Let us know if you agree to cookies

We use cookies to give you the best online experience. Please let us know if you agree to all cookies.

Skip to main navigation

Skip to main content

Anti-fraud policy

Our anti-fraud policy sets out our policy with regards to fraud and other forms of dishonesty.

Anti-fraud, bribery and corruption policy

Last updated: April 2021

Why do we need this policy?

The purpose of this policy is to provide definitions of fraud, bribery and corruption and responsibilities for reporting in the event of suspected, attempted or actual fraud, bribery or irregularity.

Who needs to follow this policy and why?

We require our people, board and our partners to act honestly and with integrity at all times and to report all reasonable suspicions of fraud, bribery or corruption.

What’s our policy and how will we implement it?

We have adopted several procedures to minimise the risk of fraud, bribery and corruption:

  • The gifts and hospitality policy provides guidance as to how any gifts or hospitality offered to employees, partners and board members should be dealt with and reported.
  • Any gifts or hospitality offered, according to the policy guidance, should be recorded on the gifts and hospitality register whether accepted or declined.
  • All board members are required to complete an annual declaration of interests, hospitality and gifts; all executive directors are required to complete the register of gifts and hospitality annually.
  • Any individual, organisation or other supplier working with, or on behalf of us will be selected via a transparent and competitive selection method.
  • We are committed to carrying out due diligence on third parties who work with or on behalf of us prior to entering contracts.
  • Our people and partners complete mandatory training

Reporting a concern

Individuals should immediately report any suspected or actual instances of fraud, bribery or corruption. This includes offers to pay bribes, solicitation of bribes and demands to make facilitation payments. Failure to report could result in disciplinary action. Reports should be made to the head of finance and commercial (or the executive director for people and business support if the concern relates to the head of finance and commercial).

If individuals are not comfortable reporting their concerns to these people, they should contact the CEO. In the event of a report being made to the head of finance and commercial, they will inform the executive director for people and business support who will inform the CEO within 48 hours. They will decide the appropriate course of action to be taken, including informing the chair of the board and the chair of the audit risk and assurance committee of material items.


We will take all reports of actual or suspected fraud, bribery and corruption seriously, and investigate proportionately and appropriately as set out in this policy. The resulting actions may include disciplinary procedures, dismissal and criminal prosecution.

Referral to external agencies

The chief executive will decide at what stage a case should be reported to the police or other external agency such as the Serious Fraud Office (SFO). Certain offices carry criminal liability for individuals concerned and sanctions include significant fines and/or imprisonment.

Recovery action

We will make all efforts to recover any gain, asset and/or benefit which has been obtained through a fraudulent act.

Where loss has been identified, legal advice may be obtained about the need to trace and/or freeze a person’s assets through the court, pending conclusion of the investigation. Legal advice will also be obtained relating to the recovery of losses through the civil and criminal courts or deducting losses from any salary payments.

During an investigation, an individual may offer to repay the amount that has been obtained improperly. The investigating officer will neither solicit nor accept such an offer as it may be construed as having been obtained under duress. Any offer should be recorded and referred to the executive director of people and business support.

Reporting to our chair and chair of audit, risk and assurance committee

We will keep our chair and chair of ARAC informed of the progress of any investigations relating to impropriety including:

  • a description of the incident, including the value of any loss, the people involved, and the means of perpetrating the fraud
  • the measures taken to prevent a recurrence
  • any action needed to strengthen future responses to fraud, with a follow-up report on whether the actions have been taken.

Roles and responsibilities

4.1 Our people, board and partners

Everyone working with and for us are expected always to be aware of the possibility that fraud, bribery, corruption and/or theft may exist in the workplace and should:

  • Act with integrity and promptly share any concerns they may have,
  • Refuse to give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
  • Not give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;
  • Not accept a payment, gift or hospitality from a third party, knowing or suspecting it is offered with the expectation that it we will provide a business advantage for them or anyone else in return;
  • Not accept hospitality from a third party that is unduly lavish or extravagant.
  • Not threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy
  • Always ask for advice and guidance if they are uncertain about anything

Specific risk mitigation measures

To manage the exposure to bribery and corruption, everyone should comply with our policy on gifts and hospitality. No payment (whether it be a facilitation payment or otherwise), gift or service, is to be made to or received without prior notification to (and the approval of) the head of finance and commercial.

Conflicts of interest are known to increase the risk of fraud. Therefore, all staff who have an interest in an actual or potential supplier (whether personally, or through family members, close friends or associates) must report that conflict of interest to the head of finance and commercial.

Related policies, procedures and information sources

Internal whistleblowing policy

Data protection, equality and diversity

A data protection impact assessment (DPIA) and equality impact assessment (EIA) have been completed for this policy.


If you have a query about this policy, please contact Richard Simpson, Head of Finance and Commercial.



Fraud describes several activities including theft, false accounting, embezzlement, bribery and deception. The Fraud Act 2006 defines three class of fraud:

  1. False representation: a person commits fraud by intentionally and dishonestly making a false representation. A false representation includes intentionally giving a misleading or untrue statement.
  2. Failing to disclose information: a person commits a fraud if they dishonestly fail to disclose information.
  3. Abuse of position: a person commits a fraud if they dishonestly abuse their position.

To have committed a fraud a person must have acted dishonestly, and with the intent to:

  • make a gain for themselves or anyone else and/or
  • cause loss to anyone else, or expose anyone else to a risk of loss


Corruption is the misuse of power for personal gain.

The Bribery Act 2010

The Bribery Act 2010 requires our people, Board and our partners to not either directly or indirectly:

  • Offer, give, solicit or accept any bribe, either in cash or any other form of reward, to or from any person or company, wherever they are located and whether they are a public official or body, or private person or company
  • Give or retain any commercial, contractual or regulatory advantage through unethical or illegal means when conducting business on our behalf.


Last reviewed: April 2021

Next review date: April 2022

Policy owner: Tracy Watterson, Assistant Director – People and Business Support

Policy reference: POL_FRA_004

Version: 2.1

If you require a PDF version of this policy, please contact us.

Back to top