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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 ensure that {{org_field_name}} maintains the highest standards of integrity, transparency, and accountability in all aspects of its operations. This policy sets out the organisation’s zero-tolerance stance on bribery and fraud, outlining preventative measures, reporting procedures, and the consequences of fraudulent or corrupt activities.

This policy aligns with:

• The Bribery Act 2010 and Ministry of Justice guidance on adequate procedures, including proportionality, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.
• The Fraud Act 2006, including fraud by false representation, fraud by failing to disclose information, and fraud by abuse of position.
• The Regulation and Inspection of Social Care (Wales) Act 2016.
• The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended.
• Welsh Government statutory guidance for service providers and responsible individuals, including the 2024 guidance for care home and domiciliary support services.
• Regulation 11, which requires the service provider to take reasonable steps to ensure the service is financially sustainable and to maintain appropriate and up-to-date accounts.
• Regulation 12, which requires policies and procedures to be kept up to date and operated effectively.
• Regulation 13, which requires the provider to act in an open and transparent way with individuals and their representatives.
• Regulation 27 and Regulation 28, which require effective safeguarding arrangements and procedures to protect individuals from abuse, neglect, improper treatment and financial abuse.
• Regulation 35, which requires the provider to ensure staff are fit to work at the service and to make referrals to the relevant regulatory or professional body, DBS or other authority where appropriate.
• Regulation 63, which requires effective arrangements to identify, record and manage actual or potential conflicts of interest.
• Regulations 73, 79 and 80, which require the Responsible Individual to visit the service, ensure policies and procedures are kept up to date, and monitor, review and improve the quality of care and support.
• The Public Interest Disclosure Act 1998, which protects workers who raise qualifying protected disclosures.
• The Social Care Wales Codes of Professional Practice and any updated Social Care Wales Code requirements in force at the time of review.

 

2. Scope

This policy applies to:

• All employees, including full-time, part-time, agency, and volunteer staff.
• Service users and their representatives, ensuring their financial interests are protected.
• Suppliers, contractors, and external partners, ensuring ethical business practices.
• Senior management and board members, ensuring compliance with governance regulations.

This policy also applies to all financial, operational and care-related activities carried out by or on behalf of {{org_field_name}}, including procurement, petty cash, payroll, expenses, resident monies, gifts and hospitality, donations, fundraising, service contracts, supplier relationships, agency staff arrangements, commissioned services, records, invoices, care fees, service user funds, and any transaction or decision that could create a financial or personal advantage for an individual or organisation.

The policy covers:

• Definitions and examples of bribery and fraud.
• Preventative measures and internal controls.
• Reporting procedures and investigation processes.
• Staff responsibilities and consequences of misconduct.

3. Definitions and Examples

3.1. What is Bribery?

Bribery is offering, promising, giving, requesting, or accepting something of value to gain an unfair advantage. Examples include:

• Staff accepting gifts or cash in exchange for preferential treatment of a service user.
• Offering financial incentives to regulators or inspectors for a favourable outcome.
• Improperly influencing procurement decisions, such as favouring suppliers based on personal benefits.

3.2. What is Fraud?

Fraud is dishonest conduct intended to make a gain, cause a loss, expose another person to a risk of loss, or obtain an advantage. Under the Fraud Act 2006, fraud may include:

• fraud by false representation, such as submitting false invoices, false timesheets, false mileage claims, false qualifications, false care records or false financial information;
• fraud by failing to disclose information where there is a legal duty to disclose it, such as failing to disclose a conflict of interest, overpayment, financial irregularity, safeguarding concern or misuse of funds;
• fraud by abuse of position, such as a staff member, manager, director, volunteer or contractor using their role to misuse resident money, influence procurement, obtain gifts, conceal errors, or gain an improper personal or organisational benefit.

In a care home setting, fraud may include but is not limited to:

• misusing, stealing or borrowing money or property belonging to an individual;
• using an individual’s bank card, PIN, online banking, benefits, pension, savings or possessions without proper authority;
• falsifying care records, medication records, training records, supervision records, recruitment records, accident records, invoices, payroll records or audit records;
• creating or approving false supplier invoices;
• claiming for hours not worked or services not delivered;
• manipulating rotas, dependency records or staffing information;
• accepting or offering inducements to influence admission, care planning, procurement, employment, inspection or contractual decisions;
• concealing financial errors, losses, debts, insolvency risks or other information that may affect the safe and sustainable operation of the service.

3.3. Financial Abuse

Financial abuse is a safeguarding matter and may also amount to fraud, theft, coercion or exploitation. Financial abuse includes:

• having money or property stolen;
• being defrauded;
• being put under pressure in relation to money or property;
• having money or property misused;
• being asked for loans, gifts or money by staff, volunteers, contractors or visitors;
• being pressured to change a will, make a gift, transfer property, sign a financial document, or make purchases for another person;
• being denied access to personal money or information about personal finances.

Any concern that an individual may have experienced financial abuse must be treated as a safeguarding concern and reported in line with the Safeguarding Adults from Abuse and Improper Treatment Policy, the Wales Safeguarding Procedures, local safeguarding arrangements and this policy.

4. Preventative Measures and Internal Controls

4.1. Ethical Culture and Zero-Tolerance Approach

At {{org_field_name}}, we operate a zero-tolerance policy towards bribery and fraud. This means:

• All employees are expected to act with integrity and honesty in all dealings.
• Gifts, hospitality, and financial transactions are strictly monitored.
• Any suspicion of bribery or fraud is investigated immediately.
• Service users, families, and external stakeholders are encouraged to report concerns without fear of retaliation.

4.2. Financial Controls, Sustainability and Transparency

To minimise the risk of bribery, fraud, financial abuse and financial mismanagement, {{org_field_name}} will maintain effective financial governance arrangements. These include:

• maintaining appropriate and up-to-date accounts for the service;
• ensuring the service is financially sustainable for the purpose of achieving the aims and objectives set out in the Statement of Purpose;
• ensuring financial planning, budget monitoring and financial controls are carried out effectively;
• ensuring that financial risks that may affect the safe operation of the service are escalated to the Registered Manager, Responsible Individual and provider without delay;
• ensuring no single individual has sole control over ordering, approval, payment, reconciliation and audit of financial transactions;
• using authorisation limits for expenditure, invoices, petty cash, resident monies and procurement;
• requiring dual authorisation for high-risk transactions, resident monies, refunds, cash handling and unusual payments;
• keeping accurate electronic and/or paper records of financial transactions, approvals, receipts, invoices, audits, reconciliations and investigations;
• undertaking regular internal checks, audits and management reviews;
• ensuring any concerns about solvency, unpaid liabilities, irregular expenditure or financial instability are escalated and acted upon promptly;
• providing accounts or financial information to Welsh Ministers, CIW or other lawful authorities when required.

Financial controls must be proportionate to the size, structure and risks of the service. Any failure to follow financial controls may be treated as a disciplinary matter and, where appropriate, a safeguarding, regulatory or criminal matter.

4.3. Managing Gifts, Hospitality, Donations and Bequests

Staff, managers, volunteers, directors, contractors and anyone working on behalf of {{org_field_name}} must not request, pressure, encourage or accept gifts, loans, cash, vouchers, personal benefits, hospitality or favours from individuals, relatives, representatives, suppliers, contractors or other stakeholders where this could create, or appear to create, a conflict of interest, influence care, influence procurement, influence employment decisions, or place an individual at risk of financial abuse.

The following are prohibited:

• accepting cash, loans, vouchers or personal payments from individuals or their representatives;
• borrowing money or property from individuals or their representatives;
• lending money to individuals;
• asking individuals or families to buy items for staff;
• accepting gifts in return for preferential treatment;
• accepting gifts from suppliers or contractors during tendering, contract review or dispute processes;
• being involved in an individual’s will, bequest, financial document, bank account, benefits, pension, property transfer or legal arrangement unless this forms part of an authorised role and has been formally approved.

Low-value token gifts, such as chocolates, biscuits or flowers, may only be accepted where refusal would cause unnecessary distress or offence, where the value is modest, and where acceptance does not create a conflict of interest. All gifts, hospitality, donations or offers with an estimated value of £20 or more, and any repeated gifts from the same person regardless of value, must be declared to the Registered Manager and recorded in the Gifts and Hospitality Register.

Any offer of cash, loan, valuable item, significant gift, inheritance, bequest, property, hospitality or personal benefit must be refused and reported immediately to the Registered Manager. Where there is any concern that the offer may involve pressure, coercion, exploitation, impaired capacity, financial abuse, bribery or fraud, the matter must also be reported as a safeguarding concern.

4.4. Procurement and Supplier Integrity

• All contracts and purchases must follow transparent procurement procedures.
• Suppliers are selected based on quality, value, and ethical standards, not personal relationships.
• Due diligence checks are conducted on new suppliers to identify potential risks of corruption or unethical business practices.

4.5. Conflicts of Interest

{{org_field_name}} will identify, record, review and manage actual, potential and perceived conflicts of interest. A conflict of interest may arise where a staff member, manager, Responsible Individual, director, volunteer, contractor, supplier, professional, relative or connected person has a personal, financial, family, business or other interest that could improperly influence, or appear to influence, decisions made on behalf of the service.

Conflicts of interest may include:

• involvement in procurement decisions where there is a personal, family or business relationship with a supplier;
• employment, promotion, supervision or disciplinary decisions involving relatives or close personal relationships;
• accepting gifts, hospitality or benefits from suppliers, contractors, individuals or representatives;
• staff or managers providing private services to individuals outside their role;
• staff, managers or directors having a financial interest in a supplier used by the service;
• a medical practitioner with a financial interest in the ownership of the care home acting as medical practitioner for an individual receiving care from the service.

All conflicts of interest must be declared immediately to the Registered Manager or Responsible Individual and recorded in the Conflict of Interest Register. The Registered Manager and Responsible Individual will decide how the conflict will be managed, which may include removing the person from the decision-making process, seeking independent advice, using alternative suppliers, increasing oversight, or reporting the matter to the provider, CIW or another authority where required.

4.6. Resident Money, Property and Financial Transactions

Any support provided to an individual with money, property, valuables, purchases, benefits, pensions, bank cards, cash, online banking, savings or personal financial decisions must be carried out in line with the Managing Service User Finances Policy and the individual’s personal plan.

Staff must:

• encourage and support individuals to manage their own money as far as possible;
• protect individuals from financial abuse, coercion, exploitation and undue influence;
• ensure any support with money is properly authorised, recorded and auditable;
• keep receipts and records for any transaction undertaken on behalf of an individual;
• ensure individual money is not mixed with the service’s money or another person’s money;
• ensure money held by the service is held in the individual’s name or clearly demarcated for that individual;
• store money and valuables securely where the service has agreed to hold them;
• ensure staff who are not authorised to support an individual with money are not involved in that individual’s financial affairs.

Staff must not:

• use an individual’s bank card, PIN, online banking or cash without clear authorisation and recording;
• borrow from or lend money to an individual;
• make personal purchases using an individual’s money;
• act as an individual’s agent unless there is lawful authority and formal approval;
• influence an individual’s spending, gifts, will, benefits, property or financial decisions for personal or organisational gain.

Any discrepancy, missing money, unexplained transaction, missing valuable, suspected coercion or concern about financial abuse must be reported immediately to the Registered Manager and managed as a safeguarding concern where appropriate.

4.7. Procurement, Suppliers and Contracts

Procurement decisions must be transparent, fair, proportionate and based on quality, safety, value, reliability and suitability for the service. Staff, managers and directors involved in procurement must declare any personal, family, financial or business connection with a supplier or contractor before quotations, tenders, purchases or contract renewals are considered.

The service will:

• obtain quotations or evidence of value for money where appropriate;
• use approved suppliers where required;
• record procurement decisions and reasons for selecting suppliers;
• carry out proportionate due diligence on new suppliers;
• include anti-bribery, fraud prevention, safeguarding, confidentiality and data protection expectations in supplier arrangements where appropriate;
• review supplier performance where poor quality, overcharging, duplicate invoicing, unexplained price increases or safety concerns are identified;
• ensure no supplier is selected because of personal benefit, inducement, pressure or favouritism.

Any suspected false invoice, duplicate invoice, inflated charge, kickback, inducement, collusion or supplier-related fraud must be reported immediately.

5. Reporting Procedures and Investigation Process

5.1. Reporting Concerns of Bribery, Fraud, Financial Abuse or Conflicts of Interest

Any staff member, volunteer, manager, director, individual, representative, relative, visitor, supplier, contractor or external stakeholder who suspects bribery, fraud, financial abuse, theft, coercion, exploitation, improper gifts, misuse of funds, false records, conflicts of interest or financial irregularity must report the concern immediately.

Concerns should be reported to:

1. the Line Manager;
2. the Registered Manager;
3. the Responsible Individual; or
4. the Designated Whistleblowing Officer at {{org_field_registered_manager_email}}.

Where internal reporting is not appropriate, or where the person raising the concern believes the matter has not been addressed properly, concerns may be raised with:

• Care Inspectorate Wales, where the concern relates to the safety, quality, governance or regulatory compliance of the service;
• the Local Authority Safeguarding Team, where an individual may have experienced abuse, neglect, improper treatment or financial abuse;
• the police, where theft, fraud, bribery, coercion, assault or another criminal offence may have occurred;
• Action Fraud, where fraud or cybercrime is suspected;
• the Serious Fraud Office, where the matter involves serious or complex fraud, bribery or corruption;
• Social Care Wales or another professional regulator, where the conduct of a registered worker or professional may call their fitness to practise into question;
• the Disclosure and Barring Service, where the legal criteria for a barring referral may be met.

Where the matter is notifiable to CIW, the notification must be submitted through CIW Online by the Responsible Individual, Registered Manager or authorised designated online assistant, in line with CIW requirements.

Reports will be treated sensitively and confidentially as far as possible. Staff who raise concerns in good faith will be protected from victimisation, bullying, harassment or retaliation.

5.2. Investigation and Immediate Protective Action

When a concern is reported, {{org_field_name}} will take prompt and proportionate action to protect individuals, preserve evidence and ensure regulatory, safeguarding, employment and criminal reporting duties are met.

The process will include:

1. Immediate risk assessment – The Registered Manager or Responsible Individual will consider whether any individual, staff member, record, money, property, evidence or service operation is at immediate risk.
2. Protective action – Where required, action may include safeguarding measures, removing access to money or records, suspending financial authority, changing duties, increasing supervision, securing documents, preserving CCTV or electronic records, or suspending a staff member in line with the Disciplinary Policy.
3. Safeguarding referral – Where the concern may involve financial abuse, abuse, neglect or improper treatment, a safeguarding referral will be made in line with the Wales Safeguarding Procedures and local safeguarding arrangements.
4. Regulatory notification – Where required, CIW will be notified through CIW Online.
5. Initial review – The Registered Manager, Responsible Individual or appointed investigator will establish the nature of the concern, people involved, records affected, immediate risks, and whether external agencies must be informed.
6. Formal investigation – Where there is credible evidence or significant risk, an internal or external investigation will be undertaken. This may include interviews, review of financial records, care records, rotas, invoices, receipts, bank records, supplier records, emails, CCTV, audit trails and witness statements.
7. Referral to external bodies – The police, Action Fraud, Serious Fraud Office, DBS, Social Care Wales, professional regulators, commissioners, insurers or auditors may be informed where appropriate.
8. Outcome and action plan – Findings will be recorded and may result in disciplinary action, contract termination, safeguarding action, recovery of funds, changes to systems, staff retraining, referral to authorities or legal action.
9. Learning and improvement – Lessons learned will be shared appropriately and included in governance, audit, risk management and quality-of-care review processes.

The person raising the concern will be informed of the outcome as far as possible, subject to confidentiality, safeguarding, employment law and data protection requirements.

5.3. Consequences of Bribery, Fraud, Financial Abuse or Failure to Report

Any staff member, manager, volunteer, contractor or other person working for or on behalf of {{org_field_name}} who is found to have engaged in bribery, fraud, theft, financial abuse, deliberate falsification of records, concealment of financial irregularities, improper gifts, conflicts of interest, coercion or failure to report concerns may be subject to:

• disciplinary action, up to and including dismissal for gross misconduct;
• removal from duties or termination of volunteer or contractor arrangements;
• referral to the police, Action Fraud or Serious Fraud Office;
• referral to CIW;
• referral to the Local Authority Safeguarding Team;
• referral to Social Care Wales, NMC or another professional regulator;
• referral to the Disclosure and Barring Service where the criteria are met;
• civil recovery action or insurance notification;
• review of fitness to work in the service.

Failure to report suspected abuse, financial abuse, bribery or fraud may itself be treated as a disciplinary matter.

6. Managing Bribery and Fraud Prevention Efficiently

6.1. Leadership, Governance and Accountability

The provider, Responsible Individual and Registered Manager are responsible for ensuring this policy is implemented effectively.

The provider is responsible for ensuring that effective financial governance, anti-bribery, fraud prevention, safeguarding and conflict of interest arrangements are in place.

The Responsible Individual is responsible for maintaining oversight of the service, ensuring suitable arrangements are in place to monitor quality and compliance, ensuring policies and procedures are kept up to date, and ensuring concerns relating to bribery, fraud, financial abuse or governance failure are considered within service monitoring and improvement arrangements.

The Registered Manager is responsible for day-to-day implementation of this policy, including staff awareness, reporting arrangements, investigations, records, safeguarding referrals, CIW notifications, audits and corrective actions.

All staff, volunteers, agency workers, contractors and suppliers must act honestly, declare conflicts of interest, refuse improper gifts or inducements, follow financial controls, report concerns immediately, cooperate with investigations, and protect individuals from financial abuse.

The Responsible Individual will ensure bribery, fraud, financial abuse, whistleblowing, safeguarding concerns, complaints, incidents, audit findings and related learning are considered within governance meetings and the quality-of-care review process.

6.2. Staff Training and Awareness

All staff will receive information and training appropriate to their role during induction and through refresher training. Training will cover:

• the zero-tolerance approach to bribery, fraud and financial abuse;
• examples of fraud and bribery in care home settings;
• financial abuse and safeguarding responsibilities;
• gifts, hospitality, donations and bequests;
• conflicts of interest;
• resident money and property procedures;
• procurement and invoice controls;
• accurate record keeping;
• whistleblowing and speaking up;
• how to report concerns internally and externally;
• duty of candour and openness when things go wrong;
• Social Care Wales Code of Professional Practice requirements.

Managers, finance staff, administrators and staff who support individuals with money will receive role-specific training and competency checks. Staff understanding will be reviewed through supervision, spot checks, audits, team meetings and performance management.

6.3. Continuous Monitoring, Audit and Improvement

The service will monitor the effectiveness of this policy through:

• regular internal audits of financial records, resident money records, gifts and hospitality records, conflict of interest declarations, petty cash, invoices, procurement records, payroll, expenses and safeguarding referrals;
• review of incidents, complaints, whistleblowing concerns, safeguarding matters, notifiable events and audit findings;
• Responsible Individual visits and governance reviews;
• staff supervision, team meetings and competency checks;
• review of supplier arrangements and procurement decisions;
• review of any patterns, trends, near misses or repeated concerns.

The Responsible Individual will ensure relevant findings are considered as part of the quality-of-care review at least every six months. Any learning will be used to improve systems, update policies, provide staff training, reduce risk and protect individuals.

6.4. Duty of Candour and Openness

{{org_field_name}} will act in an open and transparent way with individuals, their representatives and relevant authorities when bribery, fraud, financial abuse, errors, omissions or financial irregularities affect, or may affect, an individual’s well-being, rights, finances, property, care or support.

Where something has gone wrong, the service will:

• take immediate action to protect the individual;
• provide an honest explanation as soon as it is appropriate to do so;
• apologise where appropriate;
• explain what action is being taken;
• involve safeguarding, CIW, commissioners, representatives, police or other bodies where required;
• record the concern, action taken, outcome and learning.

Staff must not conceal mistakes, falsify records, obstruct reporting, victimise whistleblowers, or prevent another person from being open and honest.

6.5. Records and Registers

The following records will be maintained securely and reviewed regularly:

• Gifts and Hospitality Register;
• Conflict of Interest Register;
• Resident Money and Property Records;
• Petty Cash Records;
• Procurement and Supplier Due Diligence Records;
• Invoice and Payment Approval Records;
• Fraud, Bribery and Financial Irregularity Log;
• Safeguarding Referral Records;
• CIW Notification Records;
• Investigation Records;
• Training and Competency Records;
• Audit and Quality Monitoring Records.

Records must be accurate, complete, contemporaneous, securely stored and available for inspection by authorised persons, including CIW, where required. Electronic records must have appropriate access controls and audit trails.

6.6. Data Protection and Confidentiality

Information relating to bribery, fraud, financial abuse, safeguarding, staff conduct, resident finances, investigations and whistleblowing will be handled confidentially and in line with UK GDPR, the Data Protection Act 2018, safeguarding duties, employment law and regulatory requirements.

Confidentiality will not prevent {{org_field_name}} from sharing information where this is necessary to protect individuals, prevent crime, report to CIW, make safeguarding referrals, notify police, inform commissioners, refer to DBS or professional regulators, obtain legal advice, support insurance claims, or comply with a lawful request.

7. Related Policies

This policy works alongside:

• CHW04 – Good Governance Policy
• CHW11 – Safe Care and Treatment Policy
• CHW13 – Safeguarding Adults from Abuse and Improper Treatment Policy
• CHW26 – Recruitment, Selection, and Retention Policy
• CHW29 – Whistleblowing (Speaking Up) Policy
• CHW41 – Managing Service User Finances Policy

8. Policy Review

This policy will be reviewed at least annually, or sooner if there are changes in legislation, Welsh Government statutory guidance, CIW requirements, Social Care Wales Codes of Professional Practice, safeguarding procedures, financial risks, service structure, audit findings, incidents, complaints, whistleblowing concerns, safeguarding matters or lessons learned from investigations.

The Registered Manager and Responsible Individual will ensure this policy remains consistent with the Statement of Purpose, related policies and current Welsh regulatory requirements. Updates will be communicated to staff, and additional training will be provided where changes affect staff responsibilities.

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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.