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AUDIT, GOVERNANCE & STANDARDS COMMITTEE

13 January 2020

 

Counter Fraud & Corruption Policy

 

Final Decision-Maker

Audit, Governance & Standards Committee

Lead Head of Service

Rich Clarke, Head of Audit Partnership

Lead Officer and Report Author

Rich Clarke, Head of Audit Partnership

Classification

Public

Wards affected

All

 

Executive Summary

 

This Committee recommended for approval a refreshed Counter Fraud & Corruption Policy on 15 January 2018 with a provision to review in two years. This report presents that review and largely retains the document as before, bar an addition setting out guidance for people who become involved in an investigation.

 

Purpose of Report

 

Recommendation

 

 

This report makes the following recommendations to this Committee:

1.   That the Policy & Resources Committee be recommended to approve the Counter Fraud & Corruption Policy.

 

 

 

Timetable

Meeting

Date

Audit, Governance & Standards Committee

13 January 2020

Policy & Resources Committee

(to be confirmed)



Counter Fraud & Corruption Policy

 

1.       CROSS-CUTTING ISSUES AND IMPLICATIONS

 

 

Issue

Implications

Sign-off

Impact on Corporate Priorities

We do not expect the recommendations will by themselves materially affect achievement of corporate priorities. However, they will support the Councilís overall achievement of its aims by helping enhance the quality of corporate governance.

Rich Clarke
Head of Audit Partnership
2 January 2020

 

Cross Cutting Objectives

Risk Management

See below in report.

 

Financial

The proposals set out are all within already approved budgetary headings and so need no new funding. It is consistent with the principles of good governance to have in place a robust Counter Fraud & Corruption Policy.

Staffing

We will deliver the recommendations with our current staffing. The Mid Kent Audit team includes 3 officers with relevant professional qualifications, and we have access to further trained individuals in other teams and through call-off contractor arrangements. We will keep the required level of experience and expertise under review.

Legal

The Council is free to set out policies on how it will address economic crime risk and incidents. The actions set out in the policy are within the Councilís powers, which include investigating reports and referring for prosecution.

Privacy and Data Protection

The Policy includes references to how we will use information to help identify and address risks of economic crime. The Policy also sets out that we will share information with others where useful and efficient.

 

We will undertake all data sharing in line with applicable laws and policies.

Equalities

The recommendation does not propose a change in service that requires an equalities impact assessment.

Public Health

No relevant impact

Crime and Disorder

The Policy aims to improve the Councilís approach in dealing with specific forms of crime.

Procurement

The Policy does not require any immediate procurement. Any future procurement exercises for products or services that would enhance our approach will be undertaken in line with applicable Standing Orders.

 

 

2.††††† INTRODUCTION AND BACKGROUND

 

2.1†††† This Committee recommended for approval a refreshed Counter Fraud & Corruption Policy on 15 January 2018, modelled around CIPFAís Counter Fraud Code of Practice. In keeping with good practice, that policy proposed a review cycle whereby it would come back to Members for re-consideration every two years.

 

2.2†††† The current document, attached, largely retains the Policy as approved in 2018 reflecting the continued good practice set out by CIPFA. It has some cosmetic modifications (including addition of further Maidstone BC branding) and minor text clarifications. However, the only modification of note is towards the end of the Policy (paragraphs 45-47) of additional guidance to those who may become involved in investigations.

 

2.3†††† This addition springs from experience of the audit team conducting investigations in the past two years and incorporates in the standard policy key tenets of guidance that has hitherto been provided individually during investigations.

 

 

 

3.   AVAILABLE OPTIONS

 

3.1     Members could choose to reject these additions and retain the Policy as approved in January 2018.

 

 

4.        PREFERRED OPTION AND REASONS FOR RECOMMENDATIONS

 

4.1     We recommend approval of the Policy at Appendix 1. The Policy remains consistent with good practice as set out by CIPFA, and the addition of guidance for those subject to investigations will help standardise information previously provided case-by-case and make it available to people more generally.

 

 

 


 

5.       RISK

5.1† We are satisfied that the risks associated are within the Councilís risk appetite and will be managed as per the Risk Management Policy.

 

6.       CONSULTATION RESULTS AND PREVIOUS COMMITTEE FEEDBACK

 

6.1     The original Policy in 2018 underwent consultation with the Councilís Corporate and Wider Leadership Teams. In compiling this update we have consulted with CIPFA as members of their Counter Fraud Network to seek any new developments for incorporation, but were advised of no new significant updates for inclusion.

 

 

7.       NEXT STEPS: COMMUNICATION AND IMPLEMENTATION OF THE DECISION

 

7.1    Once agreed, the Policy will replace the previous version available on the Councilís intranet.

 

 

8.        REPORT APPENDICES

 

         Appendix 1: Counter Fraud & Corruption Policy

 

 

9.        BACKGROUND PAPERS

 

CIPFA Code of Practice as per previous papers on 15 January 2018.