Anti-bribery and anti-fraud policy

Our position

Changing Lanes Limited does not tolerate bribery, fraud or any other dishonesty, by anyone working for or with us. This policy applies to directors, staff, contractors, subcontractors and anyone acting on our behalf. It supports compliance with the Bribery Act 2010, the Fraud Act 2006 and the Economic Crime and Corporate Transparency Act 2023.

Bribery

You must not offer, promise, give, ask for or accept any payment, gift, hospitality or advantage intended to influence a decision improperly — including from or to employers, funding bodies, lead providers, suppliers or public officials. Facilitation payments are not allowed. Gifts and hospitality above [to be confirmed: gifts and hospitality register threshold] must be declared and recorded; cash gifts are never allowed.

Funding fraud

Public funding must only be claimed for genuine, eligible learners and genuine delivery. We never:

• offer or give learners money, vouchers, gifts or other inducements to enrol, to stay on a course or to claim an outcome;
• create, alter, back-date or reuse evidence (for example attendance, identity, residency, benefit or outcome evidence), or sign for someone else;
• claim for learners who are ineligible, did not attend, or did not achieve the milestone claimed;
• charge a learner for any element of a Skills Bootcamp, or charge twice for the same thing;
• misreport an employment outcome.

The platform supports this: eligibility is decided by a person, evidence is verified by staff, milestone evidence is prepared by one person and approved by another, nothing is submitted to a funder automatically, and every step is audited.

Other fraud

Including false invoices or expenses, payroll fraud, misuse of company payment cards, false statements to customers or employers, and misuse of learner or employer information for personal gain.

Reasonable procedures

The "failure to prevent fraud" offence (in force from 1 September 2025) applies to large organisations; we do not currently meet its size thresholds but we follow the government's six principles as good practice: top-level commitment, risk assessment, proportionate procedures, due diligence on partners and subcontractors, communication and training, and monitoring and review. We also follow the "adequate procedures" principles under section 7 of the Bribery Act 2010.

Reporting

Report suspected bribery or fraud to the director responsible ([to be confirmed: director responsible for policy sign-off]) or through the Whistleblowing policy. We investigate every report, take disciplinary action where appropriate, report to the police or Action Fraud, and tell the funding body or lead provider promptly where public funds may be affected, as our funding contracts require.

Review

The directors review fraud and bribery risks and this policy every year.

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