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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Bribery Prevention Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} upholds the highest standards of integrity, transparency, and accountability by preventing bribery and corruption within our organisation. This policy complies with the Bribery Act 2010, Care Inspectorate Scotland regulations, and the Scottish Social Services Council (SSSC) Codes of Practice.

This policy aims to:

• Prevent bribery, corruption, and unethical behaviour within the organisation.
• Ensure all staff understand their legal and ethical responsibilities.
• Protect {{org_field_name}} from reputational and legal risks associated with bribery.
• Encourage a culture of honesty and openness in financial and operational dealings.
• Outline clear reporting and investigation procedures for any suspected bribery cases.

2. Scope

This policy applies to:

• All employees, including care workers, supervisors, and management.
• Agency and temporary staff working with {{org_field_name}}.
• Board members, contractors, suppliers, and business partners.
• Any individuals acting on behalf of or representing {{org_field_name}}.

This policy covers all forms of bribery and corruption, including:

• Offering, promising, or giving a bribe.
• Requesting, agreeing to receive, or accepting a bribe.
• Bribery of foreign public officials.
• Corporate failure to prevent bribery.

3. Legal and Regulatory Framework

This policy aligns with:

• Bribery Act 2010 – Establishing offences related to bribery and corruption.
• Care Inspectorate’s Quality Framework – Defining expectations for ethical business conduct in care services.
• Health and Social Care Standards (Scotland) 2018 – Promoting dignity, respect, and ethical care practices.
• Scottish Social Services Council (SSSC) Codes of Practice – Ensuring ethical conduct among social service workers.
• The Public Services Reform (Scotland) Act 2010 – Addressing financial transparency in public service organisations.
• The Regulation of Care (Scotland) Act 2001 – Governing care service conduct and ethical standards.

4. Definition of Bribery and Corruption

Bribery is defined as the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action that is illegal, unethical, or a breach of trust. This includes:

• Financial payments or gifts.
• Kickbacks or facilitation payments.
• Favouritism or preferential treatment.
• Unlawful donations or sponsorships.
• Hospitality, travel, or accommodation offered in return for favourable treatment.

5. Responsibilities of Staff

All employees, agency workers, and business partners must:

• Act with integrity and uphold ethical standards at all times.
• Not offer, give, request, or accept bribes in any form.
• Report any suspected bribery through the established reporting channels.
• Adhere to financial and procurement policies to prevent bribery risks.
• Attend mandatory anti-bribery training to understand obligations and risks.

Managers and senior staff must:

• Lead by example and promote a culture of transparency and integrity.
• Ensure compliance with anti-bribery laws and policies.
• Monitor financial transactions to detect any irregularities.
• Support staff in reporting concerns without fear of retaliation.

6. Gifts and Hospitality Policy

{{org_field_name}} permits the exchange of gifts and hospitality only when:

• It is of low value and given without expectation of favours.
• It is not intended to influence decisions or gain an unfair advantage.
• It complies with local laws, organisational policies, and ethical standards.
• It is recorded in the Gifts and Hospitality Register for transparency.

The following are strictly prohibited:

• Offering or accepting cash gifts.
• Accepting expensive or excessive gifts.
• Providing gifts to public officials, inspectors, or procurement officers.
• Offering hospitality in exchange for business advantages.

7. Reporting and Investigation Procedures

Employees must report any suspected or actual bribery to:

• Their line manager or senior leadership.
• The designated Bribery Prevention Officer.
• The Whistleblowing Hotline (anonymous reporting available).

Investigation Process:

1. Initial Assessment – The concern is reviewed to determine if further action is required.
2. Formal Investigation – If evidence is found, an internal investigation will be launched.
3. Legal and Regulatory Reporting – If necessary, reports will be made to external regulatory bodies such as the Care Inspectorate Scotland or law enforcement authorities.
4. Action and Resolution – If wrongdoing is confirmed, disciplinary action (including termination) or legal proceedings may be initiated.

Retaliation against individuals who report concerns will not be tolerated.

8. Preventative Measures

To prevent bribery, {{org_field_name}} implements:

• Strict financial controls to monitor transactions and prevent illicit payments.
• Robust procurement procedures to ensure fair selection of suppliers and service providers.
• Regular audits and risk assessments to identify potential bribery risks.
• Mandatory anti-bribery training for all employees.
• Clear policies on gifts, hospitality, and conflicts of interest.

9. Staff Training and Awareness

All staff must complete:

• Induction training on bribery prevention.
• Annual refresher training on ethical conduct and financial integrity.
• Specialist training for finance and procurement teams.

Training will ensure that employees:

• Recognise and prevent bribery risks.
• Understand reporting procedures.
• Promote a culture of ethical responsibility.

10. Consequences of Policy Breach

Failure to comply with this policy may result in:

• Disciplinary action, including dismissal.
• Legal consequences, including fines or imprisonment under the Bribery Act 2010.
• Reputational damage to both the individual and {{org_field_name}}.

11. Related Policies

This policy should be read alongside:

• Whistleblowing Policy
• Financial Management and Procurement Policy
• Code of Conduct Policy
• Gifts and Hospitality Policy
• Fraud Prevention Policy

12. Policy Review

This policy will be reviewed annually or sooner if there are changes in legislation, best practices, or organisational needs. Any amendments will be communicated to all staff and relevant stakeholders.

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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.