For the committee to review and approve the updated Anti-Fraud, Bribery and Corruption Policy attached at Appendix A and consider recommendations for improvements.

The Counter Fraud Manager presented the updated Anti-Fraud, Bribery and Corruption Policy; the policy was provided in Appendix A to the report.  The following key points were highlighted:

i.             The policy had been brought into line with the council’s Counter Fraud and Corruption Strategy; the purpose of the policy was to provide a clear framework alongside the strategy.

ii.            The policy had been re-written, with attention drawn to the sections on ‘Tax Evasion’ (agenda page 150) which reflected the Criminal Finances Act 2017, ‘Reporting, Advice, Support’, and the ‘Fraud Response Plan’.

The key points of the discussion included:

1.           The accessibility of the document was welcomed.

2.           To avoid any potential for confusion about the quantification of high value/high risk area payments, it was suggested that paragraph 11.7 of the strategy (agenda page 151) be amended to read ‘In the council, reasonable due diligence is exercised when processing all transactions particularly high value/high risk area payments.’

3.           In relation to the section on ‘Training and Awareness’, the Vice-Chairperson questioned whether councillors should be required to complete annual fraud awareness training.  The Senior Lawyer noted that officers were required to undertake annual fraud awareness training in view of the delegated decisions made by officers.   A committee member suggested that the Members’ Development Working Group be invited to consider the most appropriate means to raise the awareness of councillors to the policy and the strategy.

4.           It was noted that the policy made references to other documents, e.g. the section on ‘Supporting Policies’ (agenda page 155), and some of these documents may only be accessible to internally employed staff.  It was requested that a link to the policy on the council’s website be provided in due course.

5.           Further to point 3 above and in response to a question about the completion of mandatory training by officers on ‘Fraud Awareness and Prevention 2021’, the Senior Lawyer advised that the deadline had been extended by two months.

6.           It was recommended that the inclusion of a section on intelligence sharing and collaboration should be included in the policy, as well as in the strategy.

7.           With attention drawn to the Fraud Response Plan flowchart (agenda page 157), a committee member noted that the Crown Prosecution Service would need to be involved between the ‘Management Decision’ and ‘Prosecution’, consequently it was recommended that reference should be made to ‘Fraud suspected?’ rather than to ‘Fraud?’ in Phase 3.  It was also recommended that the ‘Consider Lessons Learned’ step should apply to both successful and unsuccessful outcomes in Phase 4.

Resolved:      That

a)      The updated Anti-Fraud, Bribery and Corruption Policy, Appendix A to the report, has been reviewed and the committee makes the following recommendations to ensure its effectiveness:

·              Paragraph 11.7 of the report be reconsidered to remove reference to high value/high risk area payments;

·              That a section on intelligence sharing and collaboration be included in the policy;

·              In the Fraud Response Plan flowchart, reference should be made to ‘Fraud suspected?’ rather than ‘Fraud?’ in Phase 3; and

·              In the Fraud Response Plan flowchart, the ‘Consider Lessons Learned’ step should apply to both successful and unsuccessful outcomes in Phase 4.

b)      Subject to the above, the updated Anti-Fraud, Bribery and Corruption Policy be approved and be recommended for adoption by the Cabinet Member - Finance, Corporate Services and Planning.

Action(s):

Action 166:     The Members’ Development Working Group be invited to consider the most appropriate means to raise the awareness of councillors to the Anti-Fraud, Bribery and Corruption Policy and to the Counter Fraud and Corruption Strategy.

Action 167:     A link to the Anti-Fraud, Bribery and Corruption Policy on the council’s website be provided in due course.

Action 168:     That figures on the completion of mandatory training by officers on ‘Fraud Awareness and Prevention 2021’ be circulated after the relevant deadline.