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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}} has a zero-tolerance approach to bribery, corruption, and fraud in line with the Bribery Act 2010, the Fraud Act 2006, and the Care Quality Commission (CQC) regulations. This policy aims to:

• Prevent bribery and fraud within our organisation.
• Ensure compliance with CQC Regulation 17 (Good Governance)​.
• Promote a culture of honesty, transparency, and accountability.
• Protect the people we support, staff, and the organisation from financial loss and reputational damage.
• Provide staff with clear guidance on recognising, reporting, and preventing fraud and bribery.

2. Scope

This policy applies to:

• All staff members at {{org_field_name}}, including management, care staff, administrative staff, volunteers, and contractors.
• The people we support, their families, and representatives.
• External stakeholders including suppliers, partners, and local authorities.
• All financial transactions, procurement activities, gifts, and hospitality related to our operations.

3. Definitions

3.1 Bribery

Bribery is offering, promising, giving, accepting, or requesting something of value to influence a decision or gain an unfair advantage. This includes:

• Cash payments, gifts, or favours in exchange for preferential treatment.
• Kickbacks in contracts or services.
• Improper financial incentives in care provision or referrals.

3.2 Fraud

Fraud is deliberate deception intended to secure an unfair or unlawful financial or personal gain. Examples include:

• False invoicing or exaggerated expenses.
• Falsification of records (e.g., time sheets, financial accounts, care records).
• Misrepresentation of qualifications or identity for personal gain.

3.3 Corruption

Corruption is the abuse of entrusted power for personal gain. This includes conflicts of interest, misuse of funds, and exploiting relationships for financial benefit.

4. Preventing Bribery and Fraud

4.1 Zero-Tolerance Approach

• {{org_field_name}} has a zero-tolerance policy towards bribery, fraud, and corruption.
• Any staff member involved in such activities will face disciplinary action, including dismissal and legal prosecution.

4.2 Staff Responsibilities

• All staff must comply with this policy and report any suspicions of bribery or fraud.
• Managers must ensure staff understand and adhere to anti-bribery procedures.
• Financial and procurement staff must conduct due diligence on suppliers and contracts.

4.3 Identifying and Reporting Suspicious Activity

• Staff must remain vigilant for warning signs, such as:
  • Unusual cash transactions or payments.
  • Sudden changes in financial behaviour.
  • Pressure to bypass standard procedures.
  • Requests for preferential treatment or favours.
• Any suspicions must be reported immediately to:
  • The Registered Manager – {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}.
  • The Company Director – {{org_field_company_director_first_name}} {{org_field_company_director_last_name}}.
  • The Data Protection Officer – {{org_field_data_protection_officer_first_name}} {{org_field_data_protection_officer_last_name}} (if data fraud is suspected).

5. Financial and Procurement Controls

5.1 Transparent Financial Processes

• All financial transactions must be clearly recorded, authorised, and regularly audited.
• Payments must be made through secure and approved methods.
• Two-authorisation system for significant financial transactions to prevent unauthorised payments.

5.2 Supplier and Contractor Due Diligence

• All suppliers and contractors must be vetted for legitimacy.
• Contracts must include anti-bribery and fraud clauses.
• Suppliers offering incentives or commissions must be reported immediately.

5.3 Staff Expenses and Reimbursements

• All expenses must be accurately documented and submitted for approval.
• Personal gain from falsifying expense claims is fraud and will result in disciplinary action.

6. Gifts and Hospitality Policy

6.1 Acceptable and Unacceptable Gifts

• Small, token gifts (e.g., chocolates, flowers) may be accepted if declared to management.
• Expensive gifts, cash, or hospitality exceeding £25 must be declined or reported.
• Gifts or incentives must never influence decisions or service delivery.

6.2 Declaring Gifts and Hospitality

• A Gifts and Hospitality Register is maintained to record:
  • The nature of the gift.
  • The giver’s name and relationship to the organisation.
  • Approval from senior management for any exceptions.

7. Preventing Conflicts of Interest

• Staff must declare any personal or financial interests that could compromise impartiality.
• Staff involved in procurement must not have personal relationships with suppliers.
• Recruitment and promotions must be based on merit, without favouritism or nepotism.

8. Reporting and Investigating Bribery and Fraud

8.1 Confidential Reporting Mechanism

• Staff can report concerns via:
  • Line managers.
  • The Registered Manager.
  • The Whistleblowing (Speaking Up) Policy (CH29)​.
• Reports can be anonymous and will be treated confidentially.

8.2 Investigation Procedures

• All allegations will be thoroughly investigated.
• If fraud is confirmed, disciplinary action will be taken, and legal authorities will be notified if necessary.
• If a report is found to be malicious or false, appropriate disciplinary action will be taken.

9. Staff Training and Awareness

• All staff receive training on bribery, fraud prevention, and ethical conduct as part of induction and annual refresher training.
• Managers and financial staff receive enhanced training on fraud risk management.
• Regular awareness campaigns to reinforce zero-tolerance culture.

10. Compliance Monitoring and Audits

• Regular audits and risk assessments will be conducted to detect and prevent bribery and fraud.
• Findings will be reported to the Registered Manager and Company Director.
• This policy will be reviewed annually or when significant changes occur.

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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.