Healing Process policy suite
Ethical Business, Anti-Bribery and Modern Slavery Policy
1. Purpose
To conduct Healing Process business with integrity, prevent bribery, corruption, fraud, exploitation and modern slavery, and make procurement and partnership decisions consistent with patient trust and public-sector expectations.
2. Scope and status
This policy applies to directors, employees, contractors, agents, partners, suppliers, gifts, hospitality, procurement, tenders, grants, pilots, donations, sponsorship and international activity.
Core supplier and product policy
3. Policy principles
- Bribery, kickbacks, facilitation payments, fraud, coercion and exploitation are prohibited.
- No commercial benefit justifies misleading an NHS body, patient, regulator, investor or research participant about evidence, approval, conflicts or product status.
- People may raise concerns without retaliation and the company will investigate proportionately.
- Supply-chain standards should reflect labour, human-rights, environmental and ethical risks as well as price and technology.
4. Mandatory requirements
- Conduct risk-based due diligence on customers, partners, agents and suppliers, including ownership, sanctions, conflicts, adverse information and labour risk where relevant.
- Maintain registers for gifts, hospitality, conflicts, outside interests, donations, sponsorship and procurement decisions.
- Prohibit payments or benefits intended to influence a decision improperly, including access to pilots, favourable evidence, procurement or clinical endorsement.
- Require transparent, fair tender and approval processes with separation of duties and documented evaluation.
- Include anti-bribery, fraud, modern-slavery, audit and termination terms in risk-relevant contracts.
- Do not use patient stories, NHS marks or professional endorsements without valid permission and accurate context.
- Assess modern-slavery and labour risks in relevant supply chains and take proportionate prevention and remediation action.
- Train risk-relevant workers and require immediate reporting of solicitation, suspected fraud or coercive practice.
5. Procedure and escalation
- Conflicts are declared before participation in a decision and managed through recusal, oversight or another documented control.
- Suspicious proposals, payments or supplier conduct are paused and escalated to Compliance; evidence is preserved and external reporting considered.
- Confirmed misconduct leads to corrective, disciplinary, contractual, recovery and reporting action as appropriate.
- Annual statements or disclosures are produced where legal or contractual thresholds apply and are based on evidence rather than generic wording.
6. Roles and responsibilities
Board
sets ethical culture and oversees material cases.
Compliance Lead
maintains controls, registers, due diligence and investigations.
Procurement/Finance
apply separation, verification and payment controls.
Managers/workers
declare conflicts and reject/report improper conduct.
Suppliers/partners
meet contractual ethical expectations.
7. Records, confidentiality and retention
Keep risk assessments, due diligence, registers, approvals, tenders, invoices, training, concerns, investigations, decisions, remediation and statements for the required period.
Records created under this policy must be accurate, attributable, access-controlled and linked to the applicable retention schedule. Where a provider is the controller or authoritative record holder, its documented instructions and legal duties apply.
8. Monitoring, assurance and review
Review annually and after material legal, market or incident change. Monitor declarations, overdue due diligence, high-risk suppliers, exceptions, allegations, training and remediation.
Material non-compliance is reported through the relevant clinical-safety, patient-safety, data, security, safeguarding, HR, contractual or whistleblowing route. Corrective actions receive an owner, target date and effectiveness check.
9. Training and communication
The policy owner identifies which roles require awareness, operational or specialist training. Training is accessible, version-controlled, role-specific and refreshed after material change or evidence that understanding is inadequate. Providers communicate local procedures and contact routes before users are granted access.
10. Related documents
11. Approval record
| Role | Name | Decision/date |
|---|---|---|
| Policy owner | To be completed | Draft pending approval |
| Clinical/technical specialist | To be completed | Draft pending approval |
| Board or delegated committee | To be completed | Draft pending approval |