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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Anti-Bribery and Corruption Policy

1. Purpose

The purpose of this policy is to establish clear and comprehensive rules for preventing bribery, corruption, and any form of unethical inducement within {{org_field_name}}. As a provider of temporary nursing and healthcare staff to care homes and other healthcare settings, we are committed to upholding the highest standards of integrity and accountability, in line with the Bribery Act 2010, The Health and Social Care Act 2008, and all applicable UK laws and regulations.

Bribery and corruption undermine trust, damage reputations, and expose individuals and organisations to criminal liability. Our business will not tolerate, permit, or condone any form of bribery or corrupt practice by any employee, agency worker, director, manager, or third party associated with us.

2. Scope

This policy applies to:

• All directors, managers, employees, and contractors of {{org_field_name}}
• All registered nurses, healthcare assistants, and other temporary staff engaged by {{org_field_name}}, whether on zero-hours contracts or other flexible arrangements
• Any third-party suppliers, service providers, or individuals acting on behalf of {{org_field_name}}
• All business interactions including client relationships, regulatory dealings, recruitment, procurement, and commercial operations.

3. Related Policies

• Whistleblowing Policy
• Disciplinary Policy
• Recruitment Policy
• Safeguarding Policy

4. Policy Statement

{{org_field_name}} is committed to a zero-tolerance approach to bribery and corruption. We:

• Prohibit offering, promising, giving, soliciting, or accepting any bribe, whether directly or indirectly
• Commit to full compliance with the Bribery Act 2010 and other relevant UK legislation
• Expect our staff and all associated persons to act with integrity, transparency, and in the best interest of the service users, clients, and the public
• Require prompt reporting and investigation of all suspected instances of bribery or corruption

5. Definitions

Bribery is offering, promising, giving, requesting, or accepting an advantage as an inducement for action which is illegal, unethical, or a breach of trust.

Corruption is the abuse of entrusted power for private gain.

Examples include:

• Paying or receiving kickbacks or facilitation payments to secure contracts or placements
• Offering money or gifts to gain preferential treatment
• Manipulating timesheets or invoicing to deceive clients or authorities
• Bribes disguised as charitable donations, sponsorships, or recruitment fees

6. Responsibilities

Directors and Senior Managers
Directors are responsible for:

• Demonstrating visible commitment to anti-bribery and corruption principles
• Leading by example and promoting a culture of integrity
• Ensuring all staff and associated persons are trained and fully informed of this policy
• Implementing appropriate financial controls, recruitment practices, and operational procedures
• Regularly monitoring compliance and taking swift action where concerns are raised
• Reporting serious breaches to regulatory bodies (e.g., CQC) and law enforcement if applicable

All Staff, Temporary Workers and Contractors
All personnel, regardless of role, must:

• Familiarise themselves with this policy
• Avoid situations that could be perceived as bribery or corruption
• Refuse any bribes or improper offers and report them immediately
• Declare all gifts and hospitality received or offered in accordance with the Gifts and Hospitality Policy
• Disclose conflicts of interest promptly
• Cooperate fully in any investigation into suspected bribery or corruption

7. Gifts and Hospitality

While appropriate hospitality and small tokens of appreciation are part of normal business practice, offering or receiving gifts or hospitality must:

• Never influence, or appear to influence, decisions or professional conduct
• Be declared to management if valued over £25
• Be refused if offered during tendering, recruitment, or contract negotiations
• Be documented in the Gifts and Hospitality Register, maintained by the director

8. Managing Third Parties

All third-party contractors, suppliers, umbrella companies, and recruitment partners must:

• Comply with this Anti-Bribery and Corruption Policy
• Be subject to appropriate due diligence, including references, financial checks, and regulatory screening
• Agree to written contractual terms which include anti-bribery clauses
• Be monitored for ongoing compliance, with immediate termination of contracts if bribery or corruption is suspected or proven

9. Reporting Concerns (Whistleblowing)

Any suspicion or evidence of bribery or corruption must be reported immediately to the Registered Manager via:

• Email: {{org_field_name}}
• Phone: {{org_field_number}}
• In-person discussion, or
• Using the confidential Whistleblowing Procedure

No staff member will face retaliation for raising a genuine concern, even if it turns out to be unfounded. Full confidentiality will be maintained where appropriate.

10. Investigations and Disciplinary Action

All allegations will be:

• Investigated thoroughly and impartially
• Documented with outcomes recorded securely
• Reported to the appropriate regulatory or enforcement agencies if required

Confirmed cases of bribery or corruption may result in:

• Summary dismissal
• Termination of contracts for agency workers or third parties
• Reporting to professional bodies such as the NMC
• Civil or criminal proceedings

11. Training and Communication

All employees, agency workers, and relevant third parties must complete mandatory anti-bribery and corruption training as part of their induction and regular refresher programmes. Training will cover:

• The law (Bribery Act 2010)
• Definitions and examples of bribery and corruption
• Reporting procedures
• Case studies relevant to healthcare and agency settings

Information will be communicated clearly through:

• Staff handbooks
• Employment contracts
• Policies and procedures manual
• Training sessions and annual refreshers

12. Record-Keeping

{{org_field_name}} will:

• Maintain accurate records of all financial transactions
• Record all gifts, hospitality, sponsorships, and donations
• Keep records of all investigations, outcomes, and actions taken
• Review expense claims, invoices, and payments regularly for irregularities

13. Risk Assessment and Review

Directors will:

• Conduct regular risk assessments, particularly when entering new markets, contracting with new clients, or engaging third parties
• Evaluate business activities, client relationships, and financial procedures for potential exposure to bribery or corruption
• Review and update this policy annually or sooner if:
  • Legislation changes
  • Business practices change
  • A significant incident occurs

14. Monitoring and Continuous Improvement

{{org_field_name}} will:

• Monitor compliance via audits and spot-checks
• Encourage staff to provide feedback on policy effectiveness
• Take corrective actions when weaknesses or non-compliance are identified
• Share lessons learned across the organisation

15. Policy Review

This policy will be reviewed at least once every 12 months or sooner if:

• There are changes in legislation, regulatory requirements, or best practice
• Business operations change significantly
• An incident requires policy revision

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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.