CuraFlow Policies
DC-A13CQCSection A · Governance, Leadership and Business

Anti Bribery and Conflicts of Interest policy

For CQC-registered domiciliary care services · version 1.0 · last reviewed 1 June 2026

Bribery law and the procedures a provider is expected to have in place. Gifts, hospitality and donations are covered, along with declaring and managing conflicts of interest, risks arising in procurement, supplier relationships and referrals, facilitation payments and political donations, and how concerns are raised and what follows.

What this policy covers

  • The law: bribery, corruption and failing to prevent it
  • Our anti-bribery approach: adequate procedures
  • Gifts, hospitality and donations
  • Conflicts of interest
  • Procurement, suppliers and referrals
  • Facilitation payments and political donations
  • Raising concerns and consequences
  • Registered provider and nominated individual
  • Annex a — gifts, hospitality and conflicts decision guide
  • Annex b — declaration and register form

Regulations and guidance it supports

Supports the fundamental standards at Regulations 13, 17 and 20 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.

  • Bribery Act 2010
  • Economic Crime and Corporate Transparency Act 2023
  • Fraud Act 2006
  • Companies Act 2006
  • Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
  • Care Act 2014
  • Equality Act 2010
  • Human Rights Act 1998

Common questions

Is the anti bribery and conflicts of interest policy CQC-aligned?
Yes. It is written and reviewed by practising UK compliance consultants against current CQC expectations, and supports the fundamental standards at Regulations 13, 17 and 20. It is a controlled starting-point document that you adapt to your own service — you remain the accountable provider.
Can I download and edit this policy?
Yes. It downloads as Word (.docx) or PDF with your company name, registered manager, CQC ID and address already filled in on the cover page and throughout the document. The Word version is fully editable.
Can I buy this policy on its own?
Policies are sold as a complete library rather than individually, because CQC expects a coherent set that cross-references properly — a single policy in isolation creates gaps. The domiciliary care library contains 141 policies and can be bought outright as a one-off purchase and kept permanently.
How often is it reviewed?
The library is re-reviewed every six months and after any material regulatory change. This policy was last reviewed 1 June 2026, and is at version 1.0. Updates reach you automatically, so downloads always reflect the current version.

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