COUNTER FRAUD POLICY
Capital Staffing Services Ltd
Introduction
This ANTI-BRIBERY AND CORRUPTION POLICY relates to actions and activities during the financial year 05 April 2023 to 04 April 2024.
The statement sets down Capital Staffing Services Ltd commitment to preventing Bribery and Corruption in our business activities and the steps we have put in place with the aim of ensuring that there is no bribery or corruption in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon
them.
Organisational structure and supply chains
This statement covers the business activities of Capital Staffing Services Ltd which are a s follows:
CAPITAL STAFFING SERVICES LTD UNDER COMPANY NUMBER 04257718 ON THE FRAMEWORK OF RM6161 AND CQC REGISTERED ACTS AS A RECRUITING AGENCY FOR TEMPORARY RECRUITMENT OF CLINICAL AND HEALTHCARE STAFF FOR AL JOB ROLES AND BANDS ACROSS THE UK, APPROVED BY NHS ENG.
The Company currently operates in the following countries:
United Kingdom territories.
Policy Statement: Capital Staffing Services is committed to preventing, detecting, and addressing fraud in all aspects of our business operations. We have zero tolerance for any form of fraud, including but not limited to, theft, embezzlement, misappropriation of assets, falsification of records, corruption, bribery, kickbacks, collusion, and other fraudulent activities. We are committed to maintaining a strong internal control environment and promoting a culture of honesty, integrity, and accountability among our employees, contractors, and stakeholders.
Compliance with Laws: Capital Staffing Services will comply with all applicable laws, regulations, and industry standards related to fraud prevention and detection.
This includes but is not limited to, relevant fraud-related laws and regulations in the jurisdictions where we operate, such as the Fraud Act 2006 in the UK, and other applicable laws related to financial and accounting practices.
Fraud Prevention Measures: Capital Staffing Services will implement robust fraud prevention measures, including but not limited to, the following:
a. Segregation of Duties: We will ensure that appropriate segregation of duties is maintained in all key financial and operational processes to prevent any single individual from having excessive control or authority over financial transactions.
b. Internal Controls: We will establish and maintain effective internal controls to ensure that all financial transactions are authorized, recorded, and reported accurately and timely, and that assets are safeguarded against fraud and misappropriation.
c. Risk Assessment: We will conduct regular risk assessments to identify and assess potential fraud risks in our business operations, and implement appropriate controls and mitigation measures to minimize these risks.
d. Code ofConduct: We will have a comprehensive code of conduct that sets clear expectations for our employees, contractors, and stakeholders regarding their conduct and ethical responsibilities, including the prohibition of fraud and other fraudulent activities.
e. Employee Screening: We wil conduct thorough background checks and screening of all employees and contractors who have access to financial transactions or sensitive information to mitigate the risk of insider fraud.
f. Whistleblowing: We will provide a confidential and accessible whistleblowing mechanism for employees, contractors, and stakeholders to report any suspected fraud or fraudulent activities, and we will take appropriate actions to investigate and address such reports in a timely and confidential manner.
Fraud Detection and Investigation: Capital Staffing Services will implement measures to detect and investigate suspected fraudulent activities, including but not limited to:
a. Monitoring and Data Analysis: We will use data analytics and other monitoring techniques to identify potential fraud indicators, such as unusual patterns or trends in financial transactions, discrepancies in records, or other anomalies.
b. Internal Audits: We will conduct regular internal audits of our financial and operational processes to assess compliance with internal controls and detect any potential fraud or irregularities.
c. Investigation and Reporting: We will investigate all reported cases of suspected fraud promptly and thoroughly, and we will take appropriate actions to address confirmed fraud cases, including reporting to relevant authorities, recovering assets, and implementing corrective measures to prevent future occurrences.
Employee Responsibilities: Al employees and contractors of Capital Staffing Services are responsible for preventing and detecting fraud in their respective roles. This includes but is not limited to:
a. Compliance with Policies and Procedures: Employees and contractors must
comply with all relevant policies, procedures, and internal controls related to fraud prevention and detection, including but not limited to thecode of conduct, financial policies, and internal control measures.
b. Reporting Suspected Fraud: Employees and contractors must report any
suspected fraud or fraudulent activities promptly through the established reporting
channels, including the confidential whistleblowing mechanism, and cooperate in any investigations related to fraud.
c. Ethical Conduct: Employees and contractors must maintain high standards of ethical conduct in their business activities, and avoid any behavior that may constitute.
ANTI-BRIBERY AND CORRUPTION POLICY
Introduction
This ANTI-BRIBERY AND CORRUPTION POLICY relates to actions and activities during the financial year 05 April 2023 to 04 April 2024.
The statement sets down Capital Staffing Services Ltd commitment to preventing Bribery and Corruption in our business activities and the steps we have put in place with the aim of ensuring that there is no bribery or corruption in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
Organisational structure and supply chains
This statement covers the business activities of Capital Staffing Services Ltd which are as follows:
CAPITAL STAFFING SERVICES LTD UNDER COMPANY NUMBER 04257718 ON THE FRAMEWORK OF RM6161 AND CQC REGISTERED ACTS AS A RECRUITING AGENCY FOR TEMPORARY RECRUITMENT OFCLINICAL AND HEALTHCARE STAFF FOR ALL JOB ROLES AND BANDS ACROSS THE UK,
APPROVED BY NHS ENG.
The Company currently operates in the following countries:
United Kingdom territories.
Policy Statement: Capital Staffing Services is committed to conducting its business with integrity and in compliance with all applicable laws and regulations related to anti-bribery and corruption. We prohibit all forms of bribery and corruption, including but not limited to, offering, promising, giving, or accepting
bribes in any form, whether directly or indirectly, to or from any person or entity, including public officials, in order to obtain or retain business or gain any improper advantage.
Compliance with Laws: Capital Staffing Services will comply with all applicable anti-bribery and corruption laws and regulations, including but not limited to the UK
Bribery Act 2010, and other relevant laws in jurisdictions where we operate. We will also comply with any applicable industry standards and guidelines related to anti-bribery and corruption.
Prohibited Activities: Capital Staffing Services prohibits all forms of bribery and corruption, including but not limited to, the following activities:
a. Offering, promising, giving, or accepting bribes, kickbacks, or any other improper payments or favors, whether in cash or in kind, to or from any person or entity, including public officials, to influence business decisions or gain any improper advantage.
b. Using intermediaries, agents, or third parties to pay bribes or engage in other corrupt activities on our behalf.
c. Making or receiving facilitation payments, which are small payments made to expedite routine government actions, even if they are considered customary or
acceptable in a particular country or industry.
d. Engaging in any other activity that may constitute bribery, corruption, or any form of unethical or illegal behavior.
Due Diligence: Capital Staffing Services will conduct due diligence on our employees, agents, intermediaries, contractors, and other business partners to ensure their compliance with anti-bribery and corruption laws and standards. This may include verifying their business practices, financial transactions, and relationships with public officials or other third parties.
Gifts and Hospitality: Capital Staffing Services acknowledges that the provision and receipt of gifts, hospitality, and entertainment may be a common business practice, but it can also be used as a means of bribery or corruption. Therefore, all gifts, hospitality, and entertainment offered or received in connection with our business activities must be reasonable, proportionate, and in compliance with applicable laws and regulations, and should not be offered or received with the intent to influence or obtain any improper advantage.
Record Keeping: Capital Staffing Services will maintain accurate and transparent records of all financial transactions, including payments, receipts, and other financial records, related to our business activities, in accordance with applicable laws and regulations. Al records must be complete, accurate, and kept for the required retention period.
Reporting and Whistleblowing: Capital Staffing Services encourages all employees, contractors, and stakeholders to report any concerns or suspicions of bribery or corruption through our established reporting channels. We will investigate all reported cases promptly and take appropriate actions to address any confirmed violations. We will also protect whistleblowers from retaliation in accordance with applicable laws and our internal policies.
Training and Awareness: Capital Staffing Services will provide training and awareness programs to our employees, agents, intermediaries, and other relevant parties to raise awareness about anti-bribery and corruption laws, policies, and procedures, and to ensure they understand their responsibilities in preventing and detecting bribery and corruption in our business activities.
Monitoring and Auditing: Capital Staffing Services will regularly monitor and audit our financial transactions, business practices, and internal controls to assess compliance with our anti-bribery and corruption policies and procedures. This may include conducting internal audits, site visits, inspections, and third-party audits to verify compliance.
