Anti-fraud and corruption strategy

1.1. South Ribble Borough Council is committed to combating fraud and corruption and promoting a 'zero tolerance culture', whether the perpetrators are internal or external to the Council. All employees, (including casuals, temporary and agency staff), elected members, partners, contractors and suppliers of goods and services are expected to demonstrate integrity, accountability and high ethical standards. The Council has adopted an Equality and Diversity Policy to which all employees are required to adhere. The Council is very mindful of the increased importance of working with partners in all areas of its activities. In these circumstances the Council shall ensure that its partners and all companies with whom it is contracted, will be fully informed of the procedures it has in place to combat fraud.

1.2 The public is entitled to expect local government employees and elected members to adhere to their respective Codes of Conduct, to conduct themselves to the highest standards, with the utmost integrity and in a manner which avoids the possibility of any suspicion arising whereby they could be influenced by improper motives. Fraud and corruption should be thought of in terms of a reputational risk not solely a financial risk.

1.3. The Chartered Institute of Public Finance and Accountancy (CIPFA) provided guidance describing actions needed for organisations to be effective in countering fraud and corruption. In addition, the Council focuses on fraud risks identified in the Audit Commission's national report, Protecting the Public Purse.

1.4. South Ribble Borough Council endorses the principles of Public Life (derived from the work of the Nolan Committee) listed below.

Selflessness

Members should serve only the public interest and should never improperly confer an advantage or disadvantage on any person.

Honest and integrity

Members should not place themselves in situations where their honesty and integrity may be questioned, should not behave improperly and should on all occasions avoid the appearance of such behaviour.

Objectivity

Members should make decisions on merit, including when making appointments, awarding contracts, or recommending individuals for rewards or benefits.

Accountability

Members should be accountable to the public for their actions and the manner in which they carry out their responsibilities and should co-operate fully and honestly with any scrutiny appropriate to their particular office. OPENNESS Members should be as open as possible about their actions and those of their Authority and should be prepared to give reasons for those actions.

Personal judgement

Members may take account of the views of others, including their political groups, but should reach their own conclusions on the issues before them and act in accordance with those conclusions.

Respect for others

Members should promote equality by not discriminating unlawfully against any person and by treating people with respect, regardless of their race, age, religion, gender, sexual orientation or disability. They should respect the impartiality and integrity of the Authority's statutory officers and its other employees.

Duty to uphold the law

Members should uphold the law and on all occasions act in accordance with the trust that the public is entitled to place in them.

Stewardship

Members should do whatever they are able to do to ensure that their authorities use their resources prudently and in accordance with the law.

Leadership

Members should promote and support these principles by leadership and by example and should act in a way that secures or preserves public confidence.

1.5. This Strategy applies equally to all employees and elected members and aims:

• to promote an anti-fraud culture throughout the Council;
• to ensure that concerns are properly raised and addressed;
• to deter serious malpractice;
• to protect the Council's reputation;
• to demonstrate accountability in line with the highest standards of governance; and
• to reduce losses to fraud and corruption to an absolute minimum.
• Recovering fraudulently claimed overpayments and other losses;
• Prosecuting offenders or if appropriate, the administration of an official caution.

1.6. South Ribble Borough Council endeavours to prevent and detect fraud by working with / towards or having the following in place:

• Effective Internal and External Audit;
• An effective system of internal control to reduce the risk of fraud;
• Detecting and stopping fraud;
• Senior officers responsible for authorising Regulation of Investigatory Powers Act 2000 (RIPA) forms;
• Local Code of Corporate Governance;
• Annual Service Assurance Statements;
• A Policy Statement and Strategy to embed Risk Management;
• Raising awareness of fraud and corruption via the Risk Management Framework;
• Audit Commission's National Fraud Initiatives (NFI) and other data matching exercises;
• Membership of the National Anti - Fraud Network (NAFN);
• Sharing of information and data between services and external organisations;
• Housing Benefits Matching Service;
• Liaison with the Police and other anti-fraud agencies;
• Provision of trained investigators;
• Specific initiatives relating to benefits, e.g. Verification Framework; Data Analysis Exercise, the Security against Fraud and Error (SAFE) initiative and the proactive exercises for the prevention of benefit fraud;
• CIPFA Code of Practice for Treasury Management;
• Recruitment and selection process;
• Corporate and service Induction and awareness sessions (for employees and elected members);
• Gifts and Hospitality Registers (for employees and elected members);
• Performance Management Framework;
• Project Management Guidance;
• Disciplinary Procedure; 
• Ethical governance audits;
• Promotion of a zero -tolerance culture towards fraud and corruption;
• Being visibly active against fraud, which acts as a significant deterrent;
• Fraud awareness sessions for employees and elected members;
• Recovering fraudulently claimed overpayments and other losses;
• Referral of benefit fraud to CPS for prosecuting of offenders

1.7. This Strategy supplements a range of inter related policies and governance arrangements to provide a corporate framework to counter fraudulent activity, including:

• The Council's Constitution which includes Standing Orders, Standing Orders for Contracts, Financial Regulations and Protocols;
• Governance Committee;
• Scrutiny Committee;
• Standards Committee;
• Annual Governance Review;
• Local Code of Corporate Governance;
• Codes of Conduct for Employees and Elected Members
• Registers of Interest;
• Scheme of Delegation;
• Codes of Conduct relevant to individual professional bodies;
• Whistleblowing Policy
• Conditions of Service;
• Complaints Procedure;
• Combating Benefit Fraud document;
• Corporate Prosecution Policy;
• Fraud Response Plan;
• Money Laundering Policy;
• Information Technology and Communication Policies which include: Acceptable Use Policy; Email Policy; Internet Policy; Security Policy; Records Management Policy; Data Protection Policy; and the Freedom of Information Policy.
• Procurement Strategy;
• Equality and Diversity Policy.

1.8. This Strategy encompasses all fraud although there are separate policies dealing with the specific issues of money laundering and housing and council tax benefit fraud.