Anti Fraud, Corruption, and Bribery Policy and Strategy

Detection, Investigation, Sanctions, and Redress

7.1 Prevention systems, particularly internal control systems, within the Council have been designed to provide indicators of any fraudulent activity.

7.2 It is often the alertness of staff and the public to such indicators that enables detection to occur and the appropriate action to take place when there is evidence that fraud or corruption may be in progress.

7.3 Despite the best efforts of financial managers and auditors, many frauds are discovered by chance or 'tip off,' and the Council has in place arrangements to enable such information to be properly dealt with - the Confidential Reporting (Whistle Blowing) Policy and the Fraud, Corruption and Bribery Response Plan both of which are available on the Council's Intranet.

7.4 Other methods of detection will be employed, on a risk basis, by those officers of the Council charged to do so.

7.5 These will include analytical intelligence techniques and the sharing of information, within the data protection rules, with other agencies both locally and nationally. Examples of bodies involved in sharing such intelligence and data are External Audit, The Cabinet Office - National Fraud Initiative (NFI) and Department for Work and Pensions (DWP).

Investigation

7.6 An Investigating Officer will be appointed by the Executive Directors and/or S.151 Officer, following liaison with the Monitoring Officer, for fraud, corruption or bribery investigations (normally the Internal Auditor).

7.7 A detailed Fraud, Corruption and Bribery Response Plan has been written which contains Flow Diagrams showing the Reporting, Investigation and Action stages under the following headings:

  • Notifying Suspected Fraud;
    • Line Management;
      • Confidential Reporting - S.151 Officer, Executive Directors, Monitoring Officer, Group Managers and/or Internal Audit;
  • Investigating Suspected Fraud;
    • Steps to be taken;
    • Responsibilities of the Investigating Officer;
  • Liaison with External Audit and the Police;
  • Interim Report/Final Report;
  • Outcomes;
    • Disciplinary;
    • Prosecution;
    • Exoneration;
  • Confidentiality; and
  • Postscript - Defamation.

7.8 The Response Plan is available to all staff on the Council's Intranet.

7.9 Depending on the nature and anticipated extent of the allegations, Internal Audit will normally work closely with management and other agencies such as the Police to ensure that all allegations and evidence are properly investigated and reported upon.

7.10 Any control weaknesses identified by an investigation must be reported to the relevant manager to allow improvements to be made that will ensure that there is no opportunity for further fraud or corruption.

Sanctions and Redress

7.11 The Council's Disciplinary Procedures will be used where the outcome of the Investigation indicates improper behaviour of staff.

7.12 Sanctions by Standards Committee for members would follow a finding of the breach of the Members Code of Conduct.

7.13 For both staff and Members In cases where financial impropriety is discovered, the Council will normally wish the Police and Crown Prosecution Service to assess evidence and make the decision to prosecute or not.

7.14 The Council will always seek to recover any losses incurred as a result of fraud, corruption or bribery, wherever this is practical, including the use of the civil law if appropriate. Losses will be calculated using a professional statistical methodology for making accurate estimates, building in a proper level of independent valuation as required.

Investigations Not Involving Fraud or Corruption

7.15 The investigation process related to the Council's Disciplinary Procedures will only be used to for those enquiries where no fraud, corruption or bribery is suspected.

7.16 The manager responsible for human resources will outline any investigations undertaken under the Disciplinary Procedures to the S.151 Officer, Monitoring Officer and relevant officers, who meet as an officer group known as the Statutory Officers Panel, on a regular basis.