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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Employment of Relatives and Close Associates Policy

1. Purpose

The purpose of this policy is to provide a clear, fair and transparent approach to the recruitment, engagement, deployment and management of relatives and close associates within {{org_field_name}}.

As a temporary staffing agency supplying registered nurses, healthcare assistants and other healthcare professionals to care homes and healthcare settings, {{org_field_name}} is committed to promoting fairness, integrity and professionalism in all areas of its operations. This includes identifying and appropriately managing actual, potential or perceived conflicts of interest, risks to professional boundaries and risks of favouritism that may arise where individuals are related to, or have close personal or business relationships with, existing staff, directors, agency workers, contractors or relevant persons within client organisations.

The aim of this policy is to safeguard the integrity and impartiality of recruitment, deployment and management decisions, maintain appropriate professional boundaries and support the safety and welfare of service users within client settings.

{{org_field_name}} will apply this policy in accordance with legislation applicable to its activities as an employment business, including the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Employment Rights Act 1996 and the Equality Act 2010.

Where agency workers are supplied to a client that carries on regulated health or social care activities, {{org_field_name}} will co-operate with the client in relation to applicable placement requirements. {{org_field_name}} does not itself provide or carry on regulated care under this policy and does not represent itself as a Care Quality Commission registered provider.

2. Scope

This policy applies to:

• All staff employed or engaged by {{org_field_name}}, including registered nurses, healthcare assistants, office staff, directors, and other agency personnel.
• Any applicant for employment with {{org_field_name}} who is related to, or has a close personal or business relationship with, an existing employee, director, or contractor of {{org_field_name}}.
• All stages of employment, including recruitment, selection, deployment, supervision, appraisal, and placement within client settings.
• All temporary placements organised by {{org_field_name}} in care homes, nursing homes, or other healthcare environments.

3. Related Policies

• Recruitment Policy
• Code of Conduct
• Conflict of Interest Policy
• Equal Opportunities and Diversity Policy
• Supervision, Appraisal and Reflective Practice Policy
• Disciplinary Policy
• Whistleblowing Policy

4. Policy Statement

{{org_field_name}} recognises the valuable contribution of all staff and is committed to employing the most suitable candidates for positions regardless of personal relationships. However, in order to prevent potential conflicts of interest or risks to professional standards, additional safeguards will be applied when relatives and close associates are involved in employment or placements. The employment of relatives and close associates is permitted under this policy, provided that it does not compromise professional standards, safeguarding, confidentiality, or the integrity of the agency’s operations.

5. Definitions

For the purpose of this policy:

• A relative includes spouses, civil partners, partners (including those living together as if married), parents, children, siblings, grandparents, grandchildren, uncles, aunts, nephews, nieces, step-relatives, and in-laws.
• A close associate includes a person with whom the staff member has a close personal relationship, such as a long-term friend, cohabitee, or business partner.
• A conflict of interest arises when a staff member’s ability to act impartially is compromised or perceived to be compromised due to a personal relationship.

6. Responsibilities

Directors

The directors of {{org_field_name}} will:

• Ensure this policy is implemented and adhered to.
• Manage any recruitment, placement, or operational decisions involving relatives or close associates impartially and transparently.
• Undertake an assessment of potential conflicts of interest when a relative or close associate is employed or placed.
• Implement appropriate control measures where necessary, such as altering placement arrangements or supervisory structures.
• Ensure that declarations of interest are appropriately recorded and reviewed.

Agency Workers and Other Staff

All staff must:

• Declare any relationship with another employee, director, or client of {{org_field_name}} during the application process or immediately upon becoming aware of such a relationship.
• Cooperate fully with any measures taken to manage potential conflicts of interest.
• Maintain professional boundaries when working alongside relatives or close associates.
• Seek guidance from the directors if unsure whether a relationship constitutes a conflict of interest.

7. Recruitment of Relatives and Close Associates

The recruitment of relatives and close associates will follow the same robust and fair recruitment processes as for any other candidate. This includes:

• Open and competitive selection processes.
• Compliance with the Recruitment Policy and Equality, Diversity, and Inclusion Policy.
• Selection based on merit, competence, qualifications, and suitability for the role.
• Avoidance of favouritism or bias in shortlisting, interviewing, or appointment.

Where a director or staff member is involved in the recruitment of a relative or close associate, they must declare this immediately, and the recruitment will be managed by another director or designated senior staff to preserve objectivity.

8. Placement of Relatives and Close Associates

{{org_field_name}} acknowledges that agency staff may occasionally be placed in the same care setting as a relative or close associate. In such situations:

• Staff must inform {{org_field_name}} of the relationship prior to placement.
• A risk assessment will be carried out by the directors to determine whether the placement is appropriate, considering professional boundaries, safeguarding, and client requirements.
• Where necessary, alternative placements may be offered to prevent actual or perceived conflicts of interest.
• Staff must ensure that professional boundaries are maintained at all times when working alongside a relative or close associate.
• Information obtained during work must not be inappropriately shared between related or associated staff.

9. Supervisory Relationships

{{org_field_name}} will not normally permit a staff member to directly supervise, appraise, or discipline a relative or close associate. Where unavoidable, additional oversight will be implemented by the directors to ensure that decisions are fair and impartial.

10. Confidentiality

All staff, regardless of relationships, are bound by the agency’s Confidentiality and Data Protection Policy. Breaches of confidentiality, including inappropriate sharing of service user information, client information, or agency-sensitive information between relatives or close associates, will be treated as a serious matter and may result in disciplinary action.

11. Managing Conflicts of Interest

Where a conflict of interest is identified, the directors will:

• Assess the nature and extent of the risk.
• Determine whether the risk can be mitigated through management controls.
• Record the assessment and the agreed control measures.
• Monitor the situation through supervision, appraisal, and placement feedback.

Potential control measures may include:

• Altering placements to separate relatives or close associates.
• Changing supervisory responsibilities.
• Increasing monitoring and support.

12. Breaches of this Policy

Any failure to declare a relationship covered by this policy may result in:

• A review of the staff member’s placement or role.
• Disciplinary action in line with the Disciplinary Policy.

In serious cases, termination of employment or removal from the agency’s active staff list.

13. Equality and Non-Discrimination

{{org_field_name}} is committed to ensuring that this policy is applied fairly and without discrimination. The employment of relatives and close associates is permitted, provided that conflicts of interest are appropriately managed. No staff member will be treated less favourably due to having a relationship with another employee, director, or client.

14. Training

All staff will receive information on this policy during induction. Directors and managers will receive additional training on:

• Managing conflicts of interest.
• Ensuring fair and objective recruitment and supervision processes.
• Maintaining professional boundaries and confidentiality.

15. Monitoring and Review

The directors of {{org_field_name}} will:

• Maintain a register of declared relationships and conflicts of interest.
• Monitor the effectiveness of this policy through supervision, placement feedback, and audit.
• Review the policy annually or sooner if legislative or regulatory changes occur.
• Consult with staff and clients to continuously improve the management of conflicts of interest.

16. Policy Review

This policy will be reviewed at least annually, or earlier where:

• there is a relevant change to legislation or statutory guidance applicable to {{org_field_name}} as an employment agency or employment business;
• there is a material change to the nature of the services provided by {{org_field_name}};
• staff or client feedback indicates that revision is necessary; or
• issues are identified through audits, incidents, complaints or the operation of this policy.

Where a change to the regulatory requirements applicable to a client affects the recruitment, suitability, deployment or conduct requirements for agency workers supplied by {{org_field_name}}, the implications of that change will also be considered as part of the review.

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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.