Search Jobs Contact Us Register

Anti-Bribery, Gifts and Wills

Anti-Bribery, Gifts and Wills

Version Control Sheet
STATUS: Approved
COMMENTS: To be reviewed 01/09/2022



The purpose of this policy is to set out the rules that must be followed by everyone in the Company so as to ensure that all dealings with Clients, Suppliers etc. are always appropriate, honest and above-board.



The Company’s reputation is based on a number of factors, with quality of service, integrity, honesty and professionalism being of the highest importance. It follows that any act which might cast doubts about the Company’s behaviour in relation to these factors is to be deplored.

Procedure and Guidance
Unacceptable behaviour

Bribery is the accepting of gifts, money, hospitality or other favours in return for providing something of value to the briber.

The following behaviour is unacceptable:

• accepting any financial or other reward from any person in return for providing some favour
• requesting a financial or other reward from any person in return for providing some favour
• offering any financial or other reward from any person in return for providing some favour

Business gifts

From time to time, Clients, suppliers or other persons might offer a gift to a temporary worker. This could be a small item, or something of considerable value. All gifts, however small, must be reported and recorded. No gifts may be accepted. If a gift is offered and then refused because of its value, this must be reported. Where refusal might cause offence (for example the gift is offered as appreciation for an exceptional quality of care and service), then this should be discussed with the temporary worker’s manager and appropriate action decided upon.


From time to time, customers, suppliers or other persons might invite a temporary worker to a hospitality event. All such invitations must be reported, and permission must be given before an employee accepts any invitation.


The company supports the ICG Foundation.


Attempts to bribe

Any temporary worker who is concerned that he or she is potentially being bribed should report this matter immediately.

Clients’ Wills and Bequests

Temporary workers are expressly forbidden to become involved in assisting in the making of or benefiting from Clients’ wills. As such care workers and other employees of the Company must refuse to offer any advice whatsoever, either to the Client, or anyone connected with the Client, on the making of wills, or their contents.

As with gifts, however, a sensible approach must be adopted where refusal may offend, and if a bequest is made to a care worker, or some other temporary worker, without his or her prior knowledge, then this must be declared. If, after investigation, the Company is satisfied that nothing untoward has taken place, then the bequest may be accepted. Where a monetary bequest is made to the Company then such monies may be used for the benefit of all temporary worker.

Disciplinary action

Any temporary worker found to have offered or accepted a bribe or is believed to have committed an act in contravention of any of the proper standards of conduct outlined in this policy will face disciplinary action which could include dismissal for gross misconduct.

Raising concerns

If an temporary worker is concerned that acts of bribery are occurring in the Company, they should inform their manager in the first instance. If this course of action is inappropriate, the temporary worker should inform the Head of Nursing for ICG Medical Ltd.


KLOE Reference for this Policy: Safe | Well-Led

Regulations directly linked to this Policy: Regulation 13: Safeguarding service users from abuse and improper treatment

Regulation(s) relevant to this Policy: Regulation 18: Staffing


Next Review