10 Counter-Fraud and Corruption Policy
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To introduce the recently reviewed Counter-Fraud and Corruption Policy at South Holland District Council (report of the Head of Internal Audit enclosed).
Additional documents:
Minutes:
Consideration was given to the report of the Head of Internal Audit which requested that members review and comment on the suggested enhancements to the Counter Fraud and Corruption Policy.
The Counter Fraud and Corruption policy was required to be reviewed and approved by the Governance and Audit Committee every three years. The policy was last approved by the Committee in December 2017 and an update was therefore due. This had been delayed to allow for an assessment of the current arrangements to be undertaken in comparison with the latest strategy from CIFAS (Fighting Fraud and Corruption Locally).
A first draft of the updated policy was provided to the Committee for review prior to approval. It was recommended that the policy, once reviewed by the Committee, be endorsed for approval by management, and stakeholders be consulted on changes, before it was presented to the Committee for approval in September 2021.
The Internal Audit Manager highlighted the areas of change within the Policy:
· Economic Crime had been added to the list within the Introduction of the various types of fraud risks;
· References to CPBS had been replaced with PSPS;
· Section 2 – Within the table giving definitions of the types of Fraud, Corruption and Bribery, the list had been expanded to include examples of fraud in each of these areas;
· Section 3 – The Audit Approach. Two new pillars had been included here:
o Govern (Tone at the top) – Proposal that the Governance and Audit Committee have a greater involvement in reviewing and approving policies for Counter Fraud and Corruption; that the Committee receive annually the fighting fraud and corruption locally strategy checklist and the risk assessment associated with this; and that the relevant portfolio holder be made aware of fraud risks and mitigations..
o Protect (Protecting the Council and its Residents) – The aim of this was that fraud and corruption cases be publicised and endorsed by the Council’s communications team to highlight awareness in the local community; and that cyber crime controls be regularly reviewed to ensure they remained adequate to new and increasingly sophisticated techniques from fraudsters.
· Contacts for Whistleblowing – this section needed updating.
Members considered the document, and the following points were raised:
· Members questioned whether the continuation of home working was a risk to the fraud policy or not.
o The Internal Audit Manager did not believe that there was a greater risk from home working. She also commented that there needed to be more work and assurance undertaken with regard to cyber security.
AGREED:
That the suggested enhancements to the Counter Fraud and Corruption Policy be noted.