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Fraud response plan

1. Introduction

1.1.    The Council's Anti-Fraud, Bribery and Corruption Policy and Strategy makes it clear that the Council is committed to adopting a zero tolerance approach to fraud, bribery and corruption from both internal and external sources. Where fraud, bribery or corruption is suspected the Council will deal with the allegations seriously in accordance with Council procedures.

1.2     This Fraud Response Plan provides guidance to Councillors and staff on the procedures that should be followed where a fraud is suspected or discovered. It includes reporting requirements, responsibilities for actions and how allegations will be investigated. It should be read in conjunction with the Council's Anti -Fraud, Bribery and Corruption Policy and Strategy, and the Whistleblowing Policy.

1.3     It is important to ensure that a structured and consistent approach is implemented by the Council for the investigation of any cases of fraud, bribery and corruption. This  Fraud Response Plan sets out the Council's approach to ensure:

  • Councillors and staff are aware of how to report any allegations of fraud, bribery or corruption;
  • there is a clear understanding of who will lead investigations and appropriate staff are informed and involved;
  • Information about the investigation is retained by officers involved in the case. in accordance with the Council's Information Management and retention policies;
  • further losses of funds or assets where fraud may have occurred are prevented and the recovery of losses is maximised;
  • evidence is gathered to support an allegation and inform further action;
  • evidence necessary for possible disciplinary and criminal action is established and secured;
  • any adverse effects or publicity on the business of the Council or any other partner organisations involved are minimised;
  • a review is undertaken of the reasons for the incident and action taken to improve control, strengthen procedures and prevent recurrence.

1.4     Under no circumstances should staff feel that they must tolerate the abuse of systems employed at the Council by other staff members or outside persons in ways that may be classed as potentially fraudulent behaviour. Whilst total anonymity cannot be guaranteed, every effort will be made not to reveal your name. However, if criminal activity is found and the case is forwarded to the police, your identity may be needed at a later date. However, all persons implicated by an allegation must be informed of the circumstances and relevant evidence and allowed to comment as part of the investigation.

1.5      The Council seeks to establish a flexible Fraud Response Plan to enable the approach to be varied in individual cases. Generally, the approach taken shall depend on the perceived risk to the Council in a financial or reputational sense. This shall be judged individually for each case, based on the information available.

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