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My Norwich

Anti-fraud and corruption policy

Detection and investigation

5.1    All employees, members and any other stakeholder in council services have a vital role in identifying potential fraud or corruption. It is not the responsibility of those groups to investigate their suspicions as this may undermine a case to be pursued but all parties play a key role in bringing such concerns to the council’s attention for a proper and thorough investigation to be undertaken.
5.2    Management are in the best position to become aware of any problems that could indicate fraud or theft etc. Management are also best placed to ensure that systems of internal control are in place and operating and thus are ideally placed to identify weaknesses or failures that may be exploited. Internal audit can provide advice and assistance in this area.
5.3    Employees are also ideally placed to detect fraud, theft or corruption. Employees are encouraged to discuss concerns with their line manager but the whistleblowing policy also provides mechanisms to raise concerns corporately.
5.4    The whistleblowing policy provides a process to enable the council to demonstrate:

  • proper investigations for all referrals
  • proper action taken in relation to findings from investigations
  • feedback is provided to anyone making a referral
  • appropriate protection for anyone making or having made a referral.

5.5    Internal audit plays an important role in the detection of fraud and corruption. Included in their annual plan are reviews of system financial controls and specific fraud and corruption tests, spot checks and unannounced visits. Internal audit operates in accordance with best practice including the adoption of a formal audit manual in line with CIPFA best practice. This includes suitable processes to provide assurance to management on the adequacy of systems of internal control including the completion of follow ups for previous recommendations.
5.6    In addition to internal audit, there are numerous systems controls in place to deter fraud and corruption, but it is often the vigilance of employees and members of the public that aids detection.
5.7    In some cases frauds are discovered by chance or ‘tip-off’ and arrangements are in place to enable such information to be properly dealt with, in accordance with the requirements of the Human Rights Act 1998.
5.8    All suspected irregularities are required to be reported (verbally or in writing) either by the person with whom the initial concern was raised or by the originator. This is essential to the policy, and:

  • ensures the consistent treatment of information regarding fraud and corruption
  • facilitates a proper and thorough investigation by an experienced audit team, in accordance with the requirements of the Human Rights Act 1998.

5.9    This process will apply to all the following areas:

  1. fraud/corruption by elected members
  2. internal fraud/corruption
  3. other fraud/corruption by authority employees
  4. fraud by contractors’ employees
  5. external fraud (the public).

5.10    Cases may be referred to the council’s external auditor and the executive head of business relationship management and democracy for consideration of action via the police or the standards committee.
5.11    In accordance with basic legal concepts any person who witnesses or discovers a criminal act has the right to refer concerns directly to the police.
5.12    Any decision to refer a matter to the police will be taken by the CIA in consultation with the head of HR and learning and/or chief executive and relevant executive head of service. The authority will normally wish the police to be made aware of, and investigate independently, offenders where financial impropriety is discovered.
5.13    Depending on the nature of an allegation under b) to e), the CIA will normally work closely with the executive head of service concerned to ensure that all allegations are thoroughly investigated and reported upon.
5.14    The authority’s disciplinary procedures will be used to facilitate a thorough investigation of any allegations of improper behaviour by employees. The processes as outlined in paragraph 4.4 will cover members.