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Anti-fraud and corruption policy

Deterrence

Prosecution

4.1    The corporate policy will encompass the public, elected members and employees. It is designed to clarify the authority’s action in specific cases and to deter others from committing offences against the authority. However, it also recognises that it may not always be in the public interest to refer cases for criminal proceedings. Each case will be considered on its merits.

Disciplinary Action

4.2    Theft, fraud and bribery and corruption are serious offences against the authority and employees will face disciplinary action if there is evidence that they have been involved in these activities. Disciplinary action will be taken, if appropriate, in addition to criminal proceedings, depending on the circumstances of each individual case, but in a consistent manner, after consultation with the relevant executive head of service and if appropriate the head of HR and learning.
4.3    Disciplinary action will be undertaken in accordance with the council’s disciplinary policy and procedure with each case considered on its merits.
4.4    Members will face appropriate action under this policy if they are found to have been involved in theft, fraud or corruption against the authority. Action will be taken in addition to, or instead of, criminal proceedings, depending on the circumstances of each individual case, but in a consistent manner. Matters, if not referred to the police, will be referred to the standards committee or appropriate group leader.
4.5    Members or employees involved in fraud, theft or corruption that does not involve the council or its finances may still be subject to the above action if it is considered to undermine the council and its reputation.

Publicity

4.6    The council recognises the key role publicity of fraud cases pursued plays in deterring other attempts to defraud the council. To that effect a publicity policy is attached at Annex A of this policy which sets out these measures in detail.
4.7    The authority’s communications team will optimise the publicity opportunities associated with anti-fraud and corruption activity within the authority. The communications team will also try to ensure that the results of any action taken, including prosecutions, are reported in the media. They will maintain close working relationships with all areas involved in anti-fraud work but particularly Nplaw and internal audit.
4.8    In all cases where financial loss to the authority has occurred, the authority will seek to recover the loss and advertise this fact.
4.9    All anti-fraud and corruption activities, including the update of this policy, will be publicised in order to make the employees and the public aware of the
authority’s commitment to taking action on fraud and corruption when it occurs.4.10    Regular reports will be made to the audit and standards committees about countering fraud and corruption activities and their success.

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