Policy Anti-fraud, theft and corruption policy

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3. Specific policy areas

The Council’s Anti-Fraud, Theft and Corruption Policy is based on a series of comprehensive and inter-related procedures designed to frustrate any attempted fraudulent or corrupt act. These cover: 

  • Culture
  • Prevention
  • Detection and Investigation
  • Deterrence
  • Response
  • Training
  • Whistleblowing
  • Bribery 

There is also a high degree of external scrutiny of Council business by a variety of bodies, including:

  • Local Government Ombudsman
  • Audit Commission
  • Central Government Departments and Parliamentary Committees
  • Her Majesty’s Revenues and Customs (HMRC)
  • Inland Revenue
  • Department of Work and Pensions (DWP)
  • The Surveillance Commissioner
  • The Information Commissioner

These bodies are important in highlighting any areas where improvements can be made. In addition, the External Auditor’s statutory duties include ensuring that the Council has in place adequate arrangements for the prevention and detection of fraud and corruption. The Council is fully committed to implementing changes to working practices that any of these bodies identify as necessary to improve our controls. Finally, the Council’s internal auditors (SWAP) have an important role to play in monitoring the Council’s control environment. 

For the purposes of the policy, Fraud and Corruption are defined as:

Fraud – A deliberate deception to secure unfair or unlawful gain or deprive a victim of a legal right including the intentional distortion of financial statements or other records by anyone internal or external to the organisation which is carried out to conceal the misappropriation of assets or otherwise for gain. 

Corruption - The offering, giving, soliciting or acceptance of an inducement or reward which may influence the action of any person. 

This policy also covers the failure to disclose an interest in order to gain financial or other pecuniary gain.

When this policy has been published and will be reviewed

Policy published 18 November 2018 (due for review by 1 September 2022)