Guidance

Management of counter corruption in immigration removal centres and pre-departure accommodation (accessible)

Published 17 August 2026

Detention Services Order 08/2026

July 2026

Any enquiries regarding this publication should be sent to us at DSOConsultation@homeoffice.gov.uk

Document Details

Process: This Detention Services Order (DSO) sets out the responsibilities of Home Office staff and Contracted Service Providers (CSPs) relating to the management of counter corruption in an IRC and the PDA.

Implementation Date: August 2026

Review Date: August 2028

Version: 1.0

Contains Mandatory Instructions

For Action: All Home Office Immigration Enforcement staff in Detention Services (DS) and the Detention Engagement Team (DET), and Contracted Service Providers (CSPs) operating in IRCs and the PDA

For Information: Home Office responsible caseworkers

Author and Unit: Head of Incident & Counter Corruption Hub Detention Services

Owner: Head of IRC Enabling and Capabilities, Detention Services

Contact Point: Detention Services Orders Team.

Processes Affected: Home Office processes within the immigration removal estate relating to the management of counter corruption in an IRC, or PDA.

Assumptions: All staff and CSPs will have the necessary knowledge to follow these procedures.

Notes: N/A

Instruction

Purpose and scope

1. This Detention Services Order (DSO) provides guidance for all staff operating in IRCs and the PDA. It explains the definition of corruption and the obligation to report suspicions or incidents of corruption.

2. This instruction does not apply to:

• Prisons

• Non-residential short-term holding facilities (STHFs)

• Residential short-term holding facilities (RSTHFs)

• Residential holding rooms (RHRs)

• Escorting operations / escorting staff

Counter corruption arrangements for STHFs, RSTHFs and escorting operations are managed through International Returns Services Command (IRSC) processes (rather than this DSO). Where Detention Services Counter Corruption & Investigation Unit (CCIU) receives information relevant to STHFs/RSTHFs/escorting (for example via Crimestoppers), this will be shared with the relevant IRSC lead for action.

3. Two different Home Office teams operate in IRCs:

• Detention Services (DS) Compliance team (Compliance team)

• Immigration Enforcement Detention Engagement team (DET)

The Compliance Team is responsible for all on-site commercial and contract monitoring work. The DETs interact face-to-face in IRCs with detained individuals on behalf of responsible officers. They focus on communicating and engaging with people detained at IRCs, serving paperwork on behalf of responsible case owners and helping them to understand their cases and detention.

There are no DETs at RSTHFs, or the Gatwick PDA. Some of the functions which are the responsibility of the DET in IRCs, are instead carried out by the contracted service provider and overseen by the International and Returns Services (IRS) Escorting Operations Team (Escorting Ops) in RSTHFs. In the Gatwick PDA, the role of detained individual engagement is covered by the local Compliance team.

4. References to “centre” in this document cover IRCs and the PDA.

5. For this DSO, ‘staff’ or ‘public official’ means any individual employed by the Home Office, a CSP or a healthcare provider, or any volunteer providing services within an IRC or the PDA.

6. CSP staff are not directly employed by a public authority; however, when operating within the immigration removal estate, they perform functions on behalf of a public authority. In doing so, they are subject to the legal framework governing the exercise of public functions and may be liable to prosecution for the common law offence of Misconduct in Public Office in England, Wales and Northern Ireland, or Wilful Neglect of Duty in Scotland.

Definitions

7. For this guidance and for the purpose of investigations, DS defines corruption as a person in a position of authority or trust who abuses their position for benefit or gain for themselves or for another person. This includes the misuse of a person’s role to plan or commit a criminal act, or a deliberate failure to act to prevent criminal behaviour.

8. ‘Abusing their position’ may include acting or failing to act (e.g. turning a blind eye) in a way that constitutes a breach of the duties of that office. ‘Benefit’ or ‘gain’ can include financial, emotional, sexual or other personal and/or work-related reasons or any other perceived or actual gain or benefit. Staff may be motivated by malicious or “noble causes” (i.e. where individuals break the rules “for the right reasons”).

9. Corruption is considered gross misconduct which can result in a person’s dismissal from employment. It is likely that dismissal will affect their ability to work elsewhere in a custodial setting as set out in DSO 02/2018.Detainee Custody Officer and Detainee Custody Officer (Escort) Certification.

10. A non-exhaustive list of criminal activities and/or inappropriate behaviours that fall within the definition of corruption can be found in the Counter Corruption Framework in Annex A.

Procedures

Local Counter Corruption Teams

11. The CSP must have a named member of the Senior Management Team who holds oversight of local counter corruption processes and acts as the Local Counter Corruption Manager (LCCM). As a minimum, the local counter corruption team must also include a Deputy Local Counter Corruption Manager at management grade and an Intelligence Analyst. Both must have appropriate knowledge of counter corruption processes and support local counter corruption work.

12. Careful consideration must be given to the membership of the local counter corruption team, including any pre-existing relationships, disciplinary records and previous engagement with colleagues or detained individuals. CCIU must be informed by email to DSCounterCorruption@homeoffice.gov.uk of any existing relationships or adverse behaviour that could bring the integrity of the individual into question before the individual takes up their appointment within the local counter corruption team.

13. LCCMs and D-LCCMs must complete mandatory training within six months of appointment. This includes the HMPPS led Local Counter Corruption Management course and the Management of Intelligence course. The Intelligence Analyst will need to complete the HMPPS led Intelligence Analyst course. Centre Managers must ensure that LCCMs, D-LCCMs and Intelligence Analysts are given sufficient time and resource to conduct this role effectively.

14. The existence and role of counter corruption teams must be promoted throughout the centre to ensure all staff are familiar with the members of their local counter corruption team. Material such as posters, staff bulletins, newsletters and leaflets must be made available to staff and displayed in high throughput areas of the centre, such as staff entrances, visit halls, reception, discharge areas, healthcare, residential units and communal staff areas.

15. CSP local counter corruption teams must work transparently and effectively in partnership with DS CCIU, police and other agencies as required to progress investigations of corruption. The CSP must ensure that their memorandum of understanding with the police refers to acts of corruption and is compliant with the Data Protection Act 2018.

16. All CSPs must have a suitable system for recording allegations of corruption. As a minimum, this must record details of the source, allegation, staff members involved, detained individuals involved and actions taken. The CSP must ensure that records cannot be accessed by anyone who is not authorised to do so.

17. Where the CSP receives information alleging corruption and the staff member becomes subject to investigation, suspension, or other disciplinary action, the CSP must notify only CCIU within 24 hours. This requirement applies equally where the CSP decides not to suspend a Detainee Custody Officer (DCO) from duty but instead reallocates them to non‑DCO duties while investigations are ongoing. In all cases, the CSP must update CCIU by email to DSCounterCorruption@homeoffice.gov.uk (for information and oversight, and not for approval) on the decision taken regarding suspension or alternative duties. Any suspension letters, investigation reports, or related documentation must also be provided to CCIU via the same mailbox for information only and must not be copied to wider distribution lists.

18. Detention Services Order 02/2018 Detainee Custody Officer Certification sets out the circumstances in which it may be necessary to suspend a DCO’s certificate pending a decision on whether to revoke it. In cases where the suspension relates to allegations of corruption, details must be provided exclusively to CCIU, which holds responsibility for determining whether the certificate is to be suspended. Following the conclusion of any investigation, full details must again be shared with CCIU, which will review the outcome and provide further recommendations to the Home Office Detention Services Vetting & Certification Assurance Team (VCAT) regarding the officer’s certification status.

Challenge and support meetings

19. Challenge and support meetings are part of a broader strategy to prevent corruption before it escalates. These meetings must be a structured one-to-one session designed to identify and mitigate risks of staff corruption at the earliest opportunity. They must be conducted in person at the staff member’s normal work location (where practicable), overseen confidentially and documented by the local CSP counter corruption team.

20. A challenge and support meeting must be arranged where intelligence or concerns indicate a credible risk that a member of staff may be vulnerable to corruption or may have breached expected professional boundaries. For the purposes of this DSO, “significant enough” includes (but is not limited to) information that is credible and specific, repeated over time, involves attempted conditioning behaviour, relates to prohibited items/unauthorised disclosures, suggests intimidation/blackmail/financial vulnerability, or raises safeguarding concerns.

21. A member of the local CSP counter corruption team must meet with the identified member of staff in person within 7 working days of the intelligence/concern being received unless there is a need to postpone beyond 7 working days. Any extension must be requested from CCIU in writing, with reasons provided. Where the intelligence suggests a critical and/or imminent risk (for example, potential escape, absconding or threat to life), this must be escalated immediately through the appropriate channels, and the challenge and support meeting must take place as soon as practicable thereafter. The challenge and support meeting must be conducted confidentially, and a written record must be completed, retained securely by the local CSP counter corruption team and shared with CCIU.

Susceptible staff tracking

22. The local CSP counter corruption team must maintain and keep up to date a list of staff suspected of being particularly susceptible to corruption due to a range of factors, including personal circumstances, intimidation and threats from corruptors. This list is separate from the conflicts of interest and life factors register. The list must be made available to CCIU on request.

Training requirements

23. All staff should understand how they support the approach to counter corruption by knowing:

• The importance of behaving professionally and with integrity.

• What corruption is, how it can happen and how to prevent it taking place.

• What to do if they suspect wrongdoing and/or corruption, including what and how to self-disclose and/or report other concerns.

• The consequences for failing to report.

• The significance of reporting conflicts of interest and/ or life factors.

• The roles of CCIU and local counter corruption staff.

• The process for investigating corrupt activity, including case management /prioritisation and how to effectively work in partnership with law enforcement agencies

• The importance of professional curiosity in identifying early warning signs, patterns of behaviour, boundary testing, conditioning attempts or other indicators that may increase the risk of corruption.

• What steps must be taken to manage detained individuals who pose a heightened risk of corrupting staff, including known and potential corruptors, as set out in paragraphs 26-29.

24. All staff should be aware that corruption will not be tolerated no matter what the form or the motivation.

25. It is mandatory for all CSP staff to complete in-person Counter Corruption Awareness Training during their initial training course, with subsequent annual refresher training. Both Home Office and CSP staff must keep a record of training attendance. The CSP must submit completion results to the DCO Training Oversight Team (DTOT) by email to VCAT-DCOTrainingOversight@homeoffice.gov.uk within one calendar month of training completion.

Corruptors (known and potential)

26. Detention Services (DS) defines corruptors as “known” where there is conclusive evidence that a detained individual has corrupted or improperly influenced staff. This includes behaviour that has previously warranted internal actions to mitigate risk. Detained individuals with any criminal justice outcome or recorded disciplinary finding relating to the corruption of staff will also be monitored as known corruptors.

27. The CCIU is responsible for confirming and applying the “known” / “potential” corruptor classification and for monitoring these cases. Where intelligence indicates a detained individual may meet the definition of a corruptor, the CSP must complete an IS91 Part C and share it in line with local procedures, including with CCIU (see paragraph 29).

28. DS defines corruptors as ‘potential’ where a detained individual has not received an adjudication or criminal justice outcome related to corrupting staff, but there is intelligence or other information indicating that they have attempted to corrupt staff. The individual will usually also have identified risk factors that increase their likelihood and capability of attempting to corrupt staff.

29. Where intelligence suggests that a detained individual is displaying behaviour consistent with that of a known or potential corruptor, an IS91 Part C must be completed by the member of staff who identifies or raises the concern. The completed Part C must be shared with the DET, DS, the local CSP, CCIU and DEPMU in line with local procedures. The DET must notify the responsible case-working team and DEPMU must upload the Part C to Atlas. The CSP or escorting provider must ensure that the risk is recorded on the person escort record before any escorted move.

Conflicts of interest and life factors

30. It is recognised, as part of everyday life, staff may experience situations or circumstances which could affect their resilience to corruption. The process of declaring conflicts of interest and life factors is designed to capture those situations. Home Office and CSP staff must declare private interests that interfere, or have the potential to interfere, with the proper discharge of their duties or have the potential to affect their resilience to corruption.

31. All Home Office employees should conduct their roles with dedication and commitment to the Civil Service and its core values: integrity, honesty, objectivity and impartiality. They must adhere to the https://www.gov.uk/government/publications/declaration-and-management-of-outside-interests-in-the-civil-service/declaration-and-management-of-outside-interests-in-the-civil-serviceMandatory declarations for Immigration Enforcement.

32. All CSP staff must complete a conflict of interest and life factors form (Annex B) and submit it to their local CSP counter corruption team:

• on commencement of employment

• annually thereafter (including nil returns)

• immediately upon any change in circumstances. Staff must not wait for the annual review.

33. Completion and submission of Annex B is a safeguard and does not constitute an admission of corruption and will not be viewed as such. The annual review should not

be the only time that new conflicts or life factors are disclosed. The local counter corruption team will maintain a conflicts of interest and life factors register for all their staff. This must be updated with details of new staff and will be reviewed within a 12-monthly period as a minimum. This information must be made available within 72 hours of request to the CCIU.

34. Below is a non-exhaustive list of conflict of interest or life factor examples which may have an impact on resilience, and which CSP staff must report:

• Business interests (including secondary employment)

• Financial difficulties (including bankruptcy, insolvency, individual voluntary arrangements (IVAs), CCJs and any financial accounts that are put into a default status).

• A substantial change in financial circumstances (such as receiving a sizeable inheritance or experiencing any financial impacts including those because of divorce or dissolution of a civil partnership.)

• Criminal convictions, police cautions, or investigations including those where no further action is taken.

• Any personal or domestic relationships which could compromise, or be perceived to compromise, the staff member in the discharge of their duties. This includes knowing, having known, contacting or being in contact with a detained or formerly detained individual, including through friends, family or previous employment.

• Any other domestic or personal circumstances that could affect the working environment.

35. The local CSP counter corruption team must assess each declaration submitted via Annex B to determine whether it is relevant and, if so, whether it constitutes an actual, potential or perceived conflict of interest and/or life factor. This assessment must be completed within 7 working days of the declaration being received and must be recorded in the local conflicts of interest and life factors register, including the rationale for the assessment outcome and any mitigations/actions agreed (with owners and review dates). The register and supporting records must be retained securely and must be made available to CCIU within 72 hours of request:

• Actual conflicts - where there is a risk that the staff member’s ability to apply judgement is or could be impaired or influenced by an extant secondary interest or life factor. (i.e. recent change to financial circumstances).

• Potential conflicts - where the staff member’s ability to apply judgement or act in their role could be impaired or influenced by a secondary interest or life factor in the future. (i.e. a family member has been detained).

• Perceived conflicts - where the staff member’s ability to apply judgement or act in their role could be perceived as impaired or influenced by a secondary interest or life factor (i.e. it could cause a reasonable person to think there was a conflict of interest).

36. Where a declaration is assessed as relevant under paragraph 35, the local CSP counter corruption team must agree, implement and monitor proportionate mitigation measures. Where practicable, mitigations must be discussed with the individual who made the declaration before being confirmed. The agreed mitigation outcome and any actions must be recorded in the conflicts of interest and life factors register (including rationale, action owner(s), target date(s) and review date). The register and supporting records must be retained securely and made available to CCIU within 72 hours of request. The following is a non-exhaustive list of possible assessment outcomes and mitigation actions:

• No conflict - agreement that there is no conflict of interest (or perceived conflict of interest) and therefore no additional action is necessary.

• Restrictions - continue with the activity but implement actions to mitigate and minimise risk. Necessary actions will be entirely dependent on the risk presented; however, it might include things such as closer monitoring, revisions to existing work plans or changes to work locations.

• Exclusions - it may be that the only reasonable step to minimise the risk is to have the staff member concerned removed from the activity. Mitigation examples may include changing responsibilities.

• In some cases - it may be considered that the interest or factor is relevant but presents no risk (i.e. it does not meet the definition of an actual, potential or perceived conflict of interest or life factor). Such instances are to be recorded and monitored.

37. Any actual conflict of interest must be resolved in a way which minimises the risk. Potential or perceived conflicts may exist where effective mitigations are in place. Assessments, considerations and agreed actions must be properly documented to provide a clear audit trail.

Reporting Process

38. All Home Office, CSP and healthcare staff working within an IRC or the PDA must report any suspicions of wrongdoing at the earliest opportunity through the appropriate reporting channels. Failure to report corruption or serious wrongdoing may itself be a disciplinary matter and, in some circumstances, may constitute a criminal offence. Staff must report wrongdoing before it escalates into corruption.

39. This DSO should be read alongside DSO 03/2020 Whistleblowing. Nothing in this DSO replaces or limits the wrongdoing reporting routes set out in that DSO. Where a concern relates to corruption, the reporting routes in this DSO must also be followed.

Anonymous reporting

40. If there is evidence or suspicion that the conduct of a member of staff falls within the definition of corruption, it must be reported without delay. Concerns can be raised through:

• Scan the QR code on the left or visit immigrationdetentioniline.co.uk.

• Crimestoppers on 0300 470 9008

• Your local counter corruption team

• DS CCIU, either in person or by emailing DSCounterCorruption@homeoffice.gov.uk

• Local whistleblowing lines

• In an emergency, dial 999 and ask for the police.

41. Staff, visitors and detained individuals can be confident when reporting a concern that their identity will be protected, and that confidentiality will always be maintained. To enable a meaningful investigation, staff are strongly encouraged to disclose their identity when reporting a concern, however, it is reasonable to assume given the very nature of the reports being submitted, there will be occasions when the reporting person does not wish to be identified.

42. DS has a bespoke integrity reporting service enabled by Crimestoppers which is entirely anonymous, and this allows all staff, visitors, detained individuals or members of the public to speak up with confidence and report any concerns they may have. This integrity line must be visibly promoted around the centre to all staff, detained individuals and visitors.

43. The identity of a member of staff who reports corruption will only be accessible to counter corruption staff and law enforcement agencies.

44. If the allegation relates to a CSP senior manager, it should be reported to the local counter corruption team and/or CCIU. The Crimestoppers integrity reporting line is also available.

45. As a minimum, each IRC must have two lockable and tamper-proof boxes clearly marked “Confidential Reports,” positioned in discreet areas of the centre that cannot be accessed by detained individuals. CCTV must not cover the location of these boxes. The CSP must ensure these boxes are signposted and promoted during counter corruption awareness training.

46. The local CSP counter corruption team must access and empty the boxes on a regular basis and no less than every 72 hours. The team must check the integrity of the boxes at each access to ensure they remain secure, in good condition and clearly marked “Confidential Reports.” Any urgent concerns identified must be shared with CCIU in line with paragraphs 50 and 51. In addition to paper-based reporting, an electronic process such as a confidential email inbox must be available for staff to raise concerns. The CCIU inbox DSCounterCorruption@homeoffice.gov.uk should also be promoted.

Security Information Reports (SIRs)

47. SIRs must be used to report any concerns, as set out in DSO 11/2014 Security Information Reports. SIRs can be written by any member of staff and must be submitted promptly in line with local SIR reporting procedures. Where the concern falls within the definition of corruption, the SIR must be marked ‘confidential’ and submitted directly to the local counter corruption team, who are responsible for managing and analysing it.

48. As set out in DSO 01/2015 Extremism and Radicalisation, all staff operating in the centres (including Home Office and healthcare staff) who have concerns about extremism or radicalisation in relation to anyone they encounter, should submit an SIR. Where this information details a concern in relation to a member of staff, the report must be shared directly with the local counter corruption team, who will make a Counter Terrorism referral and share it only with CCIU.

Handling of information

49. Access to intelligence and information will be restricted only to those individuals who require it to investigate and combat the threat posed by corruption.

50. The local counter corruption team must ensure that intelligence reports relating to corruption are triaged within 72 hours. If the intelligence relates to a critical and/or imminent risk, such as potential absconding, escape or threat to life, it must be escalated immediately through the appropriate channels, including the police in an emergency, and in line with local incident reporting procedures.

51. Out of regular business hours, any concern deemed to pose an imminent threat must be reported to the most senior member of the CSP, who must raise it directly with the on-call DS Duty Head of Detention Operations. Where the information is deemed an imminent threat or a risk to staff, detained individuals, or the safety and security of the immigration removal estate, CCIU must also be informed within 24 hours of the information being received.

52. When intelligence is shared, it must be disseminated only to those who need to know and in a sanitised form that protects the source and does not disclose any tactics that may have been used to obtain the information.

53. Handling codes (3x5x2) must be appended to all disseminations as per DSO 11/2014 Security Information Reports, to ensure that the receiving agency or officer is aware of how they can use the intelligence. Where the intelligence originates from an external source or agency, permission must always be sought to disseminate the intelligence, even if sanitisation has taken place within DS.

54. The CSP must document all allegations and incidents of staff corruption, ensuring that all individuals against whom a concern has been reported are captured on the CCIU return spreadsheet (Annex C). This must be shared fortnightly with the CCIU, including nil returns. Where information identifies an imminent threat, or a risk to staff, detained individuals, or the safety and security of the immigration removal estate, CCIU must be informed within 24 hours of the information being received.

55. The CSP must document all allegations of detained individuals attempting to corrupt staff on the CCIU return spreadsheet (Annex C). For example, when a detained individual is overly friendly or asks a staff member to convey an illicit or prohibited article. All reports received that relate to allegations of staff corruption are to be categorised under the coding (Annex D) supplied by CCIU. This will be regularly reviewed to ensure it remains up to date and relevant.

56. Detained individuals who provide intelligence must be afforded the necessary safeguards. Any detained individual noted as a source of intelligence must be recorded. The details of detained individuals providing information in relation to corruption are to be shared with DS Security Team as set out in DSO 02/2015 Regulation of Investigatory Powers Act 2000 (RIPA).

57. Any reports submitted that raise concerns about more than one individual are to be logged for everyone separately. For example, one report containing allegations relating to five members of staff would generate five individual reports.

58. The CSP must make sure that all staff, visitors and detained individuals have access to, and are aware of, the available reporting methods so that suspicions of wrongdoing and corruption can be captured in a timely manner.

59. All Home Office, CSP and healthcare staff have a duty to ensure that reporting channels are not used maliciously or as a vehicle for bullying and/or harassment. Bullying and harassment, false or malicious reporting will not be tolerated and any suspicions of this will be dealt with through local policies.

60. CSPs must ensure that the processing, storage, and destruction of corruption-related intelligence complies with current data protection legislation. Privileged, personal and confidential information must only be used for corruption-related investigations where this is proportionate and managed in line with current data protection legislation. All intelligence and evidential documents must be retained for 10 years.

Case management

61. All counter corruption cases will be rated under three categories: Active, Open and Closed. It will not be uncommon for cases to move between the three categories. Below sets out the characteristics which will define the status of a case.

• ACTIVE: Intelligence is current and frequent and requires tasking. These cases are likely to require regular case management meetings more than the monthly minimum.

• OPEN: Intelligence requires development or monitoring.

• CLOSED: No further actions are required or there is evidence that the allegations are false.

62. The CSP LCCM must arrange monthly, or more frequent if required, case management meetings to support the management of their corruption cases. Case management meetings must include all local counter corruption staff, CCIU and local Police Liaison Officers, where required. Attendance must be limited to those individuals who are required to investigate and combat the threat posed by corruption.

63. For each case, the meeting must consider the intelligence, the potential outcome, and the desired support from CCIU and law enforcement. All decisions and actions must be documented and shared only with those required to investigate and combat the threat posed by corruption. Tasking should not take place outside of this meeting, except in high-risk cases requiring immediate attention.

64. Where counter corruption staff progress corruption cases outside of the case management meeting, CCIU must be informed within 24 hours and provided with relevant details of the action taken.

65. Requests to transfer detained individuals involved in corruption concerns should be made directly to CCIU only.

66. When triaging intelligence reports relating to corruption, the LCCM / D-LCCM must consider whether the report relates to potential corruption, professional standards (not including potential corruption), staff issues or requires no further action. Information and intelligence that concern professional standards matters (not including potential corruption) must be discussed as part of the local professional standards meetings and documented on the monthly professional standards return.

Standards and conduct

67. Home Office staff must be aware of the expected professional standards of conduct, as outlined in the Civil Service Code, and must always comply with those standards.

68. The Civil Service Code sets the standards of behaviour that all civil servants are expected to follow in the discharge of their duties. The Code requires that civil servants perform their duties with integrity, honesty, objectivity and impartiality.

69. In addition to the Civil Service Code, the Home Office Personal Conduct Policy sets clear expectations for professional standards and personal conduct. Staff are required to always uphold these standards. Any engagement in corrupt behaviour constitutes a direct breach of both the Civil Service Code and Home Office Personal Conduct Policy.

70. Failure to adhere to the Civil Service Code and Home Office Personal Conduct Policy may result in disciplinary proceedings and should be managed in line with the Home Office Discipline Policy and Procedure which can be found on internal systems. In the most serious cases, a referral may be made to the police for a criminal investigation.

71. Any evidence or suspicion of corruption involving a Home Office member of staff that is identified during a CSP investigation or disciplinary process must be referred to CCIU for consideration and onward referral, where necessary.

Support for staff and detained individuals

72. Consideration needs to be given to the impact that acts of corruption have on detained individuals and staff, and appropriate support networks need to be in place and regularly promoted within the IRC or the PDA. CSPs must operate a system through which staff can independently obtain support and advice if they encounter difficulties in the workplace. CSPs must also maintain links with charities that offer support to detained individuals, and details of those organisations, including any charges that may apply, must be made available. Home Office staff can contact the Employee Assistance Programme (EAP) for support in addition to the IE wellbeing team.

73. It is recognised that being arrested, suspended or excluded based on corruption related allegations can leave a staff member feeling isolated, confused, and vulnerable. Where this occurs, the CSP must complete a wellbeing risk assessment at the point of suspension, using the Home Office Individual Stress Impact Tool (ISIT) template or an equivalent CSP template that captures the same minimum information. The assessment must ensure that the individual is signposted to appropriate support services and that their wellbeing is safeguarded. It must be reviewed at key stages of the investigation through to case conclusion.

74. In some circumstances, corruption and wrongdoing can raise safeguarding issues. All Home Office, CSP and subcontracted staff working or volunteering with children and young people (under the age of 18), must be clear of their safeguarding responsibilities.

75. All Home Office, CSP and healthcare staff must report any suspicions of wrongdoing and corruption at the earliest opportunity through the appropriate channels. If the suspected wrongdoing or corruption involves any actual or potential harm to a young person, this must also be reported using child protection procedures as outlined in DSO 19/2012 Safeguarding children policy or through the policies and procedures of other employers for staff of CSP and non-directly employed persons.

76. All Home Office, CSP and healthcare staff working or volunteering must be clear of their safeguarding responsibilities for adults and follow the appropriate reporting procedures as outlined in DSOs 03/2022 Adults at Risk, 01/2022 Assessment Care in Detention and Teamwork (ACDT) and 04/2020 Mental Vulnerabilities and Immigration Detention: Non-clinical guidance. This is particularly important where a detained individual may have mental health, physical health or social care issues which may make them particularly vulnerable.

Investigations

77. If a police investigation is ongoing, all other Home Office or CSP investigations should cease until its conclusion, unless the police have agreed otherwise. Any potential criminal offences not immediately identified but revealed during a Home Office or CSP investigation must be referred immediately to the police and CCIU.

78. All staff must support any investigation, criminal or otherwise, and prosecutions that may arise following allegations of corruption. This includes but is not limited to providing witness statements, attending interviews and giving evidence in court. The CSP must allow staff the time and support to enable this.

79. CSPs are responsible for undertaking any investigations and any subsequent disciplinary action. All investigations into a member of staff where there are allegations of corruption must be formally resolved, even when an individual resigns while under investigation. If an individual resigns before an investigation is concluded, all reasonable efforts should be made by the CSP to ensure as much participation as possible in the ongoing procedures, both before and after termination of employment. Where the allegation relates to corruption, a copy of the investigation report must be shared with CCIU only. CCIU will consult with VCAT as appropriate.

Self-audit

80. CSPs are required to undertake an annual self-audit of this DSO to ensure that the processes are being followed. This audit should be made available to the Home Office on request.

81. The DS Incident & Counter Corruption Hub must also conduct an annual audit against the responsibilities assigned to it under this DSO.

Revision History

Review date	Reviewed by	Review outcome	Next review
August 2026	Head of Incident and Counter Corruption Hub	Implementation	August 2028

Annex D

Counter Corruption Report Categories

No	CC Headings	Code
A
1	Affiliation to prohibited groups	AP
2	Assault	AS
3	Associations	AC
4	Alcohol	AL
5	Adverse/Negative history	AV
B
6	Behaviour Change	BC
7	Blackmail / Bribery	BB
8	Breach of Security/Failure to follow procedures	BS
9	Bullying	BL
C
10	Conflict of Interest	CI
11	Criminal Allegations	CA
12	CT Concerns	CT
13	Corruptor (known or potential)	CD
14	Conditioning attempt	CO
15	Criminal Conviction	CV
D
16	Drugs - Conveyance	DC
17	Drugs - Indication by Dogs	DD
18	Drugs - Conveyance suspicion	DCS
19	Drugs - Other	DO
E
20	Escape Assistor	EA
F
21	Fraud	FD
I
22	Inappropriate Behaviour	IB
23	Inappropriate Relationship	IR
M
24	Mobile Phone (Illicit) - Conveyance	MC
25	Mobile Phone (Illicit) - Suspicion	MS
O
26	Organised Crime Links	OC
P
27	Prohibited items - Conveyance	PC
28	Prohibited items - Suspicion	PS
29	Photographs / Concerning Images	PH
S
30	Social media	SM
31	Sexual Assault	SS
32	Street Name	SN
T
33	Theft	TH
U
34	Unauthorised Disclosure of Information	UD
35	Unauthorised Article	UA
V
36	Vulnerable to Conditioning	VC
W
37	Weapons	WE