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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, which makes it a criminal offence to offer, promise, give, request, or accept a bribe.
• The Fraud Act 2006, which defines fraud as dishonestly obtaining an advantage through deception.
• The Regulation and Inspection of Social Care (Wales) Act 2016, which requires service providers to uphold ethical financial and governance standards.
• Care Inspectorate Wales (CIW) guidance, which expects service providers to maintain robust financial controls and prevent abuse.
• The Public Interest Disclosure Act 1998, which protects whistleblowers who report concerns of bribery or fraud.

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.

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 secure an unfair or unlawful financial or personal gain. Examples include:

• Falsifying expense claims or financial records to misappropriate funds.
• Staff inflating working hours or submitting false timesheets.
• Misusing service user funds, including unauthorised transactions or deception.
• Providing false information during recruitment, such as falsified qualifications.

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 and Transparency

To minimise the risk of financial fraud, we implement robust financial controls, including:

• Clear segregation of duties, ensuring no single individual has sole control over financial transactions.
• Regular financial audits and independent reviews, ensuring transparency in accounting records.
• Strict procedures for handling service user finances, including dual-signature authorisation for transactions.
• Electronic and paper records of all financial transactions, ensuring full accountability.

4.3. Managing Gifts and Hospitality

• Employees must not accept personal gifts, cash, or hospitality from service users, families, suppliers, or contractors.
• Any gifts or hospitality exceeding a nominal value (£20) must be declared and recorded in the Gifts and Hospitality Register.
• Staff must report any attempts to offer bribes, ensuring compliance with legal obligations.

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.

5. Reporting Procedures and Investigation Process

5.1. Reporting Concerns of Bribery or Fraud

Any staff member, service user, or external stakeholder suspecting bribery or fraud must:

1. Report the concern immediately to their Line Manager or the Registered Manager.
2. Alternatively, contact the Designated Whistleblowing Officer at {{org_field_registered_manager_email}}.
3. If internal reporting is not appropriate, concerns can be raised with:
   • Care Inspectorate Wales (CIW) for regulatory concerns.
   • The police if criminal activity is suspected.
   • The National Fraud and Cyber Crime Reporting Centre (Action Fraud).

All reports will be treated confidentially, and whistleblowers are legally protected from victimisation under the Public Interest Disclosure Act 1998.

5.2. Investigation Process

Once a concern is reported:

1. Initial review – The Registered Manager or designated investigator will conduct an initial assessment.
2. Formal investigation – If there is credible evidence, an internal or external investigation will be conducted.
3. Staff interviews and document review – Statements, financial records, and relevant documents will be examined.
4. Disciplinary action – If misconduct is found, appropriate action will be taken, which may include dismissal and referral to law enforcement.
5. Reporting to CIW and relevant authorities, where required.

If the investigation finds no wrongdoing, the individual who raised the concern will be informed, and no further action will be taken.

5.3. Consequences of Bribery and Fraud

Any staff member found guilty of bribery or fraud may face:

• Immediate dismissal for gross misconduct.
• Legal action, including prosecution under the Bribery Act 2010 or Fraud Act 2006.
• Referral to regulatory bodies, such as CIW, DBS, or professional licensing organisations.

6. Managing Bribery and Fraud Prevention Efficiently

6.1. Leadership and Accountability

• The Registered Manager is responsible for overseeing anti-bribery and fraud prevention measures.
• All department heads must ensure compliance within their teams.
• The Finance Team is responsible for financial oversight, audits, and reporting irregularities.

6.2. Staff Training and Awareness

• Mandatory anti-bribery and fraud training is provided to all staff during induction.
• Annual refresher training reinforces awareness and regulatory updates.
• Role-specific training is provided for managers and financial staff.
• Clear reporting channels are displayed in staff areas to encourage reporting of concerns.

6.3. Continuous Monitoring and Improvement

• Regular internal audits assess compliance with financial and anti-bribery controls.
• Incident trends and reports are reviewed to identify risks and implement preventative measures.
• Annual policy reviews ensure alignment with CIW regulations, legal requirements, and best practices.

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 is reviewed annually, or sooner if changes in legislation, CIW guidance, or financial risk assessments require updates.

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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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