Counter Fraud & Corruption Policy
- Meeting of Audit, Governance and Standards Committee, Monday 15th January, 2018 6.30 pm (Item 74.)
- View the background to item 74.
Mr Rich Clarke, Head of Audit Partnership, introduced his report proposing a refreshed policy setting out how the Council aimed to identify and mitigate the risks of fraud, corruption and wider economic crime and how the Council would deal with incidents.
Mr Clarke explained that:
· The Council’s present counter fraud policy dated from 2009. Whilst the document remained fundamentally sound in setting out a robust counter fraud message and how the Council would deal with incidents as they arose, there were some areas that needed re-examination.
· There had been changes to legislation, including the Bribery Act 2010, and updates to best practice (CIPFA’s Counter Fraud Code of Practice) that should feature within the Council’s policy making. The Code included a recommendation that Councils should seek to orientate their policies as to how they would identify and address the risk of fraud and to what they would do if it occurred. The policy aimed to fulfil these requirements by going into more detail about how the Council would seek to investigate and address instances that arise, the types of instances the Council would be looking to identify and the actions the Council would seek to take to mitigate the risk, including e-learning, workshops and designing new systems.
· A lot of the detail would come forward in the Internal Audit and Governance Plan 2018/19 which would set out some of the proactive work the Internal Audit Team intended to undertake in high risk areas to provide assurance that the Council’s arrangements were sufficiently robust to address the risk of fraud arising as well as having strong arrangements for dealing with it should it occur.
· It was a function of the Audit, Governance and Standards Committee to recommend and monitor the effectiveness of the Council’s Counter Fraud and Corruption Policy. Approval of the Policy was delegated to the Policy and Resources Committee.
RESOLVED to RECOMMEND to the POLICY AND RESOURCES COMMITTEE: That the Counter Fraud and Corruption Policy, attached as Appendix 1 to the report of the Head of Audit Partnership, be approved subject to the following amendments:
Paragraph 16 – Amend the first sentence to read:
Officers shall be alert to the possibility of economic crime and report any suspicious activity.
Paragraph 17 – Amend the first sentence to read:
Officers shall comply with the Code of Conduct and all relevant Council policy and procedures.
Paragraph 33 – Amend to confirm that data will be handled in accordance with the Data Protection Regulations.
Paragraph 38 – Amend the first sentence to read:
The culture and tone of the Council must be one of honesty with zero tolerance towards fraud, bribery and corruption.
Paragraph 40 – Amend the first sentence to read:
Criminal prosecutions deter potential offenders and reinforce our zero tolerance towards economic crime.
Whilst the Committee understood the reasons for not including details of all of the Appendices to the policy, it was considered that, as appropriate, a summary should be included to provide assurance to people raising issues that investigations will be undertaken with due professionalism and independence.
Note: Councillor English left the meeting at the start of this item (7.00 p.m.).
- Counter Fraud Corruption Policy, item 74. PDF 73 KB View as HTML (74./1) 57 KB
- Enc. 1 for Counter Fraud Corruption Policy, item 74. PDF 575 KB View as HTML (74./2) 38 KB