NA93-Financial and Anti-Fraud Policy

Registration Number: {{org_field_registration_no}}

Financial and Anti-Fraud Policy

1. Purpose

The purpose of this policy is to provide a comprehensive framework for the effective management of financial resources and the prevention, detection, and response to fraud, corruption, bribery, or financial malpractice within {{org_field_name}}. As a temporary staffing agency providing registered nurses, healthcare assistants, and other healthcare staff to care homes and healthcare settings, {{org_field_name}} has a legal and ethical responsibility to manage finances responsibly and to maintain high standards of financial integrity, transparency, and accountability. Fraud, theft, and financial misconduct can undermine confidence in the agency, damage relationships with clients and stakeholders, and place service users and staff at risk. This policy aligns with the Fraud Act 2006, Bribery Act 2010, Proceeds of Crime Act 2002, Money Laundering Regulations 2017, Companies Act 2006, Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and relevant Care Quality Commission (CQC) Fundamental Standards.

2. Scope

This policy applies to: All directors, staff, contractors, and temporary workers employed or supplied by {{org_field_name}}. All financial transactions, payroll operations, invoicing, procurement, expense claims, and financial record-keeping. All funds, assets, and financial resources owned, managed, or overseen by {{org_field_name}}. The prevention and management of fraud, theft, financial abuse, bribery, corruption, and misuse of funds.

3. Related Policies

Code of Conduct – Confidentiality and Data Protection Policy – Recruitment Policy – Whistleblowing Policy – Conflict of Interest Policy – Anti-Bribery and Corruption Policy – Complaints Policy – Incident Reporting and Investigation Policy

4. Policy Statement

{{org_field_name}} is committed to achieving the highest standards of financial integrity, honesty, and accountability. The agency operates a zero-tolerance approach to fraud, theft, financial malpractice, and bribery. The directors will ensure that financial resources are used solely for legitimate business purposes and that robust systems are in place to safeguard assets, detect irregularities, and respond to suspected financial misconduct. All staff are expected to act honestly, with integrity, and in compliance with this policy and relevant legal requirements.

5. Responsibilities

Directors The directors of {{org_field_name}} will: Ensure robust financial systems, procedures, and controls are established and maintained. Oversee all financial management activities, including payroll, invoicing, procurement, and record keeping. Conduct regular financial audits and reviews. Investigate suspected or actual instances of fraud, bribery, or financial irregularity. Report criminal conduct to the appropriate authorities (e.g., police, HMRC, National Crime Agency). Provide training to all relevant staff on financial responsibilities and fraud awareness. Review and update this policy at least annually or when changes in legislation occur.

All Staff and Temporary Workers All staff and temporary workers must: Act honestly and with integrity in all financial dealings. Report any concerns or suspicions of financial malpractice, fraud, or irregularity to the directors immediately. Declare any conflicts of interest relating to financial transactions or decisions. Avoid any actions that could be perceived as dishonest, fraudulent, or improper.

6. Financial Management Controls

The directors of {{org_field_name}} will implement and maintain the following controls: Segregation of duties to ensure that no individual is solely responsible for financial processing and authorisation. Dual authorisation for payments and procurement where practical. Formal authorisation processes for expenses, payroll, procurement, and banking activities. Accurate and timely record-keeping of all financial transactions. Reconciliation of bank accounts, payroll records, and other financial documents on a regular basis. Secure handling and storage of financial records, cash, and sensitive information.

7. Definition of Fraud

For the purposes of this policy, fraud includes: Falsification of documents, financial records, or signatures. Misappropriation of funds, cash, or assets. Submission of false claims for payment or expenses. Deliberate misrepresentation of financial information. Theft or unauthorised removal of funds, assets, or property. Use of company funds or assets for personal gain.

8. Definition of Bribery and Corruption

Bribery and corruption include: Offering, giving, receiving, or soliciting anything of value to improperly influence a business decision or gain an unfair advantage. Accepting gifts, hospitality, or favours that create or appear to create a conflict of interest. Facilitating payments (i.e., unofficial payments made to secure or speed up a routine task). Offering or receiving kickbacks, commissions, or incentives that are not declared and approved by the directors.

9. Payroll and Temporary Worker Payments

The directors will ensure that: All temporary workers are paid correctly, accurately, and promptly for hours worked. Pay rates and terms are agreed in writing prior to assignment. Timesheets or electronic attendance records are verified by authorised client representatives before payment is made. Deductions, including tax, National Insurance, and pension contributions (if applicable), are correctly calculated and processed. Any overpayments or underpayments are rectified promptly.

10. Procurement and Expenses

Procurement of goods and services will: Follow a fair, transparent, and cost-effective process. Involve appropriate authorisation, quotation, or tendering procedures. Be recorded accurately, including supplier details, authorisation, and payment information. Expenses will be reimbursed to staff only where pre-approved and supported by appropriate documentation (receipts, invoices). Personal purchases, non-essential items, or unapproved expenses will not be reimbursed.

11. Financial Record Keeping

All financial records will be: Accurate, complete, and up to date. Retained for at least six years in accordance with the Companies Act 2006 and HMRC requirements. Accessible only to authorised personnel. Available for inspection by auditors, regulatory bodies, or law enforcement when required. Protected against unauthorised access, loss, or damage in accordance with data protection legislation.

12. Detection and Reporting of Fraud

All staff have a responsibility to report suspected or actual fraud, bribery, or financial irregularities. Staff may report: Directly to a director. Anonymously through the Whistleblowing Policy. Externally to regulators or law enforcement where appropriate. The directors will: Treat all concerns seriously and confidentially. Investigate all reports promptly and fairly. Take appropriate action, including disciplinary procedures, referral to regulatory bodies, or legal action.

13. Investigations

Investigations into suspected fraud or financial misconduct will: Be conducted by the directors or an appointed independent investigator. Involve full documentation of findings and evidence. Maintain confidentiality where appropriate, balanced against the need to act. Ensure that staff subject to investigation are treated fairly and given an opportunity to respond to allegations. Result in appropriate actions being taken to recover losses, improve controls, and prevent recurrence.

14. Staff Training

{{org_field_name}} will provide training for all staff on: Financial controls and procedures. Recognising and reporting fraud and bribery. Whistleblowing procedures. Training will be refreshed regularly and updated following changes in legislation, guidance, or internal procedures.

15. Conflict of Interest

All staff must declare any personal, financial, or other interests which could compromise or appear to compromise their objectivity in financial matters. Declarations will be recorded, reviewed, and, where necessary, action will be taken to prevent conflicts.

16. Gifts and Hospitality

Staff must not: Accept gifts or hospitality from clients, suppliers, or contractors without prior approval from a director. Offer gifts, hospitality, or favours with the intention of influencing a business decision. All gifts and hospitality accepted must be recorded in the Gifts and Hospitality Register maintained by the directors.

17. Continuous Improvement

The directors of {{org_field_name}} will: Regularly review financial procedures and controls to ensure they remain effective. Act upon findings from audits, inspections, or investigations. Incorporate lessons learned into staff training and policy updates.

18. Policy Review

This policy will be reviewed annually or earlier if: Changes occur in relevant legislation (e.g., Bribery Act, Fraud Act, Companies Act). Feedback or audit findings suggest improvements are needed. Incident investigations indicate gaps in existing controls.

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.