Anti-fraud and corruption policy

6.1 As with any risk faced by the council, it is the responsibility of managers to ensure that any fraud risk is adequately considered when preparing risk assessments in support of achieving strategic priorities, business plans, project and programme objectives and outcomes.

6.2 In making this assessment it is important to consider the risk of fraud occurring rather than any actual incidences of fraud having occurred in the past. Once the fraud risk has been evaluated, appropriate action should be taken to mitigate those risks on an ongoing basis.

6.3 Any changes in operations or the business environment must also be assessed to ensure any impacts, which might increase or otherwise change the risk of fraud, bribery and corruption, are properly taken into account.

6.4 Good corporate governance procedures are a strong safeguard against fraud and corruption. Adequate supervision, recruitment and selection, scrutiny and healthy scepticism must not be seen as distrust but simply as good management practice shaping attitudes and creating an environment opposed to fraudulent activity.

6.5 Whilst all stakeholders in scope have a part to play in reducing the risk fraud, elected Members, Directors and Management are ideally positioned to influence the ethical tone of the organisation and play a crucial role in fostering a culture of high ethical standards and integrity.

6.6 The Council adopts the four key themes of Govern, Acknowledge, Prevent and Pursue. The approach to each of these headings is set out in Appendix B.

6.7 A fraud response plan is contained within Appendix C. This is used in the event of a fraud or a suspected fraud.

6.8 The council will provide a counter fraud provision which: • Ensures that the resources dedicated are sufficient and those involved are trained to deliver a professional counter fraud service to the highest standards; • Proactively deters, prevents and detects fraud, bribery and corruption ; • Investigates suspected or detected fraud, bribery and corruption; and • Enables the council to apply appropriate sanctions and recover all losses through court action or by invoicing an individual.

6.9 In cases of confirmed fraud recommendations will be used to inform policy, systems, risk management and control improvements, thereby reducing the council’s exposure to fraudulent activity.

6.10 The Council will share relevant information with third parties and participate in data matching exercises for the purposes of preventing, investigating and enforcing fraud and corruption. Data will only be shared where there is a clear legal basis for doing so in line with the councils Privacy Statement, Data Protection Policy and relevant legislation.

6.11 On identification of a fraud or suspected fraud the Council will respond swiftly to:

• Prevent further losses of funds or other assets where fraud has occurred;
• Minimise the risk of inappropriate action or disclosure taking place which would compromise an investigation;
• Ensure there is a clear understanding over who will lead any investigation and to ensure managers, HR, Internal Audit are involved as appropriate;
• Establish and secure evidence necessary and ensure containment of any information for disciplinary, civil and/or criminal action;
• Maximise recovery of losses;
• Ensure appropriate and timely action is taken against those who are suspected of fraud;
• Identify the perpetrators and take appropriate action with any disciplinary, civil and/or criminal action; and
• Minimise any adverse publicity for Welwyn and Hatfield Borough Council