Anti-Bribery and Anti-Corruption Policy

Policy Lead: Mrs. Tavleen Sharma - Registered Manager

Version No.: 1.0

Date of issue: February 2025

Date to be reviewed: February 2026

Introduction

VCare Consultancy Services Limited is committed to conducting its business with the highest standards of integrity, honesty, and transparency. We have a zero-tolerance approach to bribery and corruption in any form. This policy outlines our commitment to comply with the Bribery Act 2010, and to prevent, detect, and respond to any corrupt activity within our organisation or associated with our work.

Scope

This policy applies to:

• All employees (permanent, temporary, and agency)

• Directors, board members, and volunteers

• Contractors, consultants, and any third-party representatives

• Any individuals or organisations working on behalf of VCare Consultancy Services Limited

Definitions

• Bribery: Offering, giving, receiving, or soliciting of something of value (e.g. money, gifts, hospitality, favours) to influence a decision or gain an improper advantage.

• Corruption: Abuse of entrusted power for private gain, including bribery, nepotism, fraud, or collusion.

Prohibited Conduct

VCare strictly prohibits:

• Offering or accepting bribes in any form.

• Making facilitation payments or unofficial payments to secure services.

• Offering gifts or hospitality intended to influence business decisions.

• Falsifying records or concealing improper transactions.

• Engaging in conflicts of interest without proper declaration.

Responsibilities

• All staff must report any concerns about bribery or corruption.

• Managers and directors must ensure this policy is communicated, enforced, and reviewed.

• Third parties and contractors are required to comply with this policy through contractual agreement.

Gifts and Hospitality

Gifts and hospitality are only acceptable when:

• They are of low value, proportionate, and not given with the intent to influence.

• They are recorded transparently in the gifts and hospitality register.

• They are approved by a senior manager if valued above a set threshold (e.g. : 50).

Reporting and Whistleblowing

All employees are encouraged to raise concerns in good faith through our Whistleblowing Policy. Reports can be made confidentially and without fear of retaliation. VCare will investigate all reports thoroughly and take appropriate disciplinary or legal action where necessary.

Training and Awareness

All staff receive mandatory training on anti-bribery and corruption during induction and through ongoing development. Managers receive additional training on assessing risk and ensuring compliance within their teams.

Compliance and Monitoring

We conduct regular reviews and risk assessments to ensure compliance. Breaches of this policy may result in disciplinary action, including dismissal, and legal action where relevant.

Commitment from Leadership

The senior leadership of VCare Consultancy Services Limited is fully committed to this policy. We expect all staff and partners to uphold our values of honesty, accountability, and public trust.