S163. Safeguarding: Counter Fraud and Security
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S163. Safeguarding: Counter Fraud and Security Policy
Policy Statement
This policy describes the measures taken by {{org_field_name}} to prevent acts of fraud, bribery and corruption and to respond to such acts where there are grounds for suspecting or there is evidence that such acts have occurred.
It is written in line with national guidance, which requires organisations administering public funds or which provide a public service to make sure that they:
- account fully for the use of the money (or items provided from public funds) to which they have been entrusted
- apply high standards of honesty and integrity at all times in the use of the money or items provided
- are open and transparent in how they make use of any public funds or items purchased from public funds.
Registered care services must always make sure that they:
- employ only people of good character at all levels of their organisation
- provide safe care and treatment at all times
- keep the people using their services safe from abuse and neglect, which includes being safe from financial abuse.
This policy should therefore be applied in relation to other safeguarding policies
Definitions
The service accepts the following definitions, which are relevant to this policy.
Fraud means any deliberate intent by anyone to deprive our organisation of money or goods through the production of false records or documents including false identities.
Examples would include:
- submission of false invoices
- submission of inflated time records or expenses claims
- the use of orders to obtain goods for personal use
- accessing and exploiting service users’ personal funds for personal gain.
Bribery occurs where someone offers payments or benefits in kind to another person or persons unreasonably to obtain some advantage. Occasions where service users or their representatives might aim to secure favours from staff, through forms of bribery, are covered in the Gifts to Staff policy.
Preventing Fraud and Bribery
The service takes all necessary measures to prevent fraud and bribery by developing an open and transparent culture with which everyone can identify and subscribe. Anyone who has suspicions or evidence of fraud or bribery occurring in any aspect of the running of the service is expected to report their concerns and will be protected as a result of doing so by the service’s Whistleblowing policy.
The service recognises that it can prevent fraudulent acts by its employees by making sure that it applies all the required checks at the point of recruitment and selection and after through its supervision arrangements, as required by the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. (See Staff Recruitment and Selection policy)
It has a comprehensive system of auditing and accounting in place, which makes sure that any financial transactions involving staff are always open and above board and the business is conducted to achieve the highest standards of probity and good governance. (See Quality Assurance: Monitoring and Reviewing the Service Provision policy)
Responding to Fraudulent Acts and Bribery
Staff who are suspected of having committed fraudulent acts will be subject to the service’s disciplinary proceedings and where the evidence points to this possible criminal proceedings following a referral to the police. Staff are made aware of these possibilities in their statements of terms and conditions and contracts.
Where the fraud is financial in nature it will be subject to the procedures that are detailed in the Financial Irregularities Investigation policy. Where service users finances are involved and there are suspicions of financial abuse the service will make a referral to the local safeguarding adults authority and notify the Care Quality Commission.
Where there has been evidence that the service has committed mistakes or has not fulfilled its duty of care to protect service users from financial harm it will follow the procedures laid out in its Duty of Candour policy.
Where there is evidence that fraudulent acts have been committed by people or organisations that are external to the service, eg contractors, the service will refer the matters to the relevant authorities, including police, and seek the appropriate redress and sanctions imposed against the offenders.
Training
All staff are made aware of the raft of policies that are involved in making sure that the business of the service is carried out to the highest standards of probity and good governance and the measures that are taken to investigate and respond to any breaches of trust and misconduct involving fraud, bribery or corruption.
Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next review date: this policy is reviewed annualy (every 12 months). When needed, this policy is also updated in response to changes in legislation, regulation, best practices, or organisational changes.
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