{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

---

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}}. We are committed to upholding the highest standards of integrity, transparency and accountability in line with the Bribery Act 2010, the Ministry of Justice guidance on procedures to prevent bribery issued under section 9 of that Act, and all other applicable laws and regulatory requirements in England. Where the Company is not itself carrying on a regulated activity, references in this policy to healthcare settings, clients or regulators do not mean that the Company is a CQC-registered provider; compliance responsibilities will be applied according to the Company’s actual legal status and service model.

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

This policy should be read alongside the following, where applicable:

• Whistleblowing Policy
• Disciplinary Policy
• Recruitment and Vetting Policy
• Gifts, Hospitality and Expenses Policy
• Conflicts of Interest Policy
• Procurement / Supplier Due Diligence Procedure
• Financial Controls and Authorisation Procedure
• Data Protection and Records Retention Policy

Together, these documents form part of the Company’s procedures for preventing bribery and corruption.

4. Policy Statement

{{org_field_name}} adopts a zero-tolerance approach to bribery and corruption. The Company prohibits all forms of bribery, whether direct or indirect, in the public or private sector, including bribery by employees, workers, agency staff, directors, officers, contractors, consultants, suppliers, intermediaries, introducers and any other person performing services for or on behalf of the Company.

The Company is committed to complying with the Bribery Act 2010, including the offence of failure by a commercial organisation to prevent bribery under section 7. The Company will maintain proportionate procedures designed to prevent persons associated with it from engaging in bribery and will take disciplinary, contractual and, where appropriate, legal action in response to breaches.

No person acting for or on behalf of the Company may offer, promise, give, request or accept a bribe, facilitation payment, kickback or any other improper advantage intended to influence a decision, secure business, obtain preferential treatment, or induce the improper performance of a relevant function or activity.

5. Definitions

For the purposes of this policy:

Bribery means offering, promising or giving a financial or other advantage, or requesting, agreeing to receive or accepting such an advantage, where the intention or effect is to induce or reward the improper performance of a relevant function or activity, or where acceptance of the advantage would itself amount to improper performance.

Corruption means the abuse of entrusted power, position or influence for private gain or improper advantage.

Associated person means any person who performs services for or on behalf of the Company. This can include employees, agency workers, temporary workers, contractors, consultants, introducers, intermediaries, umbrella companies, suppliers and other business partners, depending on the circumstances.

Facilitation payment means an unofficial payment or advantage requested or offered to secure or speed up a routine or necessary action. Facilitation payments are prohibited under this policy.

Kickback means a payment, commission, rebate or other benefit given in return for improperly awarding, steering or retaining business or for securing an improper commercial advantage.

Foreign public official has the meaning used in the Bribery Act 2010 and includes certain persons holding legislative, administrative or judicial positions or exercising public functions outside the United Kingdom.

Examples of prohibited conduct include:

• paying, offering or accepting kickbacks to secure placements, contracts, shifts or preferred supplier status;
• offering gifts, hospitality or other benefits to influence tendering, procurement, rostering, recruitment or contract decisions;
• manipulating timesheets, charge rates, invoices, expenses or payroll records for dishonest gain;
• disguising bribes as charitable donations, sponsorships, rebates, referral fees, consultancy fees or recruitment fees;
• using third parties to make improper payments on the Company’s behalf.

6. Responsibilities

Directors and Senior Managers

Directors and senior managers are responsible for:

• demonstrating visible and active commitment to preventing bribery and corruption;
• ensuring that proportionate anti-bribery procedures are implemented and kept under review;
• identifying and assessing bribery risks in the Company’s business, including risks arising from recruitment, placements, client acquisition, supplier engagement, payroll, invoicing, procurement and the use of third parties;
• ensuring appropriate financial controls, segregation of duties and approval processes are in place;
• ensuring that gifts, hospitality, expenses, conflicts of interest and third-party due diligence are properly recorded and reviewed;
• ensuring that all relevant personnel receive appropriate induction and refresher training;
• ensuring that concerns are investigated promptly, fairly and confidentially; and
• taking appropriate disciplinary, contractual, remedial and, where necessary, legal or regulatory action.

Any reference in this policy to reporting matters to external regulators applies only where there is a legal, contractual or professional duty to do so in the circumstances of the case.

All Staff, Temporary Workers and Contractors

All personnel covered by this policy must:

• read, understand and comply with this policy and any related procedure;
• avoid any conduct that could amount to bribery, corruption, facilitation payments, kickbacks or improper influence;
• never use personal funds, third parties, gifts, hospitality, donations, referral arrangements or sham service agreements to circumvent this policy;
• declare gifts, hospitality, outside interests, close personal relationships and any actual, potential or perceived conflict of interest promptly;
• keep accurate and complete records relating to expenses, timesheets, invoices, procurement, recruitment and payments;
• report concerns immediately using the reporting routes in this policy or the Whistleblowing Policy; and
• cooperate fully with audits, reviews and investigations.

7. Gifts, Hospitality and Business Courtesies

The Company recognises that reasonable and proportionate hospitality may, in limited circumstances, form part of legitimate business relationship management. However, gifts, hospitality or other business courtesies must never be offered, promised, given, requested or accepted where they are intended, or could reasonably be perceived, to influence a business decision, secure an improper advantage, reward preferential treatment, or compromise professional judgment.

The following rules apply:

• cash or cash equivalents, including vouchers or personal discounts not generally available to staff, must never be offered or accepted;
• gifts or hospitality must not be offered or accepted during tender processes, audits, investigations, complaints, recruitment exercises, contract negotiations, rate reviews or supplier selection exercises unless expressly approved in writing by a director and clearly justifiable;
• repeated, lavish or non-transparent gifts or hospitality are prohibited regardless of value;
• all gifts and hospitality above the Company’s internal reporting threshold, and any gift or hospitality that could reasonably give rise to concern regardless of value, must be declared and recorded in the Gifts and Hospitality Register;
• where there is any doubt, the gift or hospitality must be declined or written approval obtained in advance from a director or nominated compliance lead.

For the avoidance of doubt, compliance with any internal value threshold does not make a gift or hospitality acceptable if the purpose or effect would be improper.

7.1 Facilitation Payments, Charitable Donations and Political Contributions

The Company prohibits facilitation payments of any kind. No person covered by this policy may make or authorise an unofficial payment or provide any other advantage in order to secure, expedite or influence a routine action.

Charitable donations, sponsorships and community contributions must never be used to disguise an improper payment or to obtain an improper business advantage. Any such payment made in the Company’s name must be transparent, accurately recorded, approved in advance in accordance with the Company’s financial controls and supported by a legitimate business or charitable rationale.

Political donations or contributions in the Company’s name may only be made where lawful and with prior written approval of the Board or a director specifically authorised by the Board. Any approved political donation or contribution must be transparently recorded and must never be made for the purpose of securing an improper advantage.

8. Third Parties, Intermediaries and Business Partners

Because the Company may be liable where a person associated with it engages in bribery, the Company will apply proportionate due diligence to third parties who perform services for or on its behalf or who may create bribery risk. This includes, where appropriate:

• verifying identity, ownership, business legitimacy and relevant experience;
• checking references, adverse information, regulatory status and, where relevant, sanctions or enforcement concerns;
• understanding the rationale for the relationship, the services to be provided, and the proposed fee or commission structure;
• assessing whether the third party is seeking unusual payment methods, offshore payments, excessive commissions, vague service descriptions, undocumented introductions or other red flags;
• ensuring written contracts contain appropriate anti-bribery, audit, cooperation and termination clauses; and
• monitoring the relationship on an ongoing basis, especially where the third party interacts with clients, candidates, workers, public bodies or regulators on the Company’s behalf.

No third party may be appointed, retained or paid where due diligence is incomplete, concerns remain unresolved, or the proposed arrangement appears designed to conceal an improper payment or influence.

9. Reporting Concerns and Whistleblowing

Any person covered by this policy must report as soon as possible any suspected or actual bribery, corruption, facilitation payment, kickback, falsification of records, conflict of interest, improper pressure or other conduct that may breach this policy or applicable law.

Concerns should normally be reported to the individual’s line manager, a director, or the person designated by the Company to receive compliance or whistleblowing concerns. Where the concern involves that person, or the reporter does not feel able to raise it through the normal route, the concern should be raised through the Whistleblowing Policy using an alternative reporting channel.

Reports may be made verbally or in writing and should include as much relevant detail as possible. The Company will treat reports seriously, handle them as confidentially as reasonably possible, and will not subject any worker to retaliation, detriment or dismissal for making a genuine report or protected disclosure.

The Company’s separate Whistleblowing Policy explains reporting routes, investigation arrangements and the protections available under the Employment Rights Act 1996 as amended by the Public Interest Disclosure Act 1998.

10. Investigations, Outcomes and Action

All allegations or suspicions of bribery or corruption will be assessed promptly and, where appropriate, investigated thoroughly, fairly and without prejudging the outcome. Investigations will be documented and records will be retained securely in accordance with the Company’s data protection and records retention requirements.

Where misconduct is substantiated, the Company may take one or more of the following actions, depending on the circumstances:

• disciplinary action up to and including summary dismissal;
• termination of assignments, engagements, contracts or supplier arrangements;
• recovery of losses or overpayments where lawful;
• notification to affected clients or contracting authorities where appropriate;
• referral to law enforcement, prosecuting authorities or other competent authorities; and/or
• referral to a professional regulator or body, such as the NMC, where the individual is subject to professional registration and the circumstances justify referral.

The Company may also suspend payments, halt transactions, withdraw from tenders or contracts, and implement urgent risk controls while an investigation is ongoing where reasonably necessary.

11. Training and Communication

The Company will provide anti-bribery and corruption training that is proportionate to role and risk. Training will be given at induction and refreshed periodically, with additional targeted training for directors, managers, recruiters, payroll and finance staff, procurement staff, and any person involved in tendering, supplier engagement, rate negotiation, contract management or client relationship management.

Training will cover:

• the offences and risks under the Bribery Act 2010;
• practical examples relevant to temporary staffing and healthcare-related recruitment environments;
• gifts, hospitality, conflicts of interest and facilitation payments;
• third-party risk and due diligence;
• accurate books and records requirements; and
• reporting routes and whistleblowing protections.

The Company may require personnel to confirm periodically that they have read, understood and will comply with this policy.

12. Record-Keeping and Financial Controls

The Company will maintain accurate, complete and transparent books, records and accounts sufficient to demonstrate the legitimate business purpose of transactions and to detect irregularities. No off-book account, false entry, misleading description, backdated approval or concealed payment may be created or used.

The Company will:

• maintain records of gifts, hospitality, donations, sponsorships, conflicts of interest, due diligence checks, approvals, concerns raised, investigations and outcomes;
• ensure expenses, invoices, payroll, timesheets, commission payments, supplier payments and client charging records are reviewed and authorised in accordance with internal controls;
• retain relevant records for an appropriate period in line with legal, regulatory, tax, contractual and data protection requirements; and
• restrict access to sensitive records to those with a legitimate business need.

13. Risk Assessment and Review

The Company will carry out periodic and proportionate assessments of bribery and corruption risk, taking account of the nature, scale and complexity of its activities. Risk assessment will consider, among other things:

• client acquisition and tendering;
• recruitment and onboarding;
• shift allocation, placement decisions and preferred supplier arrangements;
• supplier and intermediary relationships;
• payroll, invoicing, rebates, referral fees and commissions;
• gifts, hospitality and conflicts of interest;
• operations in higher-risk sectors, locations or business relationships; and
• any previous incidents, complaints, audit findings or red flags.

The findings of risk assessments will be used to design, improve and review the Company’s anti-bribery procedures, training, monitoring and due diligence arrangements.

14. Monitoring, Audit and Policy Review

The Company will monitor the effectiveness of this policy and the procedures supporting it through audits, management review, spot checks, training records, register reviews, incident analysis and feedback from staff and business partners.

This policy will be reviewed at least annually and sooner where required because of legislative change, regulatory developments, changes to the Company’s business model, lessons learned from incidents, audit findings, or identified weaknesses in control measures.

Responsibility for review and implementation sits with the Board / Directors or the person formally designated by the Company for compliance oversight.

15. Breach of this Policy

A breach of this policy is a serious matter. Any employee, worker or contractor who breaches this policy may face disciplinary action, termination of engagement, removal from assignments, reporting to clients, professional referral, civil recovery action and/or referral to law enforcement or prosecuting authorities.

Individuals should be aware that bribery is a criminal offence and may result in prosecution, fines and imprisonment. The Company may also face criminal liability, financial penalties, serious reputational damage and exclusion from business opportunities if bribery occurs.

---

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.