To consider the proposed corporate strategy for countering fraud and corruption.

The Committee considered a report which set out the revised corporate strategy for countering fraud and corruption.

A copy of the draft Policy Statement and Strategy was attached at Appendix A to the officer’s report.

Points and comments included:

·         The present Strategy had been approved in 2012 so an update was required.  The update was also an action point within the Annual Governance Statement.

·         The new Statement adhered to the Chartered Institute of Public Finance and Accountancy (CIPFA) Code of Practice on Managing the Risk of Fraud and Corruption 2014.

·         It was important for any person supporting the delivery of the Council’s services to have a good, general, awareness of the possibility of fraud in their area, what action the Council took to prevent fraud and corruption, what to do if they had concerns and how investigations were carried out.

·         The most significant change involved Internal Audit taking on the responsibility to undertake financial crime investigations to a criminal standard in order to pursue prosecutions without the need to involve the Police or Crown Prosecution Service.  The approach taken would be determined on a case-by-case basis.  The Committee noted that this approach was increasingly used by local authorities and reflected good practice.

·         A Member welcomed the draft Strategy and requested that details be shared with the Police through the nominated Liaison Officer.

·         The Chairman sought clarification on what determined civil or criminal action.  In response the Head of Internal audit and Risk explained that each case would be considered on its individual merits.  Key legal, human resources and audit experts would consider the issue at the beginning of an investigation.

·         A Member referred to the recommended delegation of authority to the Director of Resources to make minor amendments to the Strategy as necessary.  He queried at what point an amendment went beyond ‘minor’.  In response the Director of Resources stated that this was difficult to define and it was a matter of judgement that had been delegated to him to decide.  The Committee concurred with a suggestion that the recommendation be amended so that delegation took place in consultation with the Chairman of the Committee.

·         A Member raised the possible issue of resource implications arising from new responsibility for financial crime investigations.  The Head of Internal Audit and Risk stated that no resource issues currently existed and it would be difficult to estimate any future impact.  He added that a degree of flexibility would meet demand though the matter would be re-examined if there was a major increase in the demand for officer capacity.

·         In response to a query by the Chairman the Head of Internal Audit and Risk stated that, historically, there had been quite low levels of fraud and corruption within the Council.  Three cases had occurred over the last year but all had been relatively minor.

·         A Member queried what levels should be expected.  In response the Head of Internal Audit and Risk stated that CIPFA produced an annual benchmark and published documents on fraud and corruption.  He reiterated that, in his experience, the levels of fraud and corruption at the Council were at a low level.

·         A Member suggested possible areas of fraud and corruption including the licensing of mobile homes.  The Director of Resources explained that a team within the Community Services Directorate dealt with licensing but acknowledged that the area was one which could be considered.

RESOLVED

1          that the draft Anti-Fraud and Corruption Policy Statement and Strategy be approved.

2          that authority be delegated to the Director of Resources, in consultation with the Chairman of the Audit Committee, to make minor amendments to the Anti-Fraud and Corruption Policy Statement and Strategy as necessary.