Counter fraud and corruption strategy

• Setting the council’s values, behaviours and standards.
• Ensuring there are effective governance arrangements for counter fraud in place.

The Director of Finance has overall responsibility for counter fraud arrangements within the council. This includes:

• Ensuring that there are robust controls in place to manage fraud risks and prevent and detect fraud and corruption.
• Ensuring that there is an effective counter fraud and corruption strategy in place.
• Ensuring that there are sufficient resources to deliver the counter fraud strategy.
• Championing and promoting counter fraud arrangements at Chief Officer Executive.

• Advising Councillors and Officers on ethical issues, standards and powers to ensure that the council operates within the law and statutory Codes of Practice.
• Owning the Anti-Bribery policy and ensuring that all allegations of bribery are dealt with appropriately.

• Communication and endorsement of the council’s policies and approach to preventing fraud.
• Commitment to training and resourcing.
• Leading by example and fostering an open culture, where staff feel empowered to speak up if they encounter fraudulent practices.
• Approving the fraud risk assessments for their Departments and as a whole, ensuring that these are regularly reviewed and that identified actions are implemented.

• Developing and implementing the Counter Fraud and Corruption Strategy and associated counter fraud plans.
• Ensuring that all suspected or reported irregularities are dealt with promptly and appropriately.
• Managing contractual arrangements for fraud investigation
• Maintaining the council’s Whistleblowing policy and arrangements
• Assessing annually whether the level of resource invested to counter fraud and corruption is proportionate for the level of risk

All senior managers are responsible for:

• Embedding a strong counter fraud and corruption culture in line with the council’s objectives, values and behaviours.
• Promoting fraud and corruption awareness and an open and transparent culture where staff feel empowered to report suspicions of wrong-doing.
• Management of fraud and corruption risks.
• Ensuring that all suspected or reported irregularities are immediately referred to Internal Audit.
• Ensuring that there are mechanisms in place within their service areas to assess fraud, corruption and theft risks and to reduce these risks by implementing strong internal controls.

Audit and Risk Management Committee oversee counter fraud arrangements in the council. This includes:

• Monitoring the Counter Fraud and Corruption strategy, actions and resources.
• Monitoring the effectiveness of counter fraud arrangements including assessment of fraud risks, actions and responses.

The Chair of Audit and Risk Management Committee also acts as a champion for whistleblowing arrangements at Member level and is a nominated contact within the Whistleblowing policy.

All elected Members are responsible for:

• Leading by example and acting in the public interest at all times.
• Complying with the Member Code of Conduct and other council policies and procedures including Financial Regulations.
• Maintaining an awareness of the possibility of fraud, corruption and theft, reporting any genuine concerns accordingly.

All staff have a role to play in combatting fraud. This includes:

• Acting in the public interest at all times, and in accordance with the council’s values and behaviours.
• Being alert to the possibility of fraud and corruption.
• Reporting any genuine concerns in line with this strategy or the Whistleblowing policy.
• Complying with council policies and procedures that are designed to reduce the risks of fraud and corruption (see section 6.3).
• Declaring any potential financial or non financial interests that may conflict with the council’s interests.