1.Introduction

Good corporate governance requires that St Stephen in Brannel Parish Council demonstrates clearly that it is firmly committed to dealing with fraud and corruption and will deal equally with perpetrators from inside (members and officers) and outside the council. In addition, there will be no distinction made in investigation and action between cases that generate financial benefits and those that do not. This policy statement, however, will not compromise St Stephen in Brannel Parish Council’s commitment to equal opportunities or the requirements of the Human Rights Act 1998 and other relevant statutory provision.

This policy embodies a series of measures designed to frustrate any attempted fraudulent or corrupt act and the steps to be taken if such action occurs. For ease of understanding it is separated into five areas as below:

Section 2 – Culture
Section 3 – Prevention
Section 4 – Deterrence
Section 5 – Detection and Investigation
Section 6 – Training

St Stephen in Brannel Parish Council is also aware of the high degree of external scrutiny of its affairs by a variety of bodies such as the Information Commissioner’s Office (ICO) and HMRC.

These bodies are important in highlighting any areas where improvements can be made.

Fraud and corruption are defined as:

Fraud – “the intentional distortion of financial statements or other records by persons internal or external to the authority which is carried out to conceal the misappropriation of assets or otherwise for gain”. In addition, fraud can also be defined as “the intentional distortion of financial statements or other records by persons internal or external to the authority which is carried out to mislead or misrepresent”.

Corruption – “the offering, giving, soliciting or acceptance of an inducement or reward which may influence the action of any person”.

In addition, this policy also covers “the failure to disclose an interest in order to gain financial or other pecuniary benefit”.

2. Culture

The culture of St Stephen in Brannel Parish Council has always been one of openness and the core values of value, fairness and trust support this. The culture therefore supports the opposition to fraud and corruption.

The prevention/detection of fraud/corruption and the protection of the public purse are responsibilities of everyone, both internal and external to the organisation.

The Council’s elected members and officers play an important role in creating and maintaining this culture. They are positively encouraged to raise concerns regarding fraud and corruption, immaterial of seniority, rank or status, in the knowledge that such concerns will, wherever possible, be treated in confidence. The public also has a role to play in this process and should inform the Council if they feel that fraud/corruption may have occurred.

Concerns must be raised when members, officers or the public reasonably believe that one or more of the following has occurred, is in the process of occurring, or is likely to occur:

  • A criminal offence
  • A failure to comply with a statutory or legal obligation
  • Improper or unauthorised use of public or other official funds
  • A miscarriage of justice
  • Maladministration, misconduct or malpractice
  • Endangering an individual’s health and/or safety
  • Damage to the environment
  • Deliberate concealment of any of the above.

The Council will ensure that any allegations received in any way, including by anonymous letters or telephone calls, will be taken seriously and investigated in an appropriate manner.

St Stephen in Brannel Parish Council will deal firmly with those who defraud the Council or who are corrupt, or where there has been financial malpractice. There is, of course, a need to ensure that any investigation process is not misused and, therefore, any abuse (such as members/officers raising malicious allegations) may be dealt with as a disciplinary matter (officers) or through Standing Order procedures (members).

When fraud and corruption has occurred due to a breakdown in systems or procedures, the Council will ensure that appropriate improvements in systems of control are implemented in order to prevent a reoccurrence.

3. Prevention

Role of Elected Members

As elected representatives, all members have a duty to the residents of St Stephen in Brannel parish to protect the council as a corporate body and public money from any acts of fraud and corruption. This is done through existing practice, compliance with the Code of Conduct, Standing Orders, Financial Regulations and relevant legislation.

Adopted by Full Council at the meeting held on Wednesday 4th December 2024 under minute FPC269/24. Due for review in 2027.