesheets, false expense claims, misuse of petty cash, supplier fraud, identity fraud, benefit-related concerns and conflicts of interest.
• Staff must be able to explain how to report concerns, how to preserve evidence, when to escalate to safeguarding, and when external reporting may be required.
• Training completion must be recorded and monitored through governance systems.

6.2 Internal Controls and Risk Management

{{org_field_name}} will maintain proportionate internal controls to reduce the risk of bribery, fraud, corruption and financial abuse. These controls will include:

• clear authorisation limits for expenditure, purchasing, petty cash, invoices, expenses, payroll amendments and service-user financial transactions;
• dual authorisation for higher-risk or higher-value transactions, including payments, refunds, cash withdrawals and changes to supplier or bank details;
• segregation of duties so that, wherever possible, the person requesting, approving, processing and reconciling a payment is not the same person;
• regular reconciliation of petty cash, service-user money records, receipts, invoices, payroll, mileage and expenses;
• spot checks and audits of financial records, including service-user finance records where {{org_field_name}} supports the person with money management;
• secure storage of cash, cards, cheque books, receipts, financial records, passwords and personal financial information;
• clear records of all financial transactions, decisions, authorisations, concerns and investigations;
• regular review of the bribery, fraud and financial abuse risk register;
• prompt action where audits identify unexplained discrepancies, missing receipts, unusual spending patterns, repeat errors, poor record keeping or concerns about staff conduct;
• governance reporting to the Registered Manager, provider, nominated individual or directors, as applicable.

6.3 Top-Level Commitment and Governance

The provider, Registered Manager, nominated individual and senior leaders will demonstrate clear commitment to preventing bribery, fraud, corruption and financial abuse. This will include ensuring that this policy is implemented, risks are reviewed, concerns are investigated, lessons are learned, and improvements are made.

Bribery and fraud prevention will be monitored through the organisation’s governance arrangements. Evidence may include audits, risk-register reviews, training records, supervision records, disciplinary outcomes, safeguarding referrals, CQC notifications, whistleblowing reports, complaints, financial discrepancy reports and action plans.

The Registered Manager will ensure that information about bribery, fraud and financial abuse risks is used to improve the safety and quality of the service.

6.4 Managing Gifts, Hospitality and Personal Benefits

• Staff must not ask for, encourage, pressure, accept or offer any gift, hospitality, loan, cash, voucher, personal favour, tip, reward, preferential treatment or personal benefit that could influence, or appear to influence, professional judgement.
• Staff must not borrow money from, lend money to, sell items to, buy personal items from, or enter into private financial arrangements with people who use the service, their relatives or representatives.
• Staff must not accept cash, bank transfers, gift cards, high-value gifts, personal loans, personal use of property, or inclusion in a will from a person who uses the service or their representative.
• Any gift or hospitality offered, accepted or declined must be recorded in the Gifts and Hospitality Register, regardless of value.
• Any gift or hospitality with an estimated value above £25, or any repeated gifts from the same person or organisation, must be reviewed and approved by {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} before acceptance.
• Where the gift or hospitality involves the Registered Manager, approval must be sought from the nominated individual, provider, director or another senior person who is independent of the matter.
• Gifts and hospitality must never influence care, support, procurement, recruitment, referrals, contracts, assessments, reviews, safeguarding decisions or professional judgement.

6.5 Supplier, Contractor and Third-Party Due Diligence

{{org_field_name}} will take a proportionate, risk-based approach to supplier, contractor and third-party due diligence. This may include checks on identity, ownership, references, insurance, financial standing, conflicts of interest, safeguarding suitability, relevant qualifications, previous concerns, sanctions exposure where relevant, and whether the supplier has appropriate anti-bribery and fraud controls.

Contracts and service agreements must include suitable anti-bribery, fraud prevention, confidentiality, safeguarding, data protection and termination clauses. {{org_field_name}} may terminate contracts where bribery, fraud, corruption, financial abuse, dishonesty or serious governance failure is identified.

Staff involved in purchasing, commissioning, invoice approval or supplier management must declare any personal, family, financial or other relationship with a supplier, contractor or prospective supplier before any decision is made.

6.6 Service-User Finances and Financial Abuse Controls

Where {{org_field_name}} supports a person with money, benefits, shopping, banking, appointeeship arrangements or financial records, staff must follow the Managing Service User Finances Policy (SL41), the person’s care and support plan, mental capacity requirements and any agreed best-interests arrangements.

Staff must not use a person’s money, bank card, PIN, online banking, benefits, property or possessions for any purpose other than the person’s own assessed and agreed needs. Receipts and records must be kept for all transactions. Any discrepancy, missing money, missing property, unexplained spending, concern about coercion, or allegation of misuse must be reported immediately to the Registered Manager and treated as a potential safeguarding concern.

Where financial abuse is suspected, {{org_field_name}} will consider immediate protective action, including securing records, protecting the person’s money and property, reviewing staff access, informing the local authority safeguarding team, notifying CQC where required, contacting the police where a crime may have been committed, and involving advocates, appointees, deputies or attorneys where appropriate and lawful.

6.7 Conflicts of Interest

Staff, managers, directors, volunteers, agency workers, contractors and others acting on behalf of {{org_field_name}} must declare any actual, potential or perceived conflict of interest as soon as they become aware of it. This includes personal, family, financial, business or other relationships with suppliers, contractors, people who use the service, relatives, advocates, commissioners or other professionals.

Declared conflicts must be recorded on the Conflicts of Interest Register and reviewed by a manager who is independent of the matter. The organisation will decide what controls are required, which may include removing the person from decision-making, changing duties, additional oversight, or refusing a transaction or relationship.

6.8 Failure to Prevent Fraud

{{org_field_name}} recognises that the Economic Crime and Corporate Transparency Act 2023 introduced a corporate offence of failure to prevent fraud for large organisations. Where this offence applies to {{org_field_name}}, the organisation will maintain reasonable fraud prevention procedures. Where the offence does not apply because {{org_field_name}} is not a large organisation, the organisation will still use the principles as good practice.

Reasonable fraud prevention procedures will be proportionate to the size, nature and risks of the service and may include top-level commitment, fraud risk assessment, proportionate controls, due diligence, communication, training, monitoring and review.

7. Reporting and Investigation

7.1 Reporting Bribery, Fraud, Corruption or Financial Abuse

Staff must immediately report any suspected, alleged or actual bribery, fraud, corruption, theft, financial abuse, financial exploitation, misuse of service-user money, falsification of records, conflict of interest or dishonest conduct. Reports should normally be made to {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} or through the Whistleblowing (Speaking Up) Policy (SL29).

If the concern involves the Registered Manager, a senior manager, director, nominated individual or anyone who may influence the investigation, the concern must be reported to an alternative senior person, the provider, the nominated individual, the local authority safeguarding team, CQC, the police, or through whistleblowing routes as appropriate.

Reports may be made anonymously where necessary and will be treated sensitively and confidentially, as far as this is possible. Staff who raise concerns in good faith must not be victimised, bullied, disciplined or treated unfairly for doing so.

Where the concern involves a person who uses the service, their money, property, possessions, tenancy or financial arrangements, the matter must be treated as a potential safeguarding concern and escalated in line with local safeguarding adults procedures.

7.2 Investigation Process

All allegations will be taken seriously and reviewed promptly. The Registered Manager or another suitably senior and independent person will decide the immediate actions required to protect people, preserve evidence and prevent further loss or harm.

The investigation process may include:

• making the person safe and protecting their money, property and records;
• recording the concern clearly, including dates, times, people involved, amounts, records affected and immediate action taken;
• preserving evidence, including receipts, financial records, rota records, timesheets, emails, messages, invoices, CCTV where lawful, audit trails, bank records and care records;
• considering whether staff suspension, change of duties, removal of financial access or increased supervision is required;
• referring to the local authority safeguarding adults team where a person who uses the service may have experienced or be at risk of financial abuse;
• notifying CQC where the incident meets statutory notification criteria;
• reporting to the police where a criminal offence may have been committed;
• informing commissioners, appointees, deputies, attorneys, insurers, auditors, banks, DWP, local authority finance teams or other relevant bodies where appropriate and lawful;
• completing a fair and confidential internal investigation in line with HR policies;
• taking disciplinary, contractual, safeguarding, regulatory or legal action where required;
• identifying lessons learned and updating controls, training, risk assessments and governance systems.

The Serious Fraud Office may be contacted where the concern involves serious or complex fraud, bribery or corruption. Routine criminal concerns will normally be referred to the police in the first instance.

7.3 CQC Notifications and Safeguarding Referrals

Where bribery, fraud, theft, financial abuse or exploitation affects, or may affect, a person who uses the service, the Registered Manager must consider whether a safeguarding referral is required under local safeguarding adults procedures.

The Registered Manager must also consider whether a statutory notification to CQC is required under the Care Quality Commission (Registration) Regulations 2009. This includes, where applicable, allegations of abuse, actual abuse, incidents reported to or investigated by the police, serious injury, or any event that affects the health, safety or welfare of a person who uses the service.

The decision to notify or not notify CQC must be recorded, including the reason for the decision, the date of any notification, the notification reference, and any follow-up action required.

7.4 Whistleblowing and Protection from Retaliation

Staff are encouraged to raise concerns at the earliest opportunity. {{org_field_name}} will not tolerate victimisation, bullying, harassment, dismissal, disciplinary action or any other disadvantage against a person who raises a concern in good faith.

Staff may use the Whistleblowing (Speaking Up) Policy (SL29) where they feel unable to raise the concern through normal management routes, where they believe the concern has not been properly addressed, or where they believe managers or senior leaders may be involved.

7.5 Records and Confidentiality

All bribery, fraud, corruption and financial abuse concerns must be recorded accurately, securely and confidentially. Records must include the concern raised, immediate action taken, safeguarding decisions, CQC notification decisions, external referrals, investigation findings, outcomes, lessons learned and any action plan.

Information must only be shared with people or organisations who need to know for safeguarding, regulatory, legal, contractual, employment, insurance, audit or law-enforcement purposes. Personal data must be handled in line with data protection and confidentiality requirements.

8. Consequences of Non-Compliance

Failure to comply with this policy may result in one or more of the following:

• management action, supervision, retraining or competency review;
• disciplinary action, up to and including dismissal;
• referral to the Disclosure and Barring Service where harm or risk of harm is identified;
• referral to a professional body, where applicable;
• safeguarding referral to the local authority;
• statutory notification to CQC, where required;
• report to the police, DWP, local authority finance team, bank, insurer, auditor, commissioner, Companies House, Charity Commission or other relevant body, depending on the concern;
• recovery of losses where lawful and appropriate;
• termination of contracts with suppliers, contractors, agency providers or other third parties;
• civil or criminal proceedings where appropriate;
• review of systems, controls, training, governance and risk management arrangements.

{{org_field_name}} recognises that failure to prevent, identify, report or respond properly to bribery, fraud, corruption or financial abuse may create safeguarding risks, regulatory risk, contractual risk, financial loss, reputational damage and potential enforcement action.

9. CQC Compliance

This policy supports compliance with the Health and Social Care Act 2008, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, the Care Quality Commission (Registration) Regulations 2009 and CQC Fundamental Standards.

In particular, this policy supports:

• Regulation 13: Safeguarding service users from abuse and improper treatment – by helping to prevent, identify, report and respond to financial abuse, exploitation, theft, coercion, improper treatment and misuse of service-user money or property.
• Regulation 17: Good governance – by requiring effective systems and processes to assess, monitor and mitigate bribery, fraud, corruption, financial abuse and financial-management risks, and by requiring accurate records, audits, risk review and governance oversight.
• Regulation 19: Fit and proper persons employed – by supporting safe recruitment, staff conduct expectations, checks on suitability, investigation of dishonesty concerns and action where staff are not suitable to work in the service.
• Care Quality Commission (Registration) Regulations 2009, Regulation 18: Notification of other incidents – by requiring the Registered Manager to consider and submit statutory notifications to CQC where incidents involve abuse, allegations of abuse, police involvement, serious injury or other incidents affecting the health, safety or welfare of people using the service.

This policy also supports CQC’s assessment expectations under the Safe and Well-led key questions, including safeguarding, learning culture, governance, management, accountability, risk management and use of information to improve care.

10. Policy Review

This policy will be reviewed at least annually, or sooner where there are changes in legislation, CQC requirements, statutory guidance, local safeguarding procedures, organisational structure, financial controls, commissioning requirements, or following a bribery, fraud, corruption, financial abuse, safeguarding or whistleblowing incident.

The review will consider whether this policy remains effective, whether controls are proportionate to current risks, whether staff understand their responsibilities, and whether learning from audits, complaints, safeguarding concerns, CQC notifications, investigations and whistleblowing reports has been implemented.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.