For the Audit and Governance Committee to review and approve the updated Anti-Fraud, Bribery and Corruption Policy, the new Fraud Response Plan and Flowchart.

The Counter Fraud Manager (CFM) presented the report, the purpose of which was for the Audit and Governance Committee to review and approve the updated Anti-Fraud, Bribery and Corruption Policy, the new Fraud Response Plan and Flowchart.

The following principal points were noted.

·       The policy undergoes a review every three years, and it had been updated in line with the Council's corporate branding and the content itself had been streamlined to ensure that it was clear and concise.

·       The updated legislation within section 12 of the policy was highlighted, which included the new failure to prevent fraud offence which is being introduced on the 1st of September 2025.

·       The policy now incorporated the recently updated 6 strategic pillars to include deterrence and protect.

·       The fraud response plan had been separated from the policy to be a standalone document.

Following committee questions, it was noted.

1.     Concern was raised on paragraph 12.2 of the Anti-fraud, Bribery and Corruption Policy (appendix 1). The CFM explained that it is not feasible or expected that all organisations prevent every single case of fraud, but the expectation is to increase the onus on larger organisations specifically to ensure that they have got robust controls and considerations around how they manage the risk of fraud. Section 13 (taken from the Home Office guidance) outlined six bullet points that providing the council are comfortable assurances around those six criteria are in place, then the council are protecting themselves as an organisation against the new legislation.

2.     The Annual Fraud report presented to the committee normally in January provides the committee with detailed breakdowns and an overview on all counter fraud activity across the Council’s services throughout the previous calendar year and represents an up-to-date account of the work undertaken, including progress and outcomes aligned with the strategy and core objectives.

3.     The CFM was the only dedicated resource in the team and reported directly into the Section 151 officer who would take on his duties in his absence.

4.     The Head of Internal Audit explained that when an audit is undertaken, they always look for any potential fraud and if they did find something that would be reported straight to the CFM.

5.     Second home premiums were beingmonitored closely with the council tax and revenues department. A risk assessment was in place to ensure adequate controls are in place to try to detect and react to issues.

6.     Herefordshire Council had successfully completed the Cyber Assessment Framework (‘Get CAF Ready’) scheme and received a recognition grant award of £15,000 from Ministry of Housing, Communities and Local Government (MHCLG) for the good progress made and were now in a strong position ahead of the expected mandatory introduction in Summer 2026.

7.     The Cabinet Member Finance and Corporate Services felt the Council was in a good position and that Cabinet would be reviewing the corporate risks which included Cyber Security and providing an update on those in September.

RESOLVED

The committee approved the updated Anti-Fraud, Bribery and Corruption Policy and recommends for adoption by the cabinet member for finance.