Agenda Item No.











The Committee's approval was sought in regard to an updated and revised Anti-Fraud and Bribery Policy. 


In referring to the report the Head of Accountancy and Resource Management indicated that the revised Policy summarised the Council's position with regard to fraud and corruption, building on the content of a number of corporate policy statements incorporated in the Council's Constitution, including the Members' Code of Conduct; Officers' Code of Conduct; Whistleblowing Policy; Financial Regulations and Contract Standing Orders.  He indicated that it was imperative that Anti-Fraud Policies reflect the 'tone at the top' of an organisation making it clear that fraud and corruption would not be tolerated.  In addition, he referred to the updated Anti-Fraud and Bribery Policy which was attached at Appendix A to the report and referred to specific elements of the Policy in particular relating to the following areas:


·                    culture

·                    prevention

·                    detection and investigation

·                    awareness and training.


In referring to specifics of the Policy the Head of Accountancy and Resource Management indicated that there was a greater emphasis on employees of all grades at all levels to lead by example in matters relating to fraud and bribery.  Employees were a vital element of the Council's stance on fraud and bribery and as such staff were encouraged and were expected to raise any concerns that they may have on such issues and where they were associated with Council activities.  He went on to indicate that the Council's stance regarding such matters in all instances involved the police.


His attention then turned to the importance of raising staff awareness in regard to anti-fraud and corruption and to this end appropriate training was provided as part of the Council's Induction arrangements for new employees, in addition to the Internal Audit Section which offered tailor made programmes in fraud awareness training for staff.  He also alluded to web based training modules being available on the Council's StaffNet.


Finally, he indicated that the arrangements as set out in the Policy signalled a move towards greater prevention with senior managers being made responsible for ensuring that employees were aware of their role they were expected to play in the Council's framework of internal control e.g. through induction and training courses, procedure manuals, intranet, internet etc.  He reminded the Committee that the Council regularly reviewed its Standing Orders and Financial Regulations to ensure that appropriate arrangements were in place in regard to the duty on all Councillors and employees to act in accordance with best practice when dealing with the affairs of the Council. 


At this juncture, brief discussion took place on current safeguarding measures in place to protect the Council's interests, fraud detection rates and arrangements in place to allow employees to raise issues which fell under the auspices of the Policy and other policies of the Council.


Having regard to the above and related issues it was


RECOMMENDED - T H A T the revised Anti-Fraud and Bribery Policy as set out in Appendix A to the report be endorsed and referred to Cabinet for adoption.


Reason for recommendation


To agree an updated and revised Policy prior to the matter being referred to Cabinet for approval.”





Attached as Appendix - Report to Audit Committee: 19th September, 2011