Anti Fraud and Corruption Policy 2021 to 2022

8.1 The Council’s expectation is that Councillors and managers will lead by example and that employees at all levels will comply with the Constitution, Council Policies, Financial Regulations and Contract Standing Orders.

8.2 The Council recognises that the primary responsibility for the prevention and detection of fraud rests with management. It is essential that employees of the Council report any irregularities, or suspected irregularities to their line manager and if this is not appropriate then to the Corporate Director or Service Director or Manager. The Council will provide all reasonable protection for those who raise genuine concerns in good faith, in accordance with the Whistleblowing Policy and Procedure.

8.3 The line manager, Service Manager, Director or Corporate Director who receives the allegation (whether from a Councillor or a Council employee) must refer the matter to the following people, to determine how the potential irregularity will be investigated:

• Director of Corporate Finance (Section 151 Officer)
• Deputy Chief Executive (Monitoring Officer
• Corporate Director
• Head of Business Assurance (& Chief Internal Auditor)
• Head of HR Operations

8.4 Where appropriate, the Monitoring Officer should inform the Leader, Deputy Leader and relevant portfolio holder where the irregularity is material and or could affect the reputation of the Council. The Section 151 Officer will liaise with the Cabinet Member for Resources, as appropriate. The Media Team should also be informed if the matter is likely to be communicated externally.

8.5 The investigating officer will follow the ‘Guidelines for Managers on Investigating Allegations’ as well as the ‘Protocol for Investigating Irregularities’ (Appendix A), which includes the need to:

• deal promptly with the matter
• record all evidence received
• ensure that evidence is sound and adequately supported
• ensure security of all evidence collected
• contact other agencies if necessary (for example Police)
• notify the Council’s insurers
• implement Council disciplinary procedures where appropriate

8.6 The Council will also work in co-operation with the following bodies that will assist in scrutinising our systems and defences against fraud and corruption:

• Local Government Ombudsman
• External Audit – Relationship Manager
• National Fraud Initiative and related Audit Networks
• Central Government Departments
• HM Revenue and Customs
• UK Border Agency
• Department for Work and Pensions
• Police

8.7 Any concerns or suspicions reported will be treated with discretion and in confidence.

Key contacts include:

• Head of Business Assurance (& Chief Internal Auditor) – Tel: 01296 387327
• Audit Manager (Fraud Lead) – Tel: 01296 383717
• Confidential Reporting Facility - Tel: 01296 382237
• Confidential email - [email protected]

8.8 Other Council means for raising concerns:

Write to:
Buckinghamshire Council
The Gateway
Aylesbury
Buckinghamshire
HP20 1UA

• Chief Executive
• Service Director - Corporate Finance (S.151 Officer)
• Deputy Chief Executive (Monitoring Officer)
• Corporate Director
• Service Director/Manager
• Head of Business Assurance (& Chief Internal Auditor)
• Audit and Governance Committee Chairman

8.9 External means of raising concerns:

• External Audit (Grant Thornton) - Tel: 020 7728 3328
• Citizens Advice Bureau - https://www.citizensadvice.org.uk/
• Police - https://www.thamesvalley.police.uk/

8.10 Attached are the following Appendices:

• Appendix A: The Protocol for Investigating Irregularities
• Appendix B: The Council’s Fraud Response Plan
• Appendix C: Examples of Fraud Indicators