1.    INTRODUCTION AND BACKGROUND

1.1     The Council’s present counter fraud policy dates from 2009.  While that document remains fundamentally sound, it has fallen out of date against current best practice.  There are also specific developments since then, including the Bribery Act 2010 and CIPFA’s Counter Fraud Code of Practice that should feature within the Council’s policymaking.

1.2     We have aimed to keep the Policy brief and straightforward with much detail included within the appendices.  Those appendices are in summary rather than attached here for the following reasons:

·         They contain details of investigative method (including, for example, the range and types of information shared) that might aid potential fraudsters.

·         They repeat policies already seen by the Committee (including the Whistleblowing Policy).

·         They need further detailed development with at-risk services (for instance discussing with public facing, decision making and cash handling departments on specific procedures to identify and address bribery threats).

1.3     However, for a brief overall summary, see the notes below which describe how the Policy addresses the key principles of the CIPFA Code.

2.        AVAILABLE OPTIONS

2.1     The Council is not required to have a Counter Fraud & Corruption policy.  However, it is in keeping with the Council’s desired standards of governance to clearly set out its approach to identifying and tackling economic crime and affirming a robust approach to threat.  The Council does currently have a policy that, broadly, conforms to those aims and would allow (but not demand) the extra action set out in Appendix 1.

2.2     Members could, therefore, choose to keep the previous policy.

2.3     Alternatively, the Policy at Appendix 1 conforms to current best practice, in particular in recognising developments since the previous incarnation. It also sets out with more clarity our aims to keep our approach updated year to year for developing risk and providing results to Senior Management and Members. It also clarifies decision making around information and investigation.

3.        PREFERRED OPTION AND REASONS FOR RECOMMENDATIONS

3.1     We recommend approval of the Policy at Appendix 1.  This will direct a more comprehensive approach to tackling fraud and corruption. We will set that out in more detail in the Internal Audit & Governance Plan 2018/19.

4.       RISK

4.1    We have considered the risks associated with this proposal, including the risks if the Council does not act as recommended in line with the Council’s Risk Management Framework.  We are satisfied that the risks associated are within the Council’s risk appetite and will be managed as per the (Risk Management) Policy.

5.       CONSULTATION RESULTS AND PREVIOUS COMMITTEE FEEDBACK

5.1     The Policy was circulated to the Director of Finance and Business Improvement last month and updated for comments.  The Policy will also be discussed at a Wider Leadership Team meeting on 9 January.  The Head of Audit Partnership will advise Members verbally of any further updates that arise from that meeting.

5.2     The Council is also a member of the CIPFA Counter Fraud Network.  Using that membership we have circulated the policy to CIPFA for comment.  The document at Appendix 1 reflects those comments.

5.3     We presented to Members in an informal briefing in November 2017 our outline plans for the Policy.  In a discussion following that presentation, Members made several points on areas to include, such as stressing the benefits of publicising successful prosecutions.  The Policy reflects the feedback from that discussion.

6.       NEXT STEPS: COMMUNICATION AND IMPLEMENTATION OF THE DECISION

6.1     Once agreed, the Policy will inform preparation of our 2018/19 Internal Audit & Governance Plan.  Members will see that plan in the Spring and have opportunity to comment on the detail.

7.       CROSS-CUTTING ISSUES AND IMPLICATIONS

8.        REPORT APPENDICES

·         Appendix 1: Counter Fraud and Corruption Policy

9.        BACKGROUND PAPERS

CIPFA Code of Practice for Counter Fraud - http://www.cipfa.org/services/counter-fraud-centre/code-of-practice

Existing Corporate Anti-Fraud and Corruption Policy - http://vindex/HR/Documents/Corporate%20Anti%20Fraud%20and%20Corruption%20Policy.pdf