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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Bribery Prevention Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} upholds the highest standards of integrity, transparency, and accountability by preventing bribery and corruption within our organisation.

This policy supports compliance with the Bribery Act 2010, the Public Services Reform (Scotland) Act 2010, the Social Care and Social Work Improvement Scotland (Requirements for Care Services) Regulations 2011, the Health and Social Care Standards, the Care Inspectorate’s Quality Framework for Support Services (Care at Home, including supported living models of support), and the Scottish Social Services Council (SSSC) Codes of Practice for Social Service Workers and Employers 2024.

The policy also supports the protection of people using the service from financial abuse, exploitation, undue influence, conflicts of interest and improper handling of gifts, money, donations or benefits. All staff must act in a way that promotes dignity, respect, honesty, transparency, professional boundaries and public confidence in the care and support provided.

This policy aims to:

• Prevent bribery, corruption, and unethical behaviour within the organisation.
• Ensure all staff understand their legal and ethical responsibilities.

• Protect people who use the service from financial harm, coercion, exploitation, undue influence or abuse of trust.
• Ensure staff understand the professional boundaries that apply when people who use the service, carers, relatives, representatives, suppliers or external professionals offer gifts, money, hospitality, donations or personal favours.
• Ensure all concerns about bribery, financial abuse, fraud, conflicts of interest or improper financial conduct are recorded, reported, investigated and escalated appropriately.

• Protect {{org_field_name}} from reputational and legal risks associated with bribery.
• Encourage a culture of honesty and openness in financial and operational dealings.
• Outline clear reporting and investigation procedures for any suspected bribery cases.

2. Scope

This policy applies to:

• All employees, including care workers, supervisors, and management.
• Agency and temporary staff working with {{org_field_name}}.
• Board members, contractors, suppliers, and business partners.
• Any individuals acting on behalf of or representing {{org_field_name}}.

For the purposes of the Bribery Act 2010, this policy also applies to any “associated person” who performs services for or on behalf of {{org_field_name}}, including employees, workers, agency staff, contractors, consultants, suppliers, volunteers, intermediaries and any other person representing the organisation.

This policy covers all forms of bribery and corruption, including:

• Offering, promising, or giving a bribe.
• Requesting, agreeing to receive, or accepting a bribe.
• Bribery of foreign public officials.
• Corporate failure to prevent bribery.

In a care at home setting, this also includes any improper advantage connected to:

• care visits, visit times or rota allocation;
• assessment, review, care planning or allocation of support;
• purchasing, procurement or supplier selection;
• handling money, shopping, pensions, benefits, bank cards or property belonging to a person using the service;
• gifts, hospitality, donations, loans, tips or personal favours from people using the service, relatives, carers or representatives;
• preferential treatment, private work, introductions or recommendations;
• employment, recruitment, references, promotion or disciplinary decisions.

3. Legal and Regulatory Framework

This policy aligns with the following legislation, standards and guidance:

• Bribery Act 2010 – creates offences of offering, promising or giving a bribe; requesting, agreeing to receive or accepting a bribe; bribery of a foreign public official; and failure by a commercial organisation to prevent bribery by associated persons.
• Ministry of Justice Bribery Act 2010 Guidance – sets out the six principles for bribery prevention: proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.
• Public Services Reform (Scotland) Act 2010 – provides the statutory framework for the regulation, scrutiny and improvement of care services in Scotland.
• Social Care and Social Work Improvement Scotland (Requirements for Care Services) Regulations 2011 – requires providers to make proper provision for the health, welfare and safety of people using services and to prepare, review and revise personal plans where required.
• Health and Social Care Standards: My Support, My Life – sets out what people should experience when using health, social care or social work services, including dignity, respect, compassion, involvement, responsive care and wellbeing.
• Care Inspectorate Quality Framework for Support Services (Care at Home, including supported living models of support) – used for self-evaluation, scrutiny, inspection and improvement support.
• SSSC Codes of Practice for Social Service Workers and Employers 2024 – sets out the standards of conduct, practice and employer responsibilities for social service workers and employers in Scotland.
• Adult Support and Protection (Scotland) Act 2007 – relevant where bribery, financial exploitation, coercion or misuse of money may indicate harm to an adult at risk.
• Adults with Incapacity (Scotland) Act 2000 – relevant where a person may lack capacity to make or communicate decisions about money, gifts, property, financial arrangements or consent.
• Health and Care (Staffing) (Scotland) Act 2019 – supports safe and high-quality care through appropriate staffing and training arrangements.
• Public Interest Disclosure Act 1998 – provides protection for workers who make qualifying disclosures about wrongdoing.
• Data Protection Act 2018 and UK GDPR – apply to the handling, recording, sharing and retention of personal information during reporting, investigation and regulatory escalation.
• Equality Act 2010 – supports fair, non-discriminatory practice when applying this policy.

4. Definition of Bribery and Corruption

Bribery is defined as the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action that is illegal, unethical, or a breach of trust. This includes:

• Financial payments or gifts.
• Kickbacks or facilitation payments.
• Favouritism or preferential treatment.
• Unlawful donations or sponsorships.
• Hospitality, travel, or accommodation offered in return for favourable treatment.

• Accepting gifts, money, loans, tips or personal benefits from people using the service, carers, relatives or representatives where this could influence, or appear to influence, professional judgement.
• Seeking or accepting personal benefit in return for arranging care visits, changing visit times, influencing care arrangements, recommending services or giving preferential treatment.
• Misusing a person’s money, bank card, property, possessions, passwords, online accounts or financial information.
• Encouraging or accepting inclusion in a will, legacy, power of attorney arrangement or other financial arrangement connected to a person using the service.
• Accepting private work from a person using the service or their family without written authorisation from the Registered Manager and appropriate risk assessment.

Bribery does not need to involve cash. It may involve any financial or non-financial advantage, including gifts, hospitality, donations, loans, discounts, services, job opportunities, preferential treatment, promises, personal favours or benefits offered to a staff member, their family, friends or associates.

4.1 Financial Abuse, Exploitation and Adult Protection

{{org_field_name}} recognises that bribery, corruption, gifts, loans, misuse of money or pressure relating to financial matters may also indicate financial abuse or exploitation. Staff must remain alert to signs that a person may be at risk of financial harm, including:

• unexplained loss of money, bank cards, valuables or property;
• unusual gifts, loans, payments or transfers;
• pressure from any person to change financial arrangements, wills, benefits, powers of attorney or access to money;
• a person appearing anxious, confused or unable to explain financial transactions;
• staff, relatives, representatives or others seeking inappropriate financial advantage;
• concerns about coercion, undue influence or misuse of trust.

Where there is any concern that a person using the service may be experiencing financial harm, abuse, neglect or exploitation, staff must report this immediately in line with the Adult Support and Protection Policy, Safeguarding Policy, Whistleblowing Policy and this policy. The Registered Manager must consider whether referral to the relevant local authority adult protection team, Police Scotland, the Care Inspectorate, the Office of the Public Guardian, the SSSC or any other relevant body is required.

5. Responsibilities of Staff

All employees, agency workers, and business partners must:

• Act with integrity and uphold ethical standards at all times.
• Not offer, give, request, or accept bribes in any form.
• Report any suspected bribery through the established reporting channels.
• Adhere to financial and procurement policies to prevent bribery risks.
• Attend mandatory anti-bribery training to understand obligations and risks.

• Maintain professional boundaries at all times and never use their position to gain a personal, financial or other advantage.
• Declare any actual, potential or perceived conflict of interest immediately to their line manager.
• Refuse and report any offer of money, loans, personal favours, inappropriate gifts, hospitality or benefits that may compromise professional judgement or public confidence.
• Never borrow from, lend to, sell to, buy from, or enter into private financial arrangements with a person using the service, their carer, relative or representative.
• Never agree to be involved in a person’s will, legacy, power of attorney, appointeeship, guardianship or financial arrangement unless this has been formally authorised through the organisation and is legally appropriate.
• Record and report any concern that a person using the service may be subject to financial abuse, exploitation, coercion or undue influence.

Managers and senior staff must:

• Lead by example and promote a culture of transparency and integrity.
• Ensure compliance with anti-bribery laws and policies.
• Monitor financial transactions to detect any irregularities.
• Support staff in reporting concerns without fear of retaliation.

• Ensure staff understand the SSSC Codes of Practice requirements on honesty, conflicts of interest, professional boundaries, gifts and money.
• Maintain oversight of gifts, hospitality, conflicts of interest, financial transactions, concerns and investigations.
• Ensure concerns are escalated to the Care Inspectorate, Police Scotland, the local authority adult protection team, the SSSC, commissioners or other bodies where required.
• Ensure that learning from incidents, complaints, audits and investigations is used to improve practice.

6. Gifts, Hospitality, Donations and Benefits

Staff must not seek, request or encourage gifts, hospitality, tips, money, loans, donations, personal favours or any other benefit from people using the service, carers, relatives, representatives, suppliers or other professionals.

Staff may only accept a modest token gift where all of the following apply:

• it is unsolicited;
• it is of nominal value;
• it is not cash, a cash equivalent, voucher, loan, bank transfer or gift card;
• it is not offered in return for favourable treatment, additional support, changes to care arrangements or any other advantage;
• accepting it would not create an actual, potential or perceived conflict of interest;
• the person offering the gift has capacity to make that decision, or there is no reason to doubt their understanding;
• it is immediately reported to the line manager and recorded in the Gifts and Hospitality Register.

Staff must politely refuse and report:

• cash, vouchers, gift cards, bank transfers or loans;
• expensive, repeated or excessive gifts;
• gifts offered secretly or with conditions attached;
• gifts from a person where there are concerns about capacity, pressure, confusion or undue influence;
• offers of hospitality, holidays, travel, accommodation, meals or entertainment that could compromise professional judgement;
• offers connected to procurement, inspection, commissioning, assessment, care planning, recruitment or employment decisions;
• any offer from a supplier, contractor or business partner that could influence the organisation’s decisions.

Where refusal of a gift may cause distress to the person, staff must explain sensitively that professional rules prevent them from accepting it personally. The matter must be referred to a manager, who may decide whether the item should be returned, shared with the staff team, donated to charity, or otherwise managed transparently. The decision and rationale must be recorded.

Staff must never accept inclusion in a will, legacy, power of attorney arrangement, guardianship arrangement, appointeeship, property transaction or other financial arrangement connected to a person using the service, unless this relates to a pre-existing personal relationship fully declared to and risk assessed by the Registered Manager.

6.1 Money Handling and Financial Transactions

Staff must only support a person with money, shopping, payments or financial transactions where this is part of the agreed care and support arrangements and is recorded in the person’s personal plan, risk assessment or agreed support documentation.

Where staff are involved in any financial transaction, the following controls must be followed:

• the task must be authorised and within the worker’s role;
• receipts must be obtained and retained wherever possible;
• money received, spent and returned must be recorded accurately;
• records must be signed by the staff member and, where possible, the person using the service or their representative;
• any discrepancy, missing receipt, concern or allegation must be reported immediately;
• staff must not use their own loyalty cards, personal bank accounts, online shopping accounts or reward schemes for purchases made on behalf of a person using the service;
• staff must not keep personal financial information, PINs, passwords, bank cards or cash unless this has been formally risk assessed and authorised under the organisation’s procedures.

Any financial arrangement that falls outside the agreed support plan must be refused and reported to a manager.

7. Reporting and Investigation Procedures

Staff must report any suspected or actual bribery, corruption, financial abuse, conflict of interest, improper gift, money-handling concern or attempted undue influence to one or more of the following:

• their line manager;
• the Registered Manager;
• the Responsible Individual / provider representative;
• the designated safeguarding or adult protection lead;
• the organisation’s whistleblowing route, where the concern cannot be raised through normal line management;
• Police Scotland, where there is immediate risk, suspected crime or urgent protection concern.

Investigation Process:

1. Initial Assessment – The concern is reviewed to determine if further action is required.
2. Formal Investigation – If evidence is found, an internal investigation will be launched.
3. Legal and Regulatory Reporting – If necessary, reports will be made to external regulatory bodies such as the Care Inspectorate Scotland or law enforcement authorities.
4. Action and Resolution – If wrongdoing is confirmed, disciplinary action (including termination) or legal proceedings may be initiated.

Victimisation, retaliation, bullying, harassment or detrimental treatment of any person who raises a concern in good faith will not be tolerated. Staff who raise concerns will be supported in line with the Whistleblowing Policy, the Public Interest Disclosure Act 1998 where applicable, the SSSC Codes of Practice, and the organisation’s duty to promote an open and safe culture.

8. Preventative Measures

{{org_field_name}} follows the six principles in the Ministry of Justice Bribery Act guidance. Preventative measures will be proportionate to the size, nature and risk profile of the service and will include leadership commitment, risk assessment, due diligence, communication and training, monitoring and review.

To prevent bribery, corruption and financial exploitation, {{org_field_name}} will:

• maintain proportionate anti-bribery procedures approved by senior management;
• complete and review bribery and financial-abuse risk assessments for the service;
• apply due diligence to suppliers, contractors, agents, consultants and other associated persons;
• operate clear controls for gifts, hospitality, donations, conflicts of interest, procurement and money handling;
• maintain a Gifts and Hospitality Register and a Conflicts of Interest Register;
• audit financial transaction records, shopping records, receipts and any money-handling arrangements;
• ensure staff receive induction, refresher training and supervision on bribery prevention, financial safeguarding and professional boundaries;
• review incidents, complaints, whistleblowing concerns, safeguarding referrals and audit findings for learning and improvement;
• ensure staff are able to raise concerns without fear of retaliation;
• take prompt action where poor practice, misconduct or criminal behaviour is suspected.

8.1 Conflicts of Interest

Staff must declare any actual, potential or perceived conflict of interest as soon as it arises. This includes:

• personal, family, friendship, financial or business relationships with people using the service, relatives, representatives, suppliers or contractors;
• involvement in private care, cleaning, shopping, transport, property, financial or other paid arrangements outside the organisation;
• offers of employment, private work, gifts, hospitality, loans, donations or personal favours;
• any situation where personal interests could influence, or appear to influence, professional judgement.

Managers must record declared conflicts of interest, assess the risk, identify any control measures, and review the arrangement regularly. Staff must not continue with any arrangement that has not been authorised.

9. Staff Training and Awareness

All staff must complete training appropriate to their role, including:

• induction training on bribery prevention, professional boundaries, gifts and hospitality, conflicts of interest, whistleblowing and money handling;
• training on recognising and reporting financial abuse, exploitation, coercion and undue influence;
• training on the SSSC Codes of Practice, including honesty, trust, conflicts of interest, gifts, money and professional boundaries;
• refresher training at least annually, or sooner where there has been a relevant incident, complaint, audit finding, regulatory update or change in procedure;
• additional training for managers, finance staff, rota planners, procurement staff and any staff involved in handling money or financial records.

Training will ensure that employees:

• Recognise and prevent bribery risks.
• Understand reporting procedures.
• Promote a culture of ethical responsibility.

• understand how bribery and financial exploitation may present in a care at home service;
• understand the reporting routes for safeguarding, adult protection, whistleblowing, regulatory notification and criminal concerns;
• understand that failure to report concerns may place people at risk and may result in disciplinary action.

10. Consequences of Policy Breach

Failure to comply with this policy may result in:

• Disciplinary action, including dismissal.
• Legal consequences, including fines or imprisonment under the Bribery Act 2010.
• Reputational damage to both the individual and {{org_field_name}}.

• referral to the SSSC where a worker’s fitness to practise may be impaired;
• referral to Police Scotland where a criminal offence may have been committed;
• referral to the local authority adult protection team where a person may be at risk of harm;
• notification to the Care Inspectorate where the matter is notifiable or affects the safety, welfare or quality of care of people using the service;
• recovery of losses or civil action where appropriate;
• termination of contracts with suppliers, contractors or associated persons.

11. Related Policies

This policy should be read alongside:

• Whistleblowing Policy
• Financial Management and Procurement Policy
• Code of Conduct Policy
• Gifts and Hospitality Policy
• Fraud Prevention Policy

• Adult Support and Protection Policy
• Safeguarding Policy
• Service User Finance / Money Handling Policy
• Financial Transactions and Shopping Policy
• Conflict of Interest Policy
• Procurement and Supplier Due Diligence Policy
• Complaints Policy
• Duty of Candour Policy
• Data Protection and Confidentiality Policy
• Disciplinary Policy
• SSSC Registration and Fitness to Practise Policy
• Personal Planning Policy
• Medication Policy, where financial concerns relate to medicines, prescriptions or collection of medication

12. Policy Review

This policy will be reviewed at least annually, or sooner where there are changes in legislation, Care Inspectorate guidance, SSSC Codes of Practice, Health and Social Care Standards, commissioning requirements, organisational structure, risk assessment findings, complaints, incidents, safeguarding concerns, whistleblowing concerns or audit outcomes. Any changes will be communicated to staff and, where relevant, to people using the service, carers, representatives, contractors and suppliers.

The Registered Manager will ensure that the Gifts and Hospitality Register, Conflicts of Interest Register, money-handling records, audit findings, complaints and safeguarding concerns are reviewed as part of quality assurance and service improvement.

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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}}
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