FALKIRK COUNCIL Anti-fraud and Corruption Strategy

1. Introduction and Scope
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FALKIRK COUNCIL
Anti-fraud and Corruption Strategy
Falkirk Council aims to provide excellent public service and in so doing needs to ensure probity and
accountability in all matters. The Council is determined to protect itself and the public from fraud and
corruption and is committed to the rigorous maintenance of a strategy for the prevention and detection of
fraud and corruption which will provide a framework for:
encouraging a corporate culture that promotes fraud deterrence and prevention
raising awareness of fraud and corruption
performing investigations and facilitating recovery
invoking disciplinary proceedings and referral to Police
monitoring, publicising and updating the Strategy and its related procedures
This strategy is written for the benefit of employees, Councillors and the public. Organisations and
businesses dealing with the Council are also expected to act with integrity.
Housing and Council Tax benefits fraud is covered by a separate strategy – “Benefits Administration Anti-
Fraud and Prosecution Policy”.
Appendix A lists a number of related documents.
2. Definitions
a) Fraud is the use of deception to obtain an unjust or illegal financial advantage. It may involve the
intentional distortion of financial statements and other records and the misappropriation or theft of
assets. Fraud includes both dishonest acts committed by Councillors or employees of the Council and
acts perpetrated against the Council by third parties.
b) Corruption is the unlawful offering, giving, soliciting or acceptance of an inducement or reward which
could influence the actions taken by the Council, its Councillors or its employees.
c) This strategy also covers the failure of Councillors, employees or third parties to disclose an interest in
order to gain financial or other benefit.
3. Elements of the Anti-fraud and Corruption Strategy
The Council’s Anti-fraud and Corruption Strategy is based on a series of comprehensive and related
elements designed to deter any fraudulent or corrupt act. These elements are:
Operating Culture
Deterrent and Preventative Measures
Fraud Response Policy
Detection and Investigation Procedures

4. Operating Culture
a) Falkirk Council is committed to the seven Principles of Public Life namely objectivity, openness,
leadership, accountability, honesty, selflessness and integrity. High ethical standards should be adhered
to and be demonstrated in all the Council’s actions and decisions.
b) The Council expects Councillors and employees to lead by example in ensuring opposition to fraud and
corruption, in ensuring adherence to rules and regulations and that all procedures and practices are
beyond reproach.
c) The Council requires all individuals and organisations with whom it deals in any capacity to behave
toward the Council with integrity and without intent or actions involving fraud or corruption.
d) Council employees and members of the public are important elements in the stance against fraud and
corruption and are positively encouraged to raise any concerns they may have on issues which impact on
Falkirk Council activities.
e) Training and guidance are vital in maintaining the effectiveness of the Anti-fraud and Corruption
Strategy. The Council supports induction and work related training, particularly for employees involved
in internal control systems, to ensure that their responsibilities and duties are regularly highlighted and
reinforced and that best practice is followed across all Council Services.
f) Internal Audit’s plans are required to provide adequate coverage of the risk of fraud and corruption and
also to reflect the requirement for audit staff to be properly and regularly trained.
g) Where appropriate, Falkirk Council will co-operate with other local authorities and public sector bodies
in the prevention, detection and investigation of fraud and corruption.
5. Deterrent and Preventative Measures
General
a) Falkirk Council’s Standing Orders Relating to Meetings, Scheme of Delegation, Contract Standing
Orders, Financial Regulations and Code of Conduct for Members and Officers set out a framework for
dealing with the affairs of the Council and all Councillors and employees have a duty to comply with
their provisions.
Employees
b) Council employees are required to follow the Code of Conduct for Officers.
c) In the interests of fairness and to ensure impartiality towards customers and those with whom the
Council does business, all offers of gifts or benefits in kind should be refused. Hospitality should only
be accepted on a scale appropriate to the circumstances of the occasion. Where it would be inappropriate
to refuse or return a gift or where hospitality has been accepted, this should be declared in a register
maintained by each Service Director.
d) An employee must not accept from a third party any fee or reward connected in any way with their
Council employment.
e) Employees must declare to their Service Director any possible conflicts of interest which they may have.
This covers, for example, providing an external service to the Council, recruitment and other
employment posts held.
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Councillors
f) Councillors are required to follow the National Code of Local Government Conduct and the Local Code
of Conduct.
g) In the interests of fairness and to ensure impartiality towards customers and those with whom the
Council does business, all offers of gifts or benefits in kind should be refused. Hospitality should only
be accepted on a scale appropriate to the circumstances of the occasion. Where it would be
inappropriate to refuse or return a gift or where hospitality has been accepted, this should be declared in
a register maintained by the Monitoring Officer.
h) In terms of the Local Authorities (Members’ Interests) Regulations 1992 all Councillors are required to
make a declaration of direct and indirect financial interests at the commencement of office. Councillors
should inform the Monitoring Officer, within one month, of any changes to the declaration of interests.
i) Councillors who have a financial or non-pecuniary interest in any issue which comes before the Council,
or any Committee or Sub-Committee are required to declare this interest and take no part in the
consideration or decision of that issue.
Internal Control Systems
j) Managers are responsible for ensuring that adequate controls exist within all financial and operational
systems and that employees are adequately trained in operating systems and procedures. All systems
should be reviewed and developed in line with best practice to ensure efficient and effective internal
controls. A system of internal control provides a framework for ensuring that assets are safeguarded,
transactions are properly authorised, duties are segregated and material errors or irregularities are
prevented or detected.
k) The adequacy and appropriateness of the Council’s financial and operational systems are independently
monitored and assessed by both Internal Audit and External Audit. Senior Managers are expected to
consider and act upon audit recommendations.
l) Employee recruitment is required to be in accordance with procedures laid down by the Head of Human
Resources. In particular, appropriate checks such as written references, must be obtained to confirm the
honesty and integrity of key employees before appointments are made.
6. Fraud Response Policy
a) Falkirk Council will be robust in dealing with any financial malpractice, and will deal timeously and
thoroughly with any person who attempts to defraud the Council or who engages in corrupt practices,
whether they are Councillors, employees, consultants, contractors or other suppliers, benefit claimants,
tenants or other third parties.
b) All suspicions of fraud and corruption must be reported to the Director of Finance and investigated by
Internal Audit in accordance with the Council’s Financial Regulations and Financial Irregularity
Investigation Procedures.
c) If there has been criminal activity then for public accountability and deterrence reasons the Council will
notify the Police.
d) The Council’s Disciplinary Procedures will be used where the outcome of investigation indicates
improper behaviour on the part of employees.
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e) Where loss has been suffered through fraudulent activity, the Council will pursue the perpetrator for
recovery, including taking appropriate legal action.
7. Detection and Investigation Procedures
a) In the majority of cases, it is the diligence of employees and the alertness and good citizenship of the
public at large that detects acts of fraud or corruption.
b) Employees should normally raise concerns with their immediate line manager. In addition they may
raise financial concerns with the Director of Finance or Internal Audit Manager.
c) Alternatively the Council’s Confidential Reporting Policy allows employees, contractors or suppliers to
raise concerns, without fear of victimisation, direct to the Director of Law and Administration in the
capacity of Monitoring Officer.
d) The public can raise any concerns via the Corporate Complaints Procedure or by writing to the Chief
Executive.
e) The Council’s Internal Audit Section will consider all reported incidents and will either give advice to
Services, undertake an investigation itself or conduct a joint investigation with the Service and Human
Resources.
f) The detailed arrangements for the investigation of any suspected fraud or irregularity are contained in
separate guidelines issued by Internal Audit – Financial Irregularity Investigations.
g) Where circumstances justify it, surveillance can be carried out in accordance with the Council’s Policy
on Covert Surveillance under the Regulation of Investigatory Powers (Scotland) Act 2000.
8. Conclusions
a) Falkirk Council has in place a clear framework of systems and procedures to deter, detect and
investigate fraud and corruption. It will ensure that these arrangements are updated to keep pace with
future developments in preventative, deterrent and detection techniques regarding fraudulent or corrupt
activity that may affect its operation.
b) The Council maintains a continuous overview of these arrangements through, in particular, its Director
of Finance and its Internal and External Auditors.
c) The Council will ensure that the existence of this Strategy and its application are well publicised.
August 2002
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Policies and Procedures
Local Code of Corporate Governance
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Anti- Fraud and Corruption Strategy
List of Related Documents
Financial Regulations
Financial Irregularity Investigation Procedures
Benefits Administration - Anti-Fraud and Prosecution Policy
Standing Orders Relating to Meetings
Scheme of Delegation to Committees, Sub-Committees and Officers
Contract Standing Orders
Code of Conduct for Members and Officers
National Code of Local Government Conduct
Disciplinary Policy and Code of Practice
Confidential Reporting Policy
Surveillance Policy
Guidelines for Acceptable Use of Internet and E-mail
ICT Security Policy and Related Guidelines
Data Matching Code of Practice
Falkirk Council Press Code
Corporate Complaints Procedure
Registers
Register of Pecuniary Interests (for Members)
Register of Statutory Disclosures and Interests (for Members)
Register of Gifts and Hospitality
Register of Other Employment
Appendix A