Anti-Bribery & Corruption Policy

Why does a care provider need an anti-bribery policy?

Under the Bribery Act 2010, a company or partnership that carries on a business commits an offence if someone working for it pays a bribe to win or keep its business. Its defence is to prove it had "adequate procedures" to stop bribery, and an anti-bribery and corruption policy forms part of those procedures. The Act also makes it an offence to offer, ask for or accept a bribe.

The template is written for care homes, home care and supported living, and the risks differ in each. Residents and families in care homes often offer gifts, for example at festivals or after a death. Home care staff work alone, which adds risk, and supported living staff may help people manage money and tenancies.

Gifts, the everyday risk

Gifts can be a sign of financial abuse, and regulation 13 treats theft or misuse of a person's money or property as abuse. The policy gives staff firm rules:

• politely say no to money, vouchers, valuables or anything above your small gift limit

• record each gift offered in the register, whether they take it or not

• tell the manager if the person may lack capacity or seems under pressure

• never borrow from, lend to or sell to a person who uses the service

• never agree to be named in a person's will, or act as their executor or attorney

Small gifts, such as chocolates for a team, are fine with the manager's approval. Giving can be part of a person's culture or faith, so staff turn gifts down kindly and explain why. The service may suggest a card or feedback instead.

What else the template covers

It bans facilitation payments (small payments to speed up a routine action), paying anyone for referrals unless a lawful contract openly allows it, and accepting gifts or hospitality while a tender or contract decision is under way. Staff declare conflicts of interest, such as a family link with a supplier or landlord, and stay out of decisions where they have one. Breaking the policy is gross misconduct.

Before you finalise it

Set your own gift value limit and name the person who keeps the gifts and hospitality register. Check the Bribery Act guidance for commercial organisations before you finalise your procedures.

Any concern about a person's money or property also follows the Safeguarding Policy & Procedure. Staff can report bribery anonymously through the Whistleblowing & Speak Up Policy. New starters should know the rules from induction, so add this policy to your Staff Induction Record & Checklist.