Anti Fraud and Corruption Policy

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Background

The purpose of this policy is to make clear to Councillors, employees, agents, customers, claimants, contractors, partners and suppliers the Council’s attitude towards fraud and corruption. For the purpose of this document, “fraud” means any attempted or actual theft, deception, bribery, forgery, extortion, corruption, embezzlement and misappropriation. These include, but are not confined to, the specific offences in the Fraud Act 2006.

The threat from fraud and corruption is both internal and external. The Council’s expectation is that Councillors and employees at all levels will lead by example to ensure that the highest standards of propriety and accountability are established and strictly adhered to, and that personal conduct is above reproach at all times.

The Council demands that individuals and organisations with which it comes into contact act towards the Council at all times with integrity and without fraudulent or corrupt intent.

Zero-tolerance

The Council will not tolerate any fraud or corruption and will maintain an effective anti fraud and corruption strategy, based upon comprehensive ongoing risk assessments in all areas of Council activity, to reduce losses from fraud and corruption in all areas to an absolute minimum, through:

• the promotion of an anti fraud culture;
• robust measures to deter, prevent and detect fraud;
• the professional investigation of any allegation or suspicion of fraudulent or corrupt activity; and
• the instigation of legal, disciplinary and recovery action against any individual found to have acted fraudulently or corruptly in their relationships and dealings with the Council.

Corporate responsibility: governance and risk management

The Council has established a framework of procedures and controls which provide the major elements of the Council’s anti-fraud and corruption governance arrangements. It is essential that the management of fraud risk is fully integrated within the Council’s comprehensive risk management procedures. Those responsible for risk assessment are expected to use the Fraud Risk Impact Assessment resources for regularly reviewing these risks to the Council.

Personal responsibility: awareness and reporting

All who are employed by, represent, or have dealings with the Council are expected to be aware of, and always to act in accordance with, this policy and the elements of the framework of procedures and controls appropriate to them.

Councillors and employees should be vigilant for signs of fraud and corruption, and are expected to report matters of genuine concern. Such concerns or reasonable suspicions may be reported in accordance with the Council’s whistleblowing policy, or directly to:

• A supervisor, manager or director;
• The Chief Financial Officer (Section 151 Officer);
• Internal Audit;
• The Monitoring Officer or Corporate Standards Manager.

Employees are assured that in raising such concerns they will be fully supported, that they will have nothing to fear from reprisals and there will be no adverse impact on their personal situation. Where anonymity is requested every effort will be made to guarantee confidentiality in accordance with the whistleblowing policy.

Members of the public are encouraged to report concerns using the contacts provided in the whistleblowing policy.

Councillors and employees are also encouraged to notify Internal Audit of opportunities which may exist for fraud or corruption due to weaknesses in systems and procedures.

Action the Council will take

The Council will investigate promptly and fully all suspicions of fraud and corruption in a professional manner in accordance with its investigation procedures. It should be noted that an allegation does not mean the individual person or company is guilty of any wrong-doing, so they will not be treated as such unless the case is proven.

Housing Benefit & Council Tax Benefit fraud

The Council has a dedicated Investigation Team which is responsible for the prevention and detection of benefit fraud.  Any allegations or suspicions of fraud will be dealt with in accordance with relevant legislation, codes of conduct and policies.

Benefit Investigation Officers are required to notify the Audit Team of cases of possible fraud involving benefits, Council Tax exemptions or discounts where the suspect is an employee or member of the Council. Similarly, should an audit investigation indicate an employee or member is fraudulently claiming benefits, Council Tax exemptions or discounts the Benefit fraud investigation team will be notified.

Other Cases

Action for all other cases will be determined by the circumstances of the case. If fraud or corruption has taken place, the Council will, as appropriate:

• prosecute the individual(s) or refer the case to the police;
• take appropriate disciplinary action where it involves an employee which could lead to dismissal;
• refer the case to the Standards Board of England where it involves a councillor;
• pursue recovery for all financial loss.

Publicising Proven Fraud

In accordance with good governance, the Council must demonstrate openness, inclusivity, integrity and accountability in all of its dealings, so the Council will, for all cases proven through the courts, publicise the names of the guilty together with the details of their crimes

Framework for anti fraud and corruption governance

Key elements of the framework of procedures and controls to reduce the opportunities for, and impacts of, fraud and corruption:

• Anti-Fraud and Corruption Policy
• The Wiltshire Council Constitution
• Standards Committee
• Financial Procedure Rules, Financial Regulations; Contract Regulations
• Procurement Guidance
• Codes of Conduct: for Councillors; for Employees
• Registers of interests, gifts and hospitality Register of Interests - staff. Register of Gifts and Hospitality - staff. Notes for Councillors
• Whistleblowing Policy
• HR policies and procedures for recruitment
• HR policies and procedures for disciplinary action
• Regulation of Investigatory Powers
• Managers’ Guide for Responding to Suspected Fraud
• Fraud Investigation and Response Plans
• Anti Money Laundering Policy and Anti Money Laundering Procedures
• Benefits Investigation, Sanctions and Recovery Policies
• Fraud Risk Impact Assessment including Managers Guide to Fraud Risk
• Anti Fraud Strategy and Action Plan
• Internal Audit Annual Plan
• Participation in national fraud initiatives and networks
• Educating staff and members in fraud awareness by training and publicity

Adherence to the provisions set out in the various documents included in this framework will help to both reduce the risk of fraud and corruption and protect employees, members and those with whom we have dealings from unfounded allegations of fraud and corruption.

Last updated: 27 January 2011