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Anti-Fraud, Bribery and Corruption Policy

Reporting Fraud

4.1 Council employees and members mustreport any concerns they may have regarding fraud and corruption, whether it relates to dishonest behaviour by council employees, Councillors, contractors or by others. That action will be free from recrimination. Such concerns will be treated in confidence and will be properly investigated. In the first instance a member of staff should contact a senior manager within the line management structure.

However, if the member of staff considers the matter too serious or sensitive or inappropriate to raise within the line management structure then one of the following may be contacted - in person, by telephone or e-mail (marked confidential):

  • Chief Executive
  • Corporate Director of Resources & Deputy Chief Executive
  • Director of Finance & Procurement (S151 Officer)
  • SWAP Internal Audit Services
  • Monitoring Officer
  • Chair of Audit Committee

Concerns can also be raised directly to the SWAP Internal Audit Services Counter Fraud Team through their Confidential Reporting Line:

SWAP Confidential Reporting Line
Confidential helpline020 8142 8462
Confidential Emailconfidential@swapaudit.co.uk (opens new window)
SWAP Internal Audit Services: Contact us (opens new window)Report it online

4.2 All matters will be treated in confidence and an expressed wish not to reveal the identity of a complainant will be respected wherever possible. (Concerns expressed anonymously are much less powerful but will be considered by the council). Alternatively, any person with a concern may use the Council's Confidential Whistleblowing Policy or as an external contact point our external auditors, Grant Thornton UK LLP.

4.3 Councillors should normally report any concerns to the appropriate Corporate Leadership Team officer, the Chief Executive, the Corporate Director of Resources & Deputy Chief Executive, the Director of Finance & Procurement (S151 Officer) or the Monitoring Officer.

4.4 Where staff may be involved there are policies that set out the approach taken. The Council's Disciplinary Policy clearly identifies the following as gross misconduct:

  • Dishonesty, including theft and/or fraud, falsification of records or information, non-declaration of information.
  • Serious Data protection breaches, unauthorised disclosure of council documents or confidential information to others inside or outside the council
  • Misuse of an official position for personal gain

Only a Manager / Officer at Head of Service level or above, can dismiss an employee on the grounds of gross misconduct in accordance with HR policies and procedures.

4.5 An accusation of dishonest behaviour by a Member of the council should be referred to the Monitoring Officer for an assessment of whether this is likely to constitute a breach of the Members' Code of Conduct.

4.6 If a case involves action against a third party, any action to be taken will be agreed between the Director of Finance & Procurement (S151 Officer) and the Monitoring Officer, with advice sought from SWAP.

4.7 Where investigation reveals evidence of suspected criminal activity with regard to fraud, bribery and corruption the Director of Finance & Procurement (S151 officer) mustrefer the matter to the Police.  Where an employee is involved, the matter should be reported to the Director of HR&OD and the Head of Paid Service.

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