SL57-Bribery and Fraud Prevention Policy

Registration Number: {{org_field_registration_no}}

Bribery and Fraud Prevention Policy

1. Purpose

The purpose of this policy is to set out {{org_field_name}}‘s commitment to preventing bribery and fraud within our organisation. This policy ensures compliance with the Bribery Act 2010, Fraud Act 2006, and relevant Care Quality Commission (CQC) regulations, and outlines how we mitigate risks, investigate allegations, and maintain integrity within our supported living services.

2. Scope

This policy applies to all employees, including permanent, temporary, agency staff, volunteers, contractors, and any individuals working on behalf of {{org_field_name}}. It covers all forms of bribery, fraud, and corruption that may arise within the organisation or in relation to third parties.

3. Related Policies

Good Governance Policy (SL04)
Safeguarding Adults from Abuse and Improper Treatment Policy (SL13)
Staff Conduct and Code of Ethics Policy (SL28)
Whistleblowing (Speaking Up) Policy (SL29)
Managing Service User Finances Policy (SL41)

4. Policy Statement

{{org_field_name}} is committed to a culture of honesty, integrity, and accountability. We do not tolerate bribery, fraud, or corruption in any form. We implement strong internal controls to prevent fraudulent activities and ensure compliance with legal and regulatory requirements.

5. Definitions

5.1 Bribery

Bribery is offering, giving, receiving, or soliciting something of value to influence an action or decision. This includes:

Offering cash, gifts, hospitality, or favours in exchange for preferential treatment.
Accepting or requesting bribes in return for services or advantages.
Facilitation payments (unofficial small payments to speed up processes).

5.2 Fraud

Fraud is wrongful or criminal deception intended to result in financial or personal gain. Examples include:

False claims for services or expenses.
Misuse of company funds or assets.
Providing false information for financial gain.

6. Preventative Measures

6.1 Staff Awareness and Training

All staff must complete mandatory anti-bribery and fraud training during induction and at least annually.
Training materials include case studies and best practices for identifying and reporting bribery and fraud.

6.2 Internal Controls and Risk Management

Regular financial audits and spot checks are conducted to detect any fraudulent activity.
Dual authorisation is required for approving financial transactions.
Clear segregation of duties is implemented to prevent misuse of funds.
A risk register is maintained and reviewed regularly to assess bribery and fraud risks.

6.3 Managing Gifts and Hospitality

Staff must declare all gifts and hospitality received or given, regardless of value.
Any gift or hospitality exceeding £25 must be reported and approved by {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}.
Accepting gifts or hospitality must not influence professional judgment or decisions.

6.4 Supplier and Contractor Due Diligence

Background checks are conducted on all suppliers, contractors, and third-party partners.
Contracts include anti-bribery clauses, and any violations result in contract termination.
Regular monitoring ensures ongoing compliance.

7. Reporting and Investigation

7.1 Reporting Bribery and Fraud

Staff must report any suspected bribery or fraud immediately to {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} or via the Whistleblowing Policy (SL29).
Reports can be made anonymously and will be treated confidentially.
Staff will not face retaliation for reporting concerns in good faith.

7.2 Investigation Process

All allegations will be investigated promptly by the Designated Investigation Officer.
If fraud is suspected, the matter will be reported to external authorities such as the police or the Serious Fraud Office (SFO).
Affected individuals will be informed of the outcome, and corrective actions will be taken as necessary.

8. Consequences of Non-Compliance

Disciplinary action, up to and including dismissal, for employees found guilty of bribery or fraud.
Termination of contracts with third parties engaged in corrupt practices.
Legal action including criminal prosecution where applicable.
Fines and regulatory action if the organisation fails to prevent bribery and fraud.

9. CQC Compliance

This policy aligns with the following CQC regulations:

Regulation 17: Good Governance – Implementing strong internal controls and ensuring transparency in financial management.
Regulation 13: Safeguarding Service Users from Abuse and Improper Treatment – Preventing financial abuse and exploitation.
Regulation 19: Fit and Proper Persons Employed – Ensuring staff have the integrity and suitability for their roles.

10. Policy Review

This policy will be reviewed annually or sooner if legislative changes, CQC regulations, or operational requirements necessitate amendments.

For further guidance, contact {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}, Registered Manager at {{org_field_email}}.

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.