Policy Statements
Culture
5.1 The Councils are determined that the culture and tone of the organisation will be, and is seen to be, one of openness, honesty and opposition to fraud, corruption or bribery.
5.2 The Councils are committed to discouraging, preventing and detecting fraud, corruption and bribery where attempted on, or from within, the Councils' organisation.
5.3 The Councils expect members and staff at all levels to be aware of the standards of conduct expected of them and the procedures designed to reduce the risk of fraud, corruption and bribery occurring.
5.4 Members and staff are responsible for their own conduct and compliance with this strategy and are required to comply with their respective codes of conduct.
5.5 There is an expectation and requirement that individuals, suppliers and organisations associated in whatever way with the Councils will act with integrity, and that members and Council staff will lead by example in these matters.
Members and Staff
5.6 Members and staff are positively encouraged to raise any concerns on fraud, corruption, and bribery matters normally, but not exclusively, through a Group Manager or other line manager. This they can do in the knowledge that such concerns will be treated in confidence and properly investigated. If necessary a route other than through a line manager may be used to raise such concerns, e.g. Internal Audit, Executive Directors, S.151 Officer or Monitoring Officer.
5.7 The Councils have drawn up a separate policy and procedure to deal with any area of concern that an employee may wish to bring to the attention of the management, the 'Confidential Reporting (Whistle Blowing) Policy'.
5.8 The Councils' Monitoring Officer needs to be informed of any actual or suspected breaches of the law or codes of practice. Regular formal meetings between the S.151 Officer, Monitoring Officer and related officers, an officer group known as the Statutory Officers Panel, discuss potential issues and the Group holds urgent meetings when suspected breaches of the law or codes of practice are identified. (See section 7 of this document relating to investigation).
5.9 The primary responsibility for maintaining sound arrangements to prevent and detect fraud, corruption and bribery rests with management. Any manager made aware of suspected fraud, corruption and bribery will adopt defined procedures by:
- Dealing promptly with the matter;
- Recording all evidence received;
- Ensuring that evidence is sound and adequately supported;
- Ensuring security of evidence collected;
- Notifying the s.151 Officer, and the Councils' Monitoring Officer; and
- Implementing Council disciplinary procedures were appropriate.
5.10 Any abuse of this process by knowingly raising unfounded and/or malicious allegations may be dealt with as a disciplinary matter.
5.11 The Councils can be expected to deal swiftly and thoroughly with any member or member of staff who defrauds or attempts to defraud the Council or who is corrupt. The Councils will be robust in dealing with financial malpractice.
Partner Organisations and Members of the Public
5.12 In addition, partner organisations or members of the public are also encouraged to report concerns through any of the above avenues. The principles and processes described in this Strategy and its Appendices, and the Councils' Confidential Reporting (Whistle Blowing) Policy, will be applied to any concerns formally reported by partner organisations or members of the public.
Monitoring
5.13 The S.151 Officer will monitor the effectiveness of all aspects of the arrangements for the anti fraud, corruption and bribery culture including the approach to investigations, success of sanctions and processes for recovering loss. On a risk basis, the S.151 Officer will make informed judgements about the levels of budgetary investment in work to counter fraud, corruption and bribery.
5.14 The Audit Committee's Terms of Reference requires them to monitor Council policies on confidential reporting, anti-fraud, anti-corruption and anti-bribery.
5.15 A regular report to the Committee by the Internal Auditor will inform Members of any suspected or proven fraud, corruption or bribery identified and the system changes required to ensure that the circumstances are not repeated.