Anti-Bribery and Corruption Policy

The Occupational Therapy Service is committed to conducting business ethically, transparently, and with integrity. We have a zero-tolerance approach to bribery and corruption in all forms and are committed to complying with the UK Bribery Act 2010.

This policy sets out our responsibilities, as well as the responsibilities of those working for or with us, in preventing bribery and corruption.

Our commitment

We are committed to:

• Acting honestly and with integrity in all business relationships
• Never offering, giving, requesting, or accepting bribes
• Complying with all applicable laws and regulations relating to bribery and corruption
• Maintaining high standards of professional and ethical conduct

What is bribery?

A bribe is any financial or other advantage offered, promised, given, requested, or accepted with the intention of inducing or rewarding improper performance of a function or activity.

Bribery can take many forms, including:

• Gifts, hospitality, or entertainment
• Payments, commissions, or fees
• Favourable treatment or preferential services
• Any other inducement intended to gain an unfair advantage

Gifts and hospitality

Reasonable and proportionate hospitality or gifts given in the normal course of business may be acceptable, provided they:

• Are not intended to influence a business decision
• Are of modest value
• Are appropriate and transparent
• Comply with applicable laws and professional standards

Gifts or hospitality must never be offered or accepted if they could be perceived as influencing professional judgment or decision-making

Responsibilities

This policy applies to:

• Employees
• Contractors and consultants
• Temporary staff
• Suppliers and business partners

Everyone working for, or on behalf of The Occupational Therapy Service, is responsible for preventing, detecting, and reporting bribery and corruption.

Reporting concerns

Any concerns about suspected bribery or corruption should be reported promptly. All reports will be taken seriously, investigated appropriately, and handled confidentially where possible. No one will suffer any disadvantage for raising a genuine concern in good faith.

Beaches of this policy

Any breach of this policy may result in disciplinary action and where appropriate, legal action. Breaches by suppliers or partners may result in termination of contracts or business relationships.

Review of this policy

This policy will be reviewed regularly and updated as necessary to ensure ongoing compliance with legal and regulatory requirements.

Last Updated 13 February 2026