Counter fraud and anti-corruption policy

Responsibilities

Our Constitution sets out how we operate and make decisions.  This includes a commitment to counter-fraud and anti-corruption. We identify specific roles and responsibilities in the Constitution and financial procedures: 

Chief executive

Ultimately accountable for the effectiveness of our arrangements for countering fraud and corruption. 

Monitoring officer

To advise Councillors and officers on ethical issues, standards and powers to ensure that we operate within the law and statutory codes of practice.

Executive director for resources (Section 151 officer)

To develop and maintain counter fraud policy and whistleblowing policy.  These will be endorsed and approved by the Audit Committee and published on our website.

To ensure we have an adequately resourced and effective counter fraud and internal audit service. 

Audit committee

To review the assessment of fraud risks and potential harm to us from fraud and corruption.

To monitor the effectiveness of our financial regulations, procurement policy and procedures and other strategies for counter fraud and anti-bribery, whistleblowing and anti-money laundering.

To promote high standards of conduct amongst staff and Councillors and have a nominated fraud champion.

Councillors

To support and promote the development of a strong counter fraud culture.

External audit

Subject to the concept of materiality, provide reasonable assurance that the financial statements are free from material misstatement, whether caused by fraud or other irregularity.

Corporate audit and risk management (counter fraud and investigations team)

To report significant matters of fraud or financial irregularity to:

  • the Section 151 officer
  • head of paid service (chief executive)
  • the Executive 
  • the audit committee

To develop and implement the counter fraud policy. To promptly investigate cases of suspected fraud reported under this policy, via the whistleblowing arrangements or the national fraud initiative.  

To make recommendations to improve controls and reduce the risk of fraud in the future.

To maintaining whistleblowing reporting arrangements.

To ensure that where fraud is found proportionate action is taken for sanctions and redress.

Executive directors

To ensure that this policy is adhered to. To assess the risk of fraud, bribery, corruption and theft in their service areas. To reduce these risks by implementing strong internal controls.

To report all suspected fraud or financial irregularity in their service areas to the head of internal audit.

Other managers

To promote staff awareness. To refer all suspected fraud to the counter fraud investigations team. To apply the policy of zero tolerance. To ensure that they assess the risk of fraud, corruption and theft in their service areas. To reduce these risks by implementing strong internal controls.

Staff

To comply with our policies and procedures. To be aware of the possibility of fraud, bribery, corruption and theft.  To report any genuine concerns to management, the counter fraud investigation team or via the whistleblowing arrangements.

Public, partners, suppliers, contractors and consultants

To be aware of the possibility of fraud, bribery, corruption and theft against us. To report any genuine concerns or suspicions.