Agenda item

The Head of Internal Audit, Anti-Fraud and Assurance will submit draft versions of the following policies and requesting the Committee to make any necessary observations and suggestions prior to their submission to Cabinet for approval:

·         Corporate Anti-Fraud and Corruption Policy

·         Corporate Anti-Fraud and Corruption Strategy

·         Corporate Anti-Bribery Policy

·         Corporate Prosecutions Policy

·         Corporate Fraud Response Plan

·         Confidential Reporting Policy

·         Corporate Anti-Money Laundering Policy

The Head of Internal Audit, Anti-Fraud and Assurance submitted draft versions of the following policies and requesting the Committee to make any necessary observations and suggestions prior to their submission to Cabinet for approval:

·         Corporate Anti-Fraud and Corruption Policy

·         Corporate Anti-Fraud and Corruption Strategy

·         Corporate Anti-Bribery Policy

·         Corporate Prosecutions Policy

·         Corporate Fraud Response Plan

·         Confidential Reporting Policy (formerly the Whistleblowing Policy)

·         Corporate Anti-Money Laundering Policy

The policies, all of which had been reviewed and updated as appropriate by Ms J Race (Principal Auditor) represented a suite of documents which provided a framework of counter fraud policies addressing specific areas of risk and supported the Council’s zero tolerance approach to fraud and illegal activity as well as providing mechanisms which officers could use to raise concerns of wrongdoing or fraudulent activity.  The covering report provided a summary of the amendments to the policies previously submitted to Committee.

In the ensuing discussion the following matters were highlighted:

·         There was a discussion of the wording of the Corporate Anti-Fraud and Corruption Policy and whether or not it should be changed to reflect a request for a more mandatory approach to the reporting of issues.  The Head of Internal Audit, Anti-Fraud and Assurance stated that further reflection would be given to the wording but it was acknowledged that getting the correct balance could be difficult

·         Arising out of the above, there was a discussion about the way in which staff could be encouraged to respond appropriately to concerns identified

·         It was suggested that the policies, being lengthy by their very nature, may not be easily digestible and there was a discussion of the ways in which they could be made more easily accessible.  It was noted that the newly appointed Corporate Governance and Assurance Manager would be asked to look at such matters.  Arising out of this reference was made to the ways in which these types of policies could be brought to staff attention which it was suggested may be either via the Council’s intranet or via training modules

·         In response to questioning, the Head of Internal Audit, Anti-Fraud and Assurance stated that issues identified relating to Universal Credit Fraud would be referred to the Department for Work and Pensions

·         It was noted that the Confidential Reporting Policy was aimed at members of staff but nevertheless referred to how members of the public could raise concerns.  The Head of Internal Audit, Anti-Fraud and Assurance briefly commented on how the public could raise concerns or disclosures of wrongdoing.  He would undertake a review of how robust the complaints process was and would also reflect further on the wording of this section of the policy

·         There were no particular concerns in relation to money laundering and indeed the risks of the Council contravening legislation in this respect were relatively low and some of the legal and regulatory requirements did not apply to public authorities.  The Council could not be immune to such risks, however, and it was appropriate, therefore, that it complied with the principles of the money laundering legislation by taking appropriate and proportionate safeguards

RESOLVED that the suite of Corporate Anti-Fraud and Corruption Policies and Strategies appended to the report now submitted be noted and referred to Cabinet for approval.