Anti-Bribery & Corruption Policy

Policy Statement

AESN Care is committed to conducting its care and support services honestly, transparently and ethically. Bribery, corruption, fraud and improper influence are not acceptable. Decisions about people we support, employees, suppliers, commissioners and professional partners must be based on legitimate care, safety, quality and business considerations rather than improper personal benefit.

1. Introduction

AESN Care recognises that adult social care involves relationships with people we support, families, representatives, local authorities, health professionals, commissioners, suppliers and other organisations. These relationships must be managed fairly and professionally.

This policy applies to employees, managers, workers, contractors and other people acting on behalf of AESN Care, to the extent relevant to their role.

2. Purpose

The purpose of this policy is to prevent bribery and corruption, explain expected standards of conduct, provide safeguards around gifts and hospitality, identify conflicts of interest and establish routes for reporting concerns.

3. Scope

The policy applies to procurement, recruitment and employment decisions, care-related purchasing, supplier relationships, professional relationships, commissioning interactions, referrals, payments, gifts, hospitality and any other activity where an improper advantage could arise.

4. Policy Objectives

• Protect people we support and AESN Care from improper influence.
• Maintain fair and transparent decision-making.
• Prevent improper payments, gifts or benefits.
• Ensure conflicts of interest are declared and managed.
• Encourage prompt reporting and investigation of concerns.

5. Definitions

Bribery means offering, promising, giving, requesting or accepting an advantage intended to improperly influence a decision or action. Corruption includes dishonest or improper conduct for personal or organisational advantage. A conflict of interest arises where personal interests could influence, or appear to influence, professional judgement.

6. Legal and Regulatory Framework

This policy is informed by the Bribery Act 2010 and other applicable criminal, employment, financial and governance requirements. The policy should be applied alongside relevant safeguarding, financial-control and whistleblowing arrangements.

7. Roles and Responsibilities

• AESN Care Management is responsible for promoting an ethical culture and ensuring concerns are addressed.
• Managers must model appropriate conduct, manage declared conflicts and escalate suspected bribery or corruption.
• Staff must not offer or accept improper advantages and must report concerns promptly.
• Everyone acting for AESN Care must cooperate with legitimate investigations.

8. Policy Requirements / Principles

• No employee may offer, request or accept a bribe.
• Facilitation payments are prohibited unless a payment is legally required and properly authorised.
• Gifts or hospitality must never influence care, procurement, referrals, employment or other decisions.
• Cash gifts or personal financial benefits connected to an AESN Care relationship must not be accepted.
• Potential conflicts of interest must be declared to management.
• Supplier and procurement decisions should be based on legitimate requirements, value, quality, safety and suitability.
• People we support must not be placed under pressure to provide gifts, money or personal benefits to staff.

9. Procedures

Gifts and hospitality

Staff should politely decline inappropriate gifts or benefits. Where refusal could cause distress or offence, the matter should be discussed with management and recorded where appropriate. Any gift that could reasonably be perceived as influencing a decision must be declared.

Conflicts of interest

Staff should disclose relevant personal, financial or family interests that could affect professional judgement. Management will determine appropriate safeguards, which may include withdrawal from a decision.

Suspected bribery

Concerns should be reported promptly to AESN Care Management or through the Whistleblowing Policy. Where there is an immediate safeguarding or criminal risk, appropriate emergency or external reporting routes should be used.

10. Reporting and Escalation

Concerns may be raised through line management, AESN Care Management or whistleblowing arrangements. Allegations involving abuse, exploitation or risk to a person receiving care must also be considered under safeguarding procedures. Serious suspected criminal conduct may require referral to the appropriate authority.

11. Records and Documentation

Relevant declarations, reports, decisions, investigations and actions will be recorded securely and only retained for as long as required under applicable retention arrangements.

12. Training and Competence

Relevant staff will receive information or training appropriate to their responsibilities, including expectations concerning gifts, conflicts, fraud and reporting.

13. Monitoring and Compliance

AESN Care Management will monitor relevant concerns, declarations, procurement controls and learning from investigations. Monitoring arrangements will be proportionate to the service and risk.

14. Breaches / Non-Compliance

Suspected breaches will be considered promptly. Depending on the circumstances, action may include investigation, disciplinary action, safeguarding escalation, recovery of funds or referral to an external authority.

15. Equality, Diversity and Human Rights

Controls under this policy will be applied fairly and without discrimination. Decisions will respect dignity, autonomy, equality and human rights.

16. Confidentiality and Data Protection

Information about allegations and investigations will be handled confidentially and shared only where there is a lawful and appropriate reason to do so.

17. Related Policies and Procedures

• Safeguarding Policy
• Whistleblowing Policy
• Disciplinary, Dismissal & Grievance Policy
• Data Protection Policy
• Privacy Policy
• Quality Assurance Policy

18. Review and Continuous Improvement

Learning from concerns, investigations, complaints and changes in law or guidance will be used to improve controls and staff awareness.

19. Policy Review

This policy will be reviewed in accordance with the review arrangements below and updated where necessary.

Related Policies

• Whistleblowing Policy
• Safeguarding Policy
• Disciplinary, Dismissal & Grievance Policy
• Data Protection Policy
• Quality Assurance Policy

Review Arrangements

This policy will be reviewed by AESN Care Management at appropriate intervals and sooner where there is a significant change in legislation, regulation, service delivery, risk, guidance, learning from incidents or complaints, or organisational arrangements. Review findings and resulting actions will be documented.

Approval

Approved by: AESN Care Management