Insert Name of Care Home Here If You Wish

Insert Name of Care Home here if you wish

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Policy Title / Prevention of Bribery / Date Implemented
or Date of Last Review
Policy Reference / Date of Next Review

Policy

Bribery undermines democracy and the rule of law and poses very serious threats to sustained economic progress in developing and emerging economies and to the proper operation of free markets more generally. The Bribery Act 2010 is intended to respond to these threats and to the extremely broad range of ways that bribery can be committed. It does this by providing robust offences, enhancing sentencing powers for the courts (raising the maximum sentence for bribery committed by an individual from 7 to 10 years imprisonment) and wide jurisdictional powers.

The Act contains two general offences covering the offering, promising or giving of a bribe (active bribery) and the requesting, agreeing to receive or accepting of a bribe (passive bribery). It also sets out two further offences which specifically address commercial bribery. Section 6 of the Act creates an offence relating to bribery of a foreign public official in order to retain or obtain business or an advantage in the conduct of business and section 7 creates a new form of corporate liability for failing to prevent bribery on behalf of a commercial organisation.

HM UK Government Guidance 2011

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This policy statement is to be reviewed annually by the Managing Director

Procedure

Introduction

The Home operates entirely within the United Kingdom and does not participate in foreign markets. As such, it considers that the risk that bribery forms any active part in the day to day operations of the business is minimal.

Nevertheless it believes that having a formal policy and adequate proportionate procedures in place are essential safeguards for the deterrence of bribery, and serve to inform all who are connected with the Home of the policy of zero tolerance.

Ongoing Risk Assessment/Due Diligence

The Home will ensure that the subject of bribery is tabled at board/operational meetings on at least a quarterly basis so that existing risks, and any new risks which may have emerged, are adequately discussed, and new measures implemented as necessary. References are taken up for all new employees, and the majority of staff are subject to DBS checks at the enhanced level. These checks ensure that any previous misdemeanours come to light and confirmed employment is assessed on the basis of such knowledge.

Accurate and Transparent Financial Reporting

The Home’s financial records are kept and audited in accordance with standard accounting principles and are transparent. Payments and receipts are identified accurately and identify the cost centre or income stream to which they relate.

Facilitation payments

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