Counter fraud and corruption strategy

6.1. The London Borough of Bromley aims to prevent fraud through maintaining a strong counter fraud culture, raising awareness of both fraud risks and counter fraud activity, undertaking proactive counter fraud initiatives and implementing a robust system of internal control.

6.2. Managers are responsible for implementing appropriate controls to manage fraud risks, including for both detection and prevention. Controls must be in place to prevent and detect fraud committed by employees and other people working on the council’s behalf as well as fraud committed by external agents. These controls could include requiring individuals and businesses to complete fraud declarations on application for grants, benefits or discounts, verification checks, authorisations and segregation of duties. On request, the Audit and Assurance Service can offer advice on the appropriateness of internal controls including during the design of new processes or policies. Managers must also ensure that they have arrangements in place, including appropriate management information, to test the effectiveness of fraud prevention measures and controls.

6.3. The London Borough of Bromley has a framework of policies that are intended to minimise fraud and corruption risks; key policies are listed. All officers and Members are expected to comply with the requirements of these policies.

• Values and Behaviours
• Whistleblowing Policy
• Anti-Bribery Policy
• Financial Regulations and Procedures
• Financial Regulations for Schools
• Contract Procedure Rules
• Anti-Money Laundering Policy
• Suite of Recruitment procedures
• Corporate Information Security Policy
• Code of Conduct for Councillors and Co-opted Members (Members only)
• Gifts and Hospitality Policy (Officers only)
• Register of Interests (Officers only)

6.4. The council will explore opportunities for financial savings from enhanced fraud detection and prevention. This will include better use of available technology and data analytics to prevent fraud.

Emergency situations

6.5. The council recognises that fraud risks may increase during emergencies. The council will anticipate emergency scenarios as part of the overarching fraud risk assessments, and consider in advance the fraud prevention measures that may be necessary during particular situations. In emergency scenarios, for example during the Covid-19 pandemic, the council will also follow any specific fraud prevention guidance from relevant authorities, including public sector counter fraud authorities. The council will consider fraud risks and mitigations as part of its response to emergencies, and in these situations, the Audit and Assurance service will prioritise resources for counter fraud advice.

6.6. A documented fraud risk assessment must be completed as soon as practicable whenever emergency processes for making payments or receiving income are set up (such as the Covid-19 grant funds). The Audit and Assurance service can provide support with fraud risk assessments. Once business as usual has resumed, or the new normal established, managers should review the effectiveness of fraud prevention measures.

Training and Awareness

6.7. Training and awareness are key to promoting a strong counter fraud culture and to preventing and detecting fraud. The council is committed to providing all employees with sufficient training to enable them to identify and report fraud in a timely manner. E-learning is being developed which will be mandatory for all staff, and additional face to face fraud awareness training can be provided in higher-risk areas on request. The council informs Members of their responsibilities at induction and reminds them of their responsibilities and updates them on developments regularly.

6.8. The Audit and Assurance service will periodically undertake fraud awareness campaigns. The service will also share relevant fraud alerts from, for example, the National Anti Fraud Network (NAFN) and Action Fraud, and specific case studies from other organisations to heighten risk and control awareness.

6.9. All managers will ensure that staff are properly inducted and trained in local procedures and controls designed for the prevention and detection of fraud.