Our approach to tackling fraud, bribery and theft

In order to minimise the risk of fraud, bribery and theft, we adopt an approach that is designed to improve both prevention and deterrence.

Risk assessment

Our Internal Audit team maintains a fraud, bribery and theft risk assessment and risk register to identify where our most significant risks lie. The register will be regularly updated to take into account emerging risks identified by fraud investigations, intelligence identified internally and by external organisations, and changes to our processes. Proactive anti-fraud, bribery and theft work will be targeted at the most significant risks facing us.

Developing and maintaining an anti-fraud, bribery and theft culture

We seek to maintain a culture which acknowledges its fraud bribery and theft risks, the processes to be adopted in the event of fraud and publicising the results of fraud investigations. Resources have been identified within our Internal Audit function to undertake and support this work.

Internal Audit is responsible for developing and implementing a fraud, bribery and theft awareness plan, giving consideration to the varying needs of elected councillors, staff (including new joiners), contractors and the public served by us to be aware of the risks faced.

Officers responsible for procuring services from suppliers must consider what measures should be put in place to ensure an appropriate level of awareness of this policy within suppliers’ employees. Advice should be sought from Internal Audit if in doubt.

Prevention

We are committed to preventing fraud, bribery and theft through sound governance, internal control and robust employee vetting. The responsibility for implementing adequate internal controls rests with management.

We have developed and are committed to systems and procedures which incorporate efficient and effective internal controls and which include adequate separation of duties. Service managers are required to ensure that such controls, including those in a computerised environment, are properly maintained and documented. When existing policies and procedures are being updated, or new processes introduced, advice from Internal Audit should be sought to ensure that the risk of fraud, bribery and theft is minimised.

Managers are expected to consider their risks on a regular basis and adapt the control systems as appropriate. Internal Audit can assist management in this process and advise on preventative controls during both routine work and following investigations where control weaknesses have been identified. Managers are expected to strengthen existing controls where weaknesses have been identified.

Effective steps must be taken at the recruitment stage to establish as far as possible, the propriety and integrity of potential employees. In this regard, temporary employees and contracted staff will be treated in the same manner as permanent employees. Employee recruitment is required therefore to be in accordance with our recruitment policies. Written references are required, and relevant pre recruitment checks performed as stated within the policy document (including amongst others, validation of stated qualifications, Disclosure Barring Service (DBS) checks etc.).

Those organisations undertaking work on our behalf, both contractors and partners, are expected to maintain strong anti-fraud, bribery and theft principles. The specific requirements as a minimum include:

• adequate internal controls in place to minimise fraud, bribery and theft of council resources
   
• adequate recruitment procedures and controls when they are handling financial information or assets on behalf of the council
   
• adequate whistleblowing procedures.  

It is intended that these expectations will be appropriately considered in all contract terms and conditions.

Our Internal Audit department will identify areas of fraud, bribery and theft risk and conduct reviews of controls in place focussed on the prevention these crimes.

Detection

We will participate in the exchange of information between itself and outside bodies to assist with the identification of fraud, bribery and theft. Any such exchange of information will be undertaken in accordance with the principles contained in the Data Protection Act 1998. These may include:

• Police
• External audit
• Local, regional and national auditor networks
• CIPFA – fraud centre
• CIFAS
• Department of Work and Pensions
• Other local authorities
• National fraud initiative (now administered by the Cabinet Office)
• Staffordshire fraud hub

Our Internal Audit department will undertake a series of proactive fraud detection exercises designed to detect and deter fraud, bribery and theft in high risk areas through identification and verification of high risk transactions.

Investigation and redress

Fraud, bribery and theft concerns can be reported to us by employees, suppliers, and the public using the contact details identified in appendix A.

Service directors are required by Financial Regulation D4 to report all instances of potential or actual financial irregularity via the Chief Internal Auditor to the County Treasurer for investigation. This will include all allegations of fraud, bribery and theft. An investigating officer will be appointed to assess all allegations and where appropriate lead an investigation.

Where evidence of fraud or bribery is identified, consideration will be given to all available sanctions. These may include:

• Criminal prosecution, with police support
• Civil recovery of losses
• Invoking our disciplinary procedure, supported by Human Resources
• Referral of individuals to professional bodies 

Our disciplinary procedure will be used to facilitate an appropriate investigation of any allegation of improper behaviour by employees of the council.

The Director of Corporate Services will decide, based on advice from the Chief Internal Auditor, appropriate Service Manager and Head of Human Resources, whether there are sufficient grounds for the matter to be reported to the Police.  For all allegations of fraud, bribery and theft consideration will be given to internal disciplinary sanctions, reporting to professional bodies, recovery of losses through civil action and criminal sanctions (with the support of the police).

Where a fraud has occurred, management must consider changes to systems and procedures to minimise the risk of similar frauds occurring in the future. Any investigation may highlight where there has been a failure of supervision or a breakdown or absence of control. Internal Audit will raise recommendations detailing areas for control improvement all relevant sections.