Investigations | Anti Fraud, Bribery and Corruption Statement and Strategy

9.1 Senior management are responsible for recording any allegations of fraud or corruption that they receive and are required to inform the Head of Audit and Risk of all suspected irregularities. The Head of Audit and Risk will liaise with the Corporate Governance Group to progress the investigation. This is to ensure that the matter is dealt with promptly and confidentially and that:

• all evidence that has been received is recorded
• evidence is sound and adequately supported
• all of the evidence that has been collected is secure, including electronic evidence
• where appropriate, other agencies are contacted eg Police
• when appropriate, to arrange for the notification of the Council’s insurers
• a report to senior management is issued and where appropriate, recommend that management take disciplinary action in accordance with the Council’s Conduct Policy, and make any necessary revisions to systems and procedures to ensure that similar frauds do not recur.

9.3 Depending on the nature and anticipated extent of the allegations, the investigation officer will normally work closely with management, HR, Legal etc., and other agencies, such as the Police. This is to ensure that all allegations and evidence are properly investigated and reported upon, and where appropriate, maximum recoveries are made for the Council.

9.4 The Council’s External Auditor, Grant Thornton, also has powers to independently investigate fraud and corruption, and the Council can use this service too.

9.5 Where a fraud has occurred, management will need to take action to ensure that any control weaknesses which provided the opportunity for this to occur are addressed. Where appropriate, control weaknesses will be identified by the investigation. Any lessons learned will be disseminated to all relevant sections.