| 1. |
Policy Statement |
| 1.1 |
Suffolk Coastal District Council is committed to providing the
highest quality of service to all its residents and customers. The
Council recognises that the services provided need to be
cost-effective, efficient and fair and that occurrences of theft,
fraud and corruption may affect the cost, efficiency and equity of
its services. |
| 1.2 |
The Council and each individual member of staff have the
responsibility to counter theft, fraud and corruption and the duty
to protect the assets of the Council. Assets include information
held by the Council, professional image and goodwill as well as
property and funds. |
| 1.3 |
The Council is committed to maintaining an honest, open and
well-intentioned environment in all its areas of operation. The
Council will prevent theft, fraud and corruption by: |
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(a) developing and anti-theft, anti-fraud and
anti-corruption culture among staff and the public to deter such
acts;
(b) encouraging the reporting of reasonably held
suspicions relating to theft, fraud or corruption within any
area of the Council's operations;
(c) designing and operating systems, procedures and
policies which minimise the risk of fraud;
(d) assisting other government bodies and law
enforcement agencies in their investigations into theft, fraud
and corruption where it is appropriate, lawful and proper to do
so, and seek assistance from such organisations when the
Council's own enquiries necessitate such measures.
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| 1.4 |
Where appropriate, the Council will seek to prosecute persons
who: |
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(a) operate corrupt practices against the Council; or
(b) steal from the Council; or
(c) defraud the Council;
and will seek to recover the proceeds of any such activity from
identified offenders. |
| 1.5 |
The Council aims to treat people from all sectors of the
community with dignity and respect and without discriminating
unfairly on grounds of race, colour, religion, nationality,
gender, age, sexual orientation or disability. This applies to all
its dealings with the public including the actions described in
this document. |
| 1.6 |
In compiling this document, the Council has taken the provisions
of the Human Rights Act 1998 into account. In the Council's view,
this document is compatible with Convention Rights. |
| 2. |
Theft, Fraud and Corruption |
| 2.1 |
The Council considers theft to be an intentional, dishonest and
unlawful borrowing, misappropriation or misuse of the Council's
assets or facilities. This definition includes actions that are
contrary to Section 1 of the Theft Act 1968 as well as those that
fall short of offences under criminal law. |
| 2.2 |
The Council considers fraud to be any dishonest act or intent
undertaken with a view for personal gain for oneself or another,
or to sustain loss to another, which involves the appropriation,
misappropriation or misuse of any asset or information held by or
on behalf of the Council. This definition includes actions that
are commonly construed as offences under criminal law as well as
those that fall short of offences under criminal law. |
| 2.3 |
For the purposes of this document the term corruption means the
offering, giving, soliciting or acceptance of an inducement or
reward intended to influence the action of any Member or officer
of the Council or contractor employed by, or on behalf of, the
Council. Corruption may also be deemed to include criminal acts
and situations where any Member or officer intentionally makes a
decision which gives any person an advantage or disadvantage where
the decision is contrary to the policy/procedures governing the
decision making process and is based on no sound reasoning. The
latter part of this definition is intended to encompass all types
of discrimination, both positive (where any person gains an unfair
advantage) and negative (where any person is unfairly
disadvantaged). |
| 3. |
Specific Activities |
| 3.1 |
The Council has an ethos of honesty and integrity. The specific
activities detailed in this section are designed to maintain an
honest culture and ensure that proper arrangements exist for the
prevention and detection of theft, fraud and corruption. The
Council will ensure that the following activities are undertaken: |
|
(a) The widespread publication of the Authority's
anti-theft, anti-fraud and anti-corruption Policy Statement as
set out in Section 1 of this document.
(b) The provision of an adequate and effective
internal audit service to carry out an on-going review of
financial and other systems in use and to test those systems for
weaknesses in internal controls. In carrying out this work
internal audit will have regard to the relative risk associated
with particular systems as agreed with the Council's external
auditors.
(c) The regular review of the content and application
of the Council's Standing Orders and Financial Regulations.
(d) The issuing of comprehensive Codes of Conduct to
all employees and Members of the Council and, where appropriate,
to contractors employed by or on behalf of the Council.
(e) The provision of theft, fraud and corruption
training to officers and Members where appropriate.
(f) The maintenance of a whistleblowing policy
document and related reporting procedures so that proper
arrangements exist to ensure that there is no obstacle to
reporting theft, fraud or corruption.
(g) The maintenance of a theft, fraud and corruption
response plan to ensure that, if any allegation is made
regarding theft, fraud or corruption, appropriate investigation
takes place and the appropriate steps are taken, if appropriate,
to recover any loss incurred.
(h) The prosecution of offenders where this is
considered to be in the interests of the Council.
(i) Full co-operation with any work undertaken or
information requested by the Council's external auditors
relating to matters of theft, fraud and corruption.
(j) Appointing one of the Council's officers as a
Compliance Officer for anti-fraud, anti-theft and
anti-corruption issues to ensure that there is a clear point of
contact for anyone wishing to report theft, fraud or corruption.
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| 3.2 |
The arrangements made to implement the above shall have regard
to relevant recommendations made by the: |
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(a) Audit Commission
(b) National Audit Office
(c) Government Departments
(d) The Council's External Auditors
(e) The Chartered Institute of Public Finance and
Accountancy
(f) Benefit Fraud Inspectorate
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