Fraud, Bribery and Anti-Corruption Policy

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 Organisation: Disability Connect Mentoring Limited (trading as Disability Connect), company number 13268728
Policy owner: Steven Jones, Director
Approved by: Board of directors on 17/10/2026
Version: 1.0
Next review: October 2027

1. Our commitment

Disability Connect has zero tolerance of fraud, bribery and corruption. We occasionally receive public money, including government grants, and we must make sure every pound is spent as agreed. This policy explains how we prevent, detect and respond to fraud, bribery and corruption.

It applies to directors, staff, volunteers, contractors, mentors and partners who act for us or receive money from us.

2. What we mean

Fraud: dishonestly making a false statement, hiding information or abusing a position to make a gain or cause a loss (Fraud Act 2006). Examples: a false grant claim, claiming payment for a session that did not happen, or changing bank details to divert a payment.

Bribery: offering, giving, asking for or accepting anything of value to influence someone to act improperly (Bribery Act 2010). It is also an offence for an organisation to fail to prevent bribery by people acting for it.

Corruption: abusing a position of trust for private gain, including favouring friends or family when awarding work.

Theft: taking money or property that belongs to Disability Connect or to someone else.

The “failure to prevent fraud” offence, in force since 1 September 2025, applies only to large organisations, so we are not in scope. We still follow the six principles in the government’s guidance, because they are good practice: leadership commitment, risk assessment, proportionate controls, checks on the people we work with, communication and training, and monitoring and review.

3. Responsibilities

The board is responsible for this policy and for making sure our controls work.

Steven Jones, Director, is our Fraud Lead. Because we have a single director, if a concern involves Steven, please report it directly to one of these:

• the funder, if the concern involves grant money
• Report Fraud, the national fraud reporting service, on 0300 123 2040
• the police, if a crime is happening now or someone is at risk.

You can get free, confidential advice first from Protect, the whistleblowing charity, on 020 3117 2520.

Our Whistleblowing Policy explains how you are protected if you raise a concern. Everyone must follow our financial controls and report any suspicion straight away.

4. Our main fraud risks and how we control them

Claiming grant money for activity that did not happen: every claim is backed by evidence such as attendance logs, payroll records and invoices. 

Paying for mentoring sessions that did not take place: mentors are paid only for sessions confirmed by both the mentor and the mentee, and logged by us.

Payments diverted by changed bank details, including email scams: we confirm any change of bank details by phone, using a number we already hold, before making a payment.

One person controlling payments: payments over £500 are checked against an invoice and the approved budget.

Claiming the same cost from two funders: each project’s spending is recorded and coded separately, so it cannot be claimed twice.

Favouring connected people or businesses: we get at least two quotes for anything over £1,000, and conflicts of interest are declared (see our Conflicts of Interest Policy).

Misuse of grant money: each grant is held in a separate bank account and reconciled every month.

Overcharging staff time to a grant: staff paid from a grant keep timesheets, approved every month.

5. Gifts and hospitality

• Never offer or accept cash or cash equivalents, such as vouchers.
• You may accept small gifts or hospitality worth up to £25, such as refreshments at a meeting.
• Record anything worth more than £25 in our gifts and hospitality register. Get approval before accepting anything worth more than £100.
• Never accept anything from someone who is bidding for work with us, or whose interests we are deciding.
• We do not make political donations or “facilitation payments” (small unofficial payments to speed up routine processes).

6. Reporting a concern

If you suspect fraud, bribery or corruption:

• report it straight away to Steven Jones or, if it involves Steven, to one of the contacts in section 3
• do not investigate it yourself or confront anyone
• keep any evidence safe.

You can also use our Whistleblowing Policy, which protects people who raise genuine concerns.

7. How we respond

1. The Fraud Lead records the concern and acts to stop any further loss.
2. We investigate fairly and confidentially, getting independent help if needed.
3. We report suspected crimes to the police, or to Report Fraud, the national fraud reporting service for England, Wales and Northern Ireland (reportfraud.police.uk, 0300 123 2040).
4. We tell any funder affected, including the Department for Work and Pensions (DWP), promptly and as our grant agreement requires.
5. We try to recover any money lost, and take disciplinary or contractual action where appropriate.
6. We review what happened and improve our controls.

8. Training and review

Everyone who handles money for us is briefed on this policy when they start. The board reviews this policy every year.

This document is available in other formats, including Easy Read and large print. 

Contact info@disabilityconnect.org.uk.