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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}} operates a zero-tolerance approach to bribery, corruption and fraud and maintains effective systems of oversight in line with: the Bribery Act 2010; the Fraud Act 2006; and (where the organisation meets the “large organisation” threshold) the corporate offence of Failure to Prevent Fraud under the Economic Crime and Corporate Transparency Act 2023. We also ensure compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including Regulation 17 (Good Governance), and relevant CQC Registration Regulations 2009, including Regulation 18 (Notification of other incidents) where applicable.

This policy supports CQC expectations under the Single Assessment Framework, particularly the Well-led key question, by ensuring robust governance, transparent decision-making, accurate record keeping, risk management, and a culture of openness and accountability.

1. Legal and Regulatory Framework

This policy should be read alongside and implemented in accordance with:

• Bribery Act 2010
• Fraud Act 2006
• Economic Crime and Corporate Transparency Act 2023 (Failure to Prevent Fraud – applies to large organisations)
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (including Regulation 17 Good Governance and Regulation 13 Safeguarding service users from abuse and improper treatment)
• Care Quality Commission (Registration) Regulations 2009 (including Regulation 18 Notification of other incidents, where applicable)
• Care Act 2014 safeguarding duties (including financial abuse as a safeguarding concern)
• Data Protection Act 2018 and UK GDPR (where fraud involves personal data, cybercrime, or data breaches), including ICO reporting requirements where relevant.

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).
  • the Local Authority Safeguarding Adults team (financial abuse is a safeguarding concern)
  • the Police and/or Action Fraud (where a criminal offence is suspected)
  • the CQC where the circumstances meet statutory notification requirements (including where an incident affects the health, safety or welfare of people using the service).

Any immediate protective actions required to safeguard people (for example restricting system access, securing cash/valuables, pausing payments, or increasing oversight) must be implemented without delay.

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.

5.1.1 Segregation of duties

No single person should initiate, approve, and reconcile the same financial transaction wherever practicable.

5.1.2 Authorisation limits

{{org_field_name}} will maintain a clear schedule of authorisation limits (e.g., petty cash, routine purchasing, contracts, and exceptional spend) and these limits will be reviewed at least annually.

5.1.3 Reconciliation and audit trail

Bank reconciliations, supplier statement reconciliations, and spot checks of invoices/receipts will be completed at defined intervals and evidenced.

5.1.4 Petty cash controls

Petty cash must be held securely, supported by receipts, and subject to routine spot checks and reconciliation by an appropriate manager.

5.1.5 Procurement transparency

For significant purchases/contracts we will document (as appropriate): quotes/tenders obtained, conflict of interest declarations, evaluation rationale, and final approval.

5.1.6 Record keeping

Records relating to finance, procurement, gifts/hospitality, declarations of interest, and investigations must be accurate, complete, contemporaneous and securely stored to evidence good governance.

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.

5.4 Service User Money, Property and Financial Safeguarding

Where {{org_field_name}} supports people to manage money or holds money/valuables on a person’s behalf, we will ensure robust safeguards to prevent financial abuse, theft or exploitation. This includes:

• clear written agreement and documented consent/authority for any arrangements,
• individual records for each person (income, expenditure, balances) with receipts,
• secure storage of cash/valuables with controlled access,
• two-person verification for withdrawals/transactions above a defined threshold,
• routine auditing/spot checks and prompt investigation of discrepancies, and
• transparency with the person and/or their representative through regular statements and access to records on request.

Any concern about missing money/valuables, coercion, or unusual transactions will be treated as a potential safeguarding concern and acted upon immediately.

6. Gifts and Hospitality Policy

6.1 Acceptable and Unacceptable Gifts

Staff must not accept any gift, hospitality, donation, discount or other benefit that could reasonably be perceived to influence professional judgement, procurement, referrals, or care decisions.

• Cash, cash equivalents (e.g., vouchers/gift cards), loans, or personal services must never be accepted.
• Modest token gifts (e.g., chocolates, flowers) may be accepted only if they are of low value, appropriate, and declared and recorded.
• Any gift or hospitality that is more than a modest token (as a guide, over £25) must be politely declined. Where refusal may cause distress, the Registered Manager must be informed immediately and a decision recorded, including the rationale and any safeguarding considerations.
• Gifts offered by people we support (or their representatives) require additional scrutiny due to potential vulnerability, undue influence, or coercion. Staff must not request or encourage gifts, and must not accept gifts that could be interpreted as a reward for care or preferential treatment.

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.

The Gifts and Hospitality Register must record all offers, including items that are declined or returned, and must be reviewed periodically as part of governance oversight.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.
• All staff (including managers and directors) must complete a declaration of interests on appointment and at least annually, and whenever circumstances change. A central Register of Interests will be maintained and reviewed by the Registered Manager/Director, with appropriate actions documented to manage or remove conflicts.

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 or suspicions of bribery, fraud, theft or financial abuse will be risk assessed and investigated promptly and proportionately. The investigation will:

• secure and preserve evidence (records, CCTV where applicable, access logs, invoices, receipts, care records),
• take immediate safeguarding actions where any person may be at risk,
• consider whether suspension/temporary redeployment is required to protect people and the integrity of the investigation,
• maintain confidentiality and fairness (including HR processes and the right to representation),
• document findings, decisions, and learning, and implement corrective actions to prevent recurrence.

External reporting: Where a criminal offence is suspected we will refer to the Police and/or Action Fraud. Where a concern involves a person we support (including potential financial abuse), we will consider a safeguarding referral. We will make CQC statutory notifications where required.

Data breaches: If the concern involves personal data (e.g., identity fraud, cybercrime, unauthorised disclosure), we will follow our data breach procedures and consider reporting to the ICO in line with UK GDPR/Data Protection Act requirements.

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.
• Governance oversight will include: periodic review of the Gifts and Hospitality Register, Register of Interests, finance/procurement audit outcomes, themes from incidents/concerns, and completion/quality of staff training. Actions and learning will be documented and tracked to completion to evidence continuous improvement and compliance with good governance requirements.
• 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}}
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