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Corporate Anti-Fraud and Corruption Strategy 

DRAFT - Version 2_- December 2019 
(with Tracked Changes) 

Flintshire County Council 

Corporate Anti-Fraud And Corruption Strategy 



Policy Statement 









Adopting the Right Strategy 



Accurately Identifying the Risks 



Creating and Maintaining a Strong Structure 






Taking Actions to Tackle the Problem 



Defining Success 



Awareness and Training 





Policy Owners 

Internal Audit Manaqer 

Date Implemented 

April 2007 

Date Last Reviewed 

November 2014 

Current Review: 

Approved bv Audit Committee (Version 1.7) 

February 2019 

Approved bv Constitution and Democratic Services 

June 2019 

Committee (Version 1.8) 

Approved bv Council (Version 2) 

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Flintshire County Council 

Corporate Anti-Fraud And Corruption Strategy 

1. Policy Statement 

• Flintshire County Council (the Council) has a zero tolerance approach to 
fraud, bribery and corruption. This Policy outlines how the Council 
delivers an effective approach to managing the risk of fraud and 

• The Council is committed to this policy and to maintaining high ethical 

• The Council is committed to the prevention, deterrence, detection and 
investigation of all forms of fraud or corruption within or against all its 

• The Council will support prosecutions or apply other relevant sanctions to 
those who commit acts of fraud or corruption. 

• The Council encourages anyone who suspects fraud and corruption to 
report it, and the Council will support anyone who does this. 

2. Introduction 

2.1 Flintshire County Council has a workforce of around 7,000 6,000 and 
spends in excess of £ 400m 25Q a year. The Council commissions and 
provides a wide range of services to individuals and households and 
works with many other private, public and voluntary sector organisations. 

2.2 The size and nature of the Council’s services means that there is an 
ongoing risk of loss due to fraud and corruption from both internal and 
external sources. The Council is continuously developing anti-fraud 
initiatives and remains committed to: 

• The prevention, detection, deterring, investigation and correcting all 
forms of fraud and corruption, whether these are attempted from 
within or external to the organisation. 

• Minimising losses caused by fraud, corruption and breaches of 

• Embedding management of fraud risk throughout the organisation. 

• Increasing awareness of counter-fraud responsibilities at all levels 
within and outside the Council. 

2.3 The Council’s commitment to the protection of public funds against fraud 
and corruption is set out in this strategy and supporting policies. 

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Corporate Anti-Fraud And Corruption Strategy 

2.4 The strategy is structured to reflect the CIPFA code of practice on 
Managing the Risk of Fraud and Corruption. The five key elements of the 
code are to: 

• Acknowledge the responsibility of the governing body for countering 
fraud and corruption 

• Identify the fraud and corruption risks 

• Develop an appropriate counter fraud and corruption strategy 

• Provide resources to implement the strategy 

• Take action in response to fraud and corruption 

2.5 The Strategy applies to: 

• AII Qffic e rs and to -aft employees (including centrally employed 
teachers) of Flintshire County Council (as defined by the Employment 

Rights Act) and is commended to School Governing Bodies and other 

associated employers as best practice. 

• All Members of the Council 

• _ Partner Organisations , including Aura and NEWydd 

• Third Party individuals such as Partners, Consultancy, Suppliers, 

Contractors , volunteers and employees of Council Suppliers and 
Contractors who are employed to deliver goods / services to the 


• General Public Counci l Supp l i e rs, Contractors and Consu l tants 

»_ G e n e ra l Pub l ic 

2.6 The Council requires all individuals and organisations., with whom it deals 
in any capacity to behave toward the Council with integrity and without 
intent or actions aoT involvino fraud or corruption. Members of the public 
are encouraged to report any concerns which they may have. 

2.7 The Strategy has the full support of Members and the Council’s Senior 
Accountable Officers. It is approved by Audit Committee and The 

2.8 This policy should be read in conjunction with the Council’s 

Whistleblowing Policy and the Fraud & Irregularity Response Plan. 


3.1 Fraud: P For the purpose of this policy refers to where an individual has 
undertaken, or intends to undertake, actions in order to obtain gain for 

him/herself or another, or cause loss to another, or expose another to risk 

of loss. raud is wh e n trick e ry is us e d to gain a dishon e st advantag e which 

is oft e n f i nanc i a l ov e r anoth e r p e rson or organisation. 

3.2 The Fraud Act 2006 came into force on 15 th January 2007. It created a 
single offence of fraud which can be committed in three separate ways: 

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Corporate Anti-Fraud And Corruption Strategy 

• Fraud by false representation; 

• Fraud by failing to disclose information where there is a legal duty to 
do so ; and 

• Fraud by abuse of position. 

I - our new 0TT@nc@s wgt© ciiso cr@3.t©0! 

•— Poss e ssion of artic le s for us e in fraud 
*— Making or supp l ying artic le s for us e in fraud 
*— Obtaining s e rvic e s dishon e st l y 
*— Participating in fraudu le nt busin e ss 

3.3 Theft: “A person shall be guilty of theft if he /she dishonestly appropriates 
property belonging to another with the intention of permanently depriving 
the other of it” (Theft Act 1968). 

3.4 Corruption: For the purpose of this policy corruption refers to an 
individual who has given or obtained advantage through means which are 

illegitimate, immoral, and/or inconsistent with their duty to the Authority or 

the rights of others. Examples include accepting bribes or incentives 

during procurement processes, seeking to influence others orthrouqh the 

The Counci l has d e fin e d corruption as “Th e offeringjcf, giving, soliciting or 
acceptance of an inducement or reward, to inf l u e nc e oth e rs.., --w. 

3.5 Irregularity: Any administrative or financial mistrust that comes about 

either by act or omission. 

The Bribery Act 2010 cr e at e d creates criminal offences for any individual 
who either offers or receives a financial or other advantage intending the 
advantage to be rewarded by the improper performance of a function or 
activity. The Act also cr e at e d creates an offence of directly or indirectly 
offering, promising or giving a bribe to a foreign public official so as to 
influence the actions of the for e ign pub l ic said official. Any individual found 
guilty of any of these offences is liable to imprisonment for up to a 
maximum period of 10 years. 

— Cyber Cr i m e : this occurs wh e r e any crimina l act dea l ing with comput e rs, 
n e tworks ov e r th e int e rn e t. 

3.6 Comput e r Fraud: occurs wh e r e informat i on t e chno l ogy e qu i pm e nt has 
b e en us e d to manipu l at e programm e s or data dishon e st l y (for e xamp le , by 
a l t e ring, substituting or d e stroying r e cords or cr e at i ng spurious r e cords), or 
wh e r e th e us e of an I T syst e m was a mat e r i a l factor i n th e p e rp e tration of 
fraud. D e ta ile d with th e Comput e r Misus e Act 1990. 

4. Adopting the Right Strategy 

4.1 To reduce losses to fraud and corruption to an absolute minimum, a 
strategic approach is implemented encompassing a clear remit covering 
all areas of fraud and corruption affecting the orqanisation Council . 

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Corporate Anti-Fraud And Corruption Strategy 

4.2 The approach adopted by the organisation Council involves a three stage 

1) Deter by having a culture within the organisation Council which 

deters the committing of fraud. 

2) Prevent by having measures in place to help prevent fraud 


3) Detect by having measures in place to detect fraud should it 


The approach is covered in more detail in section 8 of this document. 

4.3 The full range of actions actions for each stage of the process int e grat e d 
actions should be taken forward with the focus on outcomes (i.e. reduced 
losses) rather than activity (i.e. number of investigations). 

5. Accurately Identifying the Risk of Fraud and Corruption 

5.1 Fraud and corruption risks are considered as part of the Council’s 
strategic risk management arrangements. 

5.2 The nature and scale of losses to fraud and corruption are identified 
where they can be practically established. By measuring the scale of 
losses, and learning from where they are detected, knowledge is gained 
of where controls within systems should be strengthened or introduced to 
reduce the risk of fraud and corruption in the future. 

6. Creating and Maintaining a Strong Structure 

6.1 The Council is committed to the Nolan Principles of Sstandards in 
Ppublic Ltife, namely objectivity, openness, leadership, accountability, 
honesty, selflessness and integrity. High ethical standards should be 
adhered to and be demonstrated in all the Council’s actions and 

6.2 The Council’s commitment to the highest standard of governance is 
supported by a strong framework including the Constitution, Code of 
Corporate Governance, Member and Officer’s Codes of Conduct and 
specific counter fraud policies e.g. Whistleblowing Policy T and the Anti- 
Money Laundering Policy. The Annual Governance Statement includes 
reference to the measures taken to counter fraud and corruption. 

6.3 The Council expects elected members and all offic e rs employees to lead 
by example in demonstrating support for anti-fraud and corruption 

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Corporate Anti-Fraud And Corruption Strategy 

measures by adhering to rules and regulations, and that all practices and 
operating procedures are beyond reproach. 

6.4 Within the County Council those charged with countering fraud and 
corruption have the appropriate authority to pursue their remit effectively. 
In order for the Council to effectively deal with allegations of fraud those 
charged with investigating matters must receive full support from all 
offic e rs employees and members. 

6.5 It is the responsibility of Service Teams and Senior Accountable Officers 
manag e m e nt’s r e sponsibi l ity to establish sound systems of internal 
controls in order to prevent and detect fraud, and d e s i gn e d to reduce the 
risk posed by fraud within service areas. The Authority has a zero 
tolerance to acts of fraud and corruption. 

6.6 The Accounts and Audit (Wales) Regulations require every local authority 
to maintain adequate and effective Internal Audit Service . 

6.7 One of the roles of Internal Audit is to promote anti-fraud and corruption T 
best practice and to ensure management has effective systems in place 
to detect and prevent corrupt practices. The Internal Audit team are 
properly trained to gain the appropriate knowledge and skills in respect of 
fraud awareness, prevention, detection and investigation. In Flintshire a 
clear mandate has been provided to Internal Audit to investigate potential 
fraud and irregularities and this is specified in the Audit Charter and the 
Financial Procedure Rules (4.3). 

6.8 Where appropriate, tThe Council will co-operate with other local 
authorities and public sector bodies in the prevention, detection and 
investigation of fraud and corruption e.g. participation in the National 
Fraud Initiative and liaison with the Police. 


Individual / Group 

Role / Responsibility 

Chief Executive 

Ultimately accountable for the effectiveness of the Council’s 
arrangements for countering fraud and corruption. 

Chief Officer 
(Monitoring Officer) 

• Advise members and officers employees on ethical 
issues, standards and powers to ensure that the Council 
operates within the law and statutory Codes of Practice. 

• Prepare a report to Council where it appears that the 
authority has or is about to do anything which would be 
in contravention of the law or which would constitute 

Corporate Finance 
Manager (Section 151 

• Ensure proper arrangements are made for the Council’s 
financial affairs. 

• Maintain an adequately resourced internal audit team. 

Chief Officer Team 

Overseeing the corporate approach to counter-fraud activity, 
setting the tone to embed a culture of high standards and 

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Senior Accountable 

• Notify Internal Audit of all suspected fraud or 
corruption incidents in their area - see Fraud and 
Irregularity Response Plan, para 6§. 

• Ensuring that adequate systems of internal control exist 
within their areas of responsibility, and that such 
controls, checks and supervision operate in such a way 
as to prevent or detect fraudulent activity. 

• Regularly need to assess the types of risks and scope 
for potential fraud associated with the operations in their 

• Ensure that officers employees receive fraud awareness 
training. The extent of this will depend on the work that 
individual officers carry out. 

• Remind officers employees who are an integral part of 
the control framework of fraud and risk issues. 

• Ensure this Strategy and the Fraud Response Plan are 
available to all officersemplovees. 


• A duty to act if they believe there is a possibility of 
fraud or corruption taking place or the rules are 
being breached - see Fraud and Irregularity 
Response Plan para 3. 

• Their own conduct and for contributing towards the 
safeguarding of corporate standards (including 
declaration of interest, private working, whistleblowing, 

• Acting with propriety in the use of official resources and 
in the handling and use of corporate funds. 

• Be alert to any financial transactions that may suggest 
money laundering. 

Internal Audit 

• Providing a pro-active corporate anti-fraud function to 
facilitate the identification and subsequent investigation 
of alleged acts of fraud or corruption. 

• Completion of any and all investigations of fraud and 
corruption that do not fall within the remit of other 
investigative bodies, such as Housing Benefit. 

• Receiving and reviewing notifications of all frauds 
reported within the Council and analysing fraud risk. 

• Making appropriate arrangements to co-ordinate the 
Council’s work on the National Fraud Initiative. 

• Undertake internal data matching across Council 

• Reporting to and liaising with the local police on 
individual cases. 

• Provide reports to the Audit Committee on incidents of 
fraud and corruption. 

• Issuing guidance to members and management in 
relation to fraud and corruption related legislation and 

• Provide advice and guidance on internal controls to 
prevent or detect fraud or corruption. 

• Promoting fraud awareness and training. 

• Acting as the Council’s consultant on issues of fraud and 

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External Audit 

Considering if the Council has adequate arrangements in 
place to prevent and detect fraud and corruption. 

Trade Unions 

• Notifvina Officers the appropriate individuals if thev 
believe there is a possibility of fraud or corruption 
taking place or the rules are being breached, see 
Fraud and Irregularity Response Plan para 4. 

• Support their members throughout the process. 


• Notifvina the appropriate individuals Officers if thev 
believe there is a possibility of fraud or corruption 
taking place or the rules are being breached, see 
Fraud and Irregularity Response Plan para 5. 

• Responsible for their own conduct. 

• Contributing towards the safeguarding of corporate 
standards, as detailed in the Members Code of Conduct. 

Audit Committee 

• Reviewing and monitoring policies for preventing and 
detecting fraud. 

• Reviewing reports relating to fraud from internal and 
external auditors. 

Third Partv 

Individuals - Partners, 
Suppliers, volunteers. 
Contractors (and 
employees of), 
Consultants and the 

To be aware of the possibility of fraud and corruption within 
their organisation or against the Council and report any 
genuine concerns / suspicions. 

8. Taking Action to Tackle the Problem 


8.1 The Council will publicise its counter fraud measures using all available 
means e.g. the press, newsletters, the Infonet and internet. 

8.2 Publicised information makes offic e rs the workforces aware that fraud 
and corruption are serious offences and that they may face disciplinary 
action if there is evidence that they have been involved in these activities. 

8.3 The Authority has a suite of policies and procedures in place to manage 
the risk of fraud and corruption which are^: 

• Corporate Anti-Fraud and Corruption Strategy 

• Fraud and Irregularity Response Plan 

• Whistleblowing Policy 

• Ant i- Brib e ry Po li cy 

• Anti-Money Laundering Policy 

8.4 Where fraud and corruption is proved, and the Council has suffered a 
financial loss, the Council will seek to recover the full value of any loss. 

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In some cases., this may involve civil proceedings being instigated 
through the courts. As a deterrent to others the Council will seek to 
publicise such cases. 


8.5 Managers at all levels within the County Council have a responsibility for 
the prevention of fraud and corruption (within their own remit) and for 
implementing appropriate strategies to minimise the risk effectively. Such 
strategies include promoting fraud awareness, assessing compliance with 
Council policies (e.g. Financial Regulations) and ensuring sufficient levels 
of internal control are maintained within systems and procedures. 

8.6 The internal audit plan includes time for audit involvement in the 
development of new systems. Involvement at this stage should help to 
ensure that controls are designed into the systems to help prevent the 
risk of fraud and corruption. The risk based annual plan also reviews the 
internal control framework of the Authority , this is risk bas e d and includes 
reviews of all high risk areas of operation- where the potential for fraud is 
included as part of the review. 


8.7 Managers play a key role in ensuring that systems and processes are in 
place to detect fraudulent activity. 

8.8 In many cases, the diligence of offic e rs individuals and the alertness and 
good citizenship of the public at large detect acts of fraud or corruption. 
Fraud and corruption may also be discovered by Internal Audit during 
routine audits, pro-active fraud audits or through the use of data 
matching. Frauds are also detected as a result of the Council’s 
participation in the National Fraud Initiative exercise. 

8.9 Offic e rs Employees , elected members and external stakeholders 
(including third party individuals) are expected to report suspected fraud 
or corruption in accordance with Council’s Financial Regulations and the 
Counci l ’s Whistleblowing proc e dur e s policy . 


8.10 Reporting suspected cases of fraud and corruption by the above means 
will ensure that all reported incidents are considered by Internal Audit in 
accordance with the Fraud and Irregularity Response Plan. All referrals 
are logged and assessed with timescales being agreed for completion of 
the investigation taking into account any future loss of evidence or funds. 

8.11 Not all referrals are fraud related and the investigation may be 
undertaken by departmental management or appointed investigating 
officers for cases of misconduct. 

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8.12 During the investigation the Investigating Officer will contact any other 
relevant parties e.g. the Monitoring Officer, People and Resources or the 
Police, to ensure all allegations and evidence are properly investigated 
and reported upon. When referrals are passed to the Police, the Crown 
Prosecution Service will determine whether a prosecution will be pursued. 

8.13 Internal Audit investigation reports identify the specific control 
weaknesses which were present at the time of the fraud and allowed it to 
be committed. Actions required to address these weaknesses and 
strengthen the control environment are included within investigation 
reports. Actions are graded depending upon their severity and the 
manager responsible must complete an action plan detailing dates for 
implementation and officer responsible. 

8.14 Where necessary, the Council’s Disciplinary policy will be used to 
facilitate a thorough investigation of any allegations of improper behaviour 
by offic e rs employees . The decision to invoke the Disciplinary policy will 
be a consideration of Chief Officers and P e op le and R e sourc e s Senior 
Manager, Human Resources & Organisational Development . 

8.15 To prevent misuse of the investigation process, someone who maliciously 
raises a matter they know is untrue may be subject to disciplinary 
action fwh e r e app li cab le} . 

Sanctions and Redress 

8.16 Where fraud or corruption has been identified the Council will recover any 
losses (where applicable) and prosecute or apply other sanctions as 
detailed within the Fraud Response Plan. Sanctions will be applied in a 
comprehensive, consistent and proportionate manner. Examples of the 
type of sanctions that could be considered are^ disciplinary action 
(against offic e rs employees) and/or civil and criminal action. 

8.17 Redress will be applied in accordance with the Investigation Outcome 
(Recovery and Sanctions) R e cov e ry of Loss e s section detailed in Fraud 
and Irregularity Response Plan. Rates of recovery will be monitored as 
part of the quality process. 

9. Defining Success 

9.1 An nually annua l r e port wi ll b e pr e s e nt e d to the Audit Committee will be 
informed on the performance against this strategy, this forms part of the 
Internal Audit annual report. 

10. Awareness and Training 

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10.1 Training and guidance are vital to maintaining the effectiveness of the 
Anti-Ffraud and Corruption Strategy. The Council supports induction and 
work related training and will ensure that fraud awareness training is 
provided to all Members , Senior Accountable Officers and the workforce 
and S e nior Manag e rs of the Council. 

10.2 Offic e rs The within Internal Audit team will receive specific training to 
ensure compliance with professional standards and relevant legislation. 

10.3 In order to raise awareness of this strategy,, and fraud and corruption in 
general, the Council will arrange periodic publicity campaigns and will 
issue advice encouraging fraud awareness. 


11.1 Flintshire County Council has in place a clear framework of systems and 
procedures to deter, prevent, detect and investigate fraud and corruption. 

11.2 The Council will monitor performance of the Anti Fraud and Corruption 
Strategy through regular reports submitted to the Audit Committee. The 
Audit Manager will, in addition, keep this policy under review in order to 
take account of any changes in Council policy and government 

11.3 Related policies such as Whistleblowing Policy and the Fraud Response 
Plan can be found on the Council’s Website and the Infonet. 

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