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Bribery and Fraud Prevention Policy

1. Introduction

Our Home Care business is committed to maintaining the highest standards of integrity and transparency in all of our dealings. We have a zero-tolerance approach to bribery, fraud and financial abuse. This policy is written with regard to the Regulation and Inspection of Social Care (Wales) Act 2016, the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 (as amended) and the Welsh Government statutory guidance for care home and domiciliary support service providers and responsible individuals (last updated 27 March 2024). It also supports compliance with the Bribery Act 2010, Fraud Act 2006, Proceeds of Crime Act 2002, Social Services and Well-being (Wales) Act 2014, and relevant safeguarding and whistleblowing duties. This policy outlines our approach to preventing and managing bribery and fraud, ensuring that we safeguard both our service users and our staff from unethical practices. Where this policy identifies a safeguarding risk (including financial abuse), we will follow our safeguarding policy, the Wales Safeguarding Procedures, and local safeguarding arrangements.

This policy applies to all employees, including Care Assistants, Senior Carers, Coordinators, Managers, and Directors, and provides clear guidance on how we manage bribery and fraud prevention efficiently. It also provides guidance for CIW inspectors to understand how we ensure compliance and operate ethically.

1.1 Definitions

• Bribery: offering, promising, giving, requesting or accepting an advantage to induce improper performance of a function or activity.
• Fraud: dishonestly making a false representation, failing to disclose information when under a duty to do so, or abusing a position for gain/cause loss.
• Financial abuse: including theft, fraud, scams, coercion in relation to money or property, misuse of benefits, or undue pressure to give gifts/loans.

2. Key Principles of Bribery and Fraud Prevention

• Zero-Tolerance Approach: We have a strict zero-tolerance policy towards bribery and fraud. Any instance of bribery, fraud, or related misconduct will result in disciplinary action.
• Prevention: We actively work to prevent bribery and fraud by ensuring that our policies, practices, and controls are effective and adhered to.
• Accountability and Transparency: We maintain transparency in all financial and operational activities, ensuring that all actions are well-documented and justifiable.
• Service User Protection: We protect the interests and well-being of service users by ensuring that no individual is taken advantage of through fraudulent practices or bribery.
• Staff Education and Awareness: We provide regular training and communication to ensure that staff understand the risks of bribery and fraud and the processes for reporting concerns.

3. How We Manage Bribery and Fraud Prevention Efficiently

A. Prevention Measures and Internal Controls

We have implemented rigorous internal controls to prevent the occurrence of bribery and fraud.

For Staff:

• Step 1: Implement a robust procurement process, ensuring that all suppliers and contractors are vetted and adhere to ethical business practices.
• Step 2: Conduct regular audits of financial transactions, including staff payroll, care expenses, and service user invoices to identify any discrepancies or fraudulent activities.
• Step 3: Ensure that any gifts or hospitality offered to staff are recorded and subject to approval, adhering to the Gifts and Hospitality Policy (GHP).
• Step 4: Maintain clear records of all financial transactions, care plans, and service user activities to ensure transparency and prevent fraudulent claims.
• Step 5: Provide staff with confidential reporting mechanisms for any concerns regarding potential bribery or fraudulent activities, including whistleblowing procedures.

For CIW Inspectors:

• Audit trails and financial documentation confirm that effective internal controls are in place to prevent bribery and fraud.
• Reports and records demonstrate that any suspicious activities are promptly investigated and acted upon.

B. Employee Conduct and Ethics

We ensure that all employees are held to the highest ethical standards and are made aware of the consequences of unethical conduct, including bribery and fraud.

For Staff:

• Step 1: All employees must sign and adhere to the Code of Conduct, which includes strict guidelines on accepting gifts or offering incentives to service users or external parties.
• Step 2: Training on anti-bribery and fraud prevention is mandatory for all employees, including annual refreshers and ongoing awareness.
• Step 3: Any employee found engaging in bribery, fraud, or unethical conduct will face immediate disciplinary action up to and including termination of employment.
• Step 4: Employees must report any conflicts of interest to management, including relationships with vendors, service providers, or service users that could lead to biased decision-making.

For CIW Inspectors:

• Employee training logs confirm that all staff receive mandatory training on preventing bribery and fraud.
• Code of Conduct records show that employees are aware of ethical expectations and the potential consequences of non-compliance.

C. Service User Safeguarding

We ensure that no service user is exploited or harmed by bribery or fraud, particularly in vulnerable situations.

For Staff:

• Step 1: Be vigilant to ensure that service users are not coerced into giving gifts, money, or personal favours in exchange for services.
• Step 2: Regularly review care plans and service user transactions to ensure there are no irregularities or suspicious activities, such as unauthorised payments.
• Step 3: Report any concerns regarding potential exploitation or fraudulent activities by service users or family members to the Registered Manager.
• Step 4: Ensure that staff do not accept monetary gifts or large personal favours from service users or their families.

For CIW Inspectors:

• Care records demonstrate that service users’ financial well-being is regularly monitored, with fraud prevention protocols in place.
• Incident logs confirm that any allegations of exploitation are promptly reported and investigated.

D. Supporting individuals to manage their money (Regulation 28)

Where staff support an individual with shopping, accessing cash, paying bills, or handling money in any way, this must be done only in line with the individual’s assessed needs and the agreed plan, and in accordance with our “Supporting Individuals to Manage Their Money” policy and procedures. These arrangements must:

• set out steps to enable and support people to manage their own money wherever possible; and
• include safeguards to protect individuals from financial abuse, including clear recording/receipts and management oversight.
  Staff who are not required to support a person with money must be precluded from involvement in that individual’s financial affairs. Staff must not, so far as practicable, act as an individual’s agent (for example, managing bank accounts, PINs, online banking or becoming an appointee) unless this is a formally authorised legal arrangement and approved by the Registered Manager/Responsible Individual.

E. Reporting, Investigating, and Addressing Concerns

We have clear processes in place for reporting, investigating, and addressing concerns about bribery and fraud.

For Staff:

• Step 1: Employees must report any suspicion or knowledge of bribery or fraud using the Whistleblowing Procedure (WP) or the Incident Reporting System (IRS).
• Step 2: Upon receiving a report, the Registered Manager will investigate the matter thoroughly, ensuring confidentiality and impartiality throughout the process.
• Step 3: If fraud or bribery is confirmed, appropriate action will be taken, including disciplinary measures, legal action, or reporting to relevant authorities.
• Step 4: Protect whistleblowers from retaliation by ensuring that they are protected under the Whistleblower Protection Policy (WPP).
• Step 5: Where bribery, theft, scams, misuse of finances, coercion, or suspected fraud involves (or may involve) an individual using the service, this must be treated as a safeguarding concern (financial abuse). The Registered Manager will ensure immediate protection actions are taken and that an appropriate referral is made to the local authority safeguarding team in line with our safeguarding policy and local safeguarding arrangements, and that a record is kept of actions and referrals.
• Step 6: Where an incident results in harm, distress, or a significant impact on an individual, we will act in an open and transparent way with the individual and/or their representative, provide information about what happened and the outcome of any investigation, and offer an apology where appropriate, in line with our duty of candour arrangements.
• Step 7: Where the matter meets CIW notification criteria (including where an incident is reported to the police, or where there is an abuse/allegation of abuse involving the provider and/or staff/volunteers, or an allegation of staff misconduct), the Responsible Individual/Registered Manager will notify CIW without delay and in writing, in the form CIW requires.

For CIW Inspectors:

• Incident reports confirm that any potential fraud or bribery is investigated in accordance with company policy.
• Action plans show that appropriate actions are taken to resolve issues and prevent recurrence.

We will ensure the whistleblowing arrangements are accessible, that staff know how to raise concerns, what safeguards are in place, and how concerns will be investigated, and we will operate these arrangements effectively so staff do not suffer victimisation or disadvantage for speaking up.

F. Financial Transparency and Audits

We ensure financial transparency and conduct regular audits to detect and prevent fraudulent activities.

For Staff:

• Step 1: Conduct quarterly financial audits to review all payments, invoices, and expenses to ensure compliance with budgetary controls and policies.
• Step 2: Maintain a secure system for tracking financial transactions that can be easily audited and reviewed.
• Step 3: All supplier relationships are reviewed to ensure there are no conflicts of interest or unethical dealings.

For CIW Inspectors:

• Audit logs and financial statements demonstrate that we maintain financial integrity and transparency.
• Audit results confirm that all financial transactions are accurately documented, with appropriate checks and balances in place to prevent fraud.

G. Ongoing Training and Awareness

We ensure that all staff are continuously educated on the risks of bribery and fraud and understand their roles in maintaining ethical standards.

For Staff:

• Step 1: Provide annual training on anti-bribery and fraud prevention, with a focus on identifying risks and reporting concerns.
• Step 2: Educate staff on how bribery and fraud can impact the business, service users, and the wider community.
• Step 3: Encourage staff to maintain a culture of openness, where ethical concerns are addressed promptly without fear of reprisal.

For CIW Inspectors:

• Training records confirm that all staff have received comprehensive training on bribery and fraud prevention.
• Feedback from staff shows a clear understanding of the company’s anti-bribery and fraud policies.

4. Governance and Continuous Improvement

We ensure that all aspects of bribery and fraud prevention are continuously monitored, reviewed, and improved through regular audits and staff feedback.

What We Do:

• Conduct quarterly audits to assess adherence to the Bribery and Fraud Prevention Policy.
• Hold annual compliance reviews to evaluate the effectiveness of the policy and make improvements as needed.
• Implement corrective actions based on audit findings and feedback from staff and service users.

For CIW Inspectors:

• Audit reports confirm that we are proactively monitoring and improving our practices in line with regulatory standards.
• Continuous improvement plans show adjustments based on feedback and identified risks.

The Responsible Individual will have oversight of bribery/fraud risks and events through governance arrangements, ensuring that learning from concerns, safeguarding, whistleblowing and complaints is analysed, shared with staff, and used to improve the service. Where relevant, this learning will inform the statement of compliance included in the provider’s annual return.

5. Compliance Monitoring and Audit Procedures

• Internal Audits: Conducted quarterly to assess compliance with anti-bribery and fraud prevention measures.
• Annual Reviews: Full compliance check against CIW regulations, the Bribery Act 2010, and Social Services and Well-being (Wales) Act 2014.
• Staff Supervisions & Appraisals: Conducted every six months to ensure understanding of ethical responsibilities and company policies.

6. Conclusion

We are committed to maintaining the highest ethical standards in our business operations. Our Bribery and Fraud Prevention Policy ensures that we safeguard both our service users and staff from unethical conduct, and that we comply fully with CIW regulations and legal standards. This policy promotes a transparent, accountable, and compliant environment where everyone involved can have confidence in the integrity of our services.

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