The Head of Internal Audit and Corporate Anti-Fraud will submit a report presenting draft versions of the revised Corporate Anti-Fraud and Corruption Policy and Corporate Anti-Fraud and Corruption Strategy together with a draft version of the Council’s new Corporate Anti-Bribery Policy and requesting the Committee to forward any observations and amendments to Cabinet which be requested to approve those policies.
The Head of Internal Audit and Corporate Anti-Fraud submitted a report presenting draft versions of the revised Corporate Anti-Fraud and Corruption Policy and the Corporate Anti-Fraud and Corruption Strategy together with a draft version of the Council’s new Corporate Anti-Bribery Policy and requesting the Committee to forward any observations and amendments to Cabinet which be requested to approve those policies.
The need for the revision of the policies had been identified following the creation of the Corporate Anti-Fraud Team within Internal Audit and, in addition, the Anti-Bribery Policy had been written in order to meet the legal obligations in relation to anti-bribery legislation. Copies of these documents were appended to the report.
The report also outlined how these policies and strategy fit within the overall counter fraud framework of the authority. It was also noted that a number of other policies including the Fraud Response Plan, Prosecutions Policy, Whistleblowing Policy and Anti-Money Laundering Policy were also being reviewed and would be presented to Committee in due course.
In the ensuing discussion, the following matters were raised:
· The valuable contribution of the Corporate Anti-Fraud Team in this process was noted. It had been a number of years since some of these policies had been reviewed and all submitted today had been previously submitted to the Employee Forum, SMT and to Service Directors. The recommendations of this Committee would then be submitted to Cabinet for approval
· The benefits of limiting cash payments had had a significant impact on reducing the opportunity for fraud. In those areas where cash payment was retained, the service undertook unannounced visits in order to minimise the opportunity for theft
· Referring to the Corporate Anti-Fraud and Corruption Strategy, the Head of Internal Audit and Corporate Anti-Fraud outlined the instances in which the Police would become involved in issues and the procedures which were followed. It was noted that the burden of proof to ensure a successful prosecution was higher than that required by the authority which could take appropriate disciplinary action irrespective of whether or not a case was taken to prosecution
· There was a discussion of the language used throughout the policies. It was suggested that actions required to be taken by officers/Members should be prescriptive rather than advisory. The Director of Legal and Governance and Head of Internal Audit and Corporate Anti-Fraud stated that these policies should be read alongside the Code of Conduct policies which detailed the actions required to be taken in relation to suspected fraud. The points made by members of the Committee were, however, well made and it was agreed that the wording of the policies would be reviewed and re submitted to the next meeting. Also, given that the Committee had not had sight of the Codes of Conduct, these would also be submitted to the next meeting so that members could see the correlation and interrelationship between all policies
· Arising out of the above, there was a discussion of the requirements of the procedure for the declaration by staff and Elected Members of gifts and hospitality
· There was a discussion of the action which could be taken against both an Elected Member and officers who through their actions in their ‘non work’ life, brought the Authority into disrepute
· Reference was made to training. It was noted that anti-fraud awareness training had not yet been made mandatory but the Service was looking to include this as part of a wider suite of awareness training. Arising out of the discussion, it was reported that a log of all online training undertaken
RESOVED that the report and draft policies be received and amended as indicated and that they be submitted to the next meeting together with copies of the Employee and Elected Member Codes of Conduct