Agenda item

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The Assistant Director for Finance and Deputy Section 151 Officer presented a refreshed anti-fraud and corruption framework responding mainly to the Economic Crime and Corporate Transparency Act 2023. The framework was refreshed following the introduction of the failure-to-prevent-fraud offence under the Economic Crime and Corporate Transparency Act 2023, which came into force in September 2025. The Assistant Director for Finance and Deputy Section 151 Officer explained the Council already had prevention, detection, investigation and risk-management arrangements, so the update was intended to strengthen rather than fundamentally redesign the existing framework.

Independent Member, Michael Laird asked whether employees signed declarations covering the use of Council assets such as laptops and mobile devices. The Assistant Director for Finance and Deputy Section 151 Officer confirmed that employees received and signed an employee code of conduct, while technology assets were covered by acceptable-use policies and related declarations.

The Vice – Chair, Councillor Bearshaw asked whether anti-fraud training was compulsory. The Assistant Director for Finance and Deputy Section 151 Officer confirmed that the e-learning module was expected to be completed annually but was not currently mandatory, and that take-up data was not available at the meeting.

He agreed to review participation, consider whether stronger enforcement was required, update the module if necessary, and provide future assurance on coverage. Staff without suitable technology access can receive equivalent information through team meetings.

Members raised the risk that changes to procedures could weaken controls if fraud implications were not considered. The Assistant Director for Finance and Deputy Section 151 Officer agreed to ensure that fraud risk is explicitly considered when processes and systems change, and to examine whether individual policies should contain a prompt or recommendation requiring that assessment.

The Vice – Chair, Councillor Bearshaw asked when the fraud risk assessment dated 2024 would next be refreshed. The Assistant Director for Finance and Deputy Section 151 officer commented there was no planned assessment during the current year but agreed that a regular, non-annual cycle should be established. He also agreed to link the assessment to service risk registers, assurance statements, the annual governance statement and other relevant processes.

Councillor Jones sought an update on the new software for risk registers which had previously been presented to the Committee. The Assistant Director for Finance and Deputy Section 151 Officer explained the Council’s third-party Corporate Management System had recently gone live and was being rolled out across the organisation. It is intended to combine performance information, service risks and internal audit recommendations, reducing duplication and helping the Audit Committee identify assurance gaps and track actions.

Members identified inconsistent version control, missing or unclear change histories, review dates and a possible incorrect March 2025 date on the anti-bribery policy. The Assistant Director for Finance and Deputy Section 151 Officer agreed to consider standardising version-control information so that documents show what changed, why it changed and when the next review was due.

Councillor Morley described controls being strengthened around supplier evaluation, purchase orders, invoice checking, contract management and matching payments to materials and construction progress. He also referred to data cleansing, version control, cyber-security investment and business-continuity arrangements as areas receiving further work.

The Chair, Councillor de Winton questioned how long the E-Learning training took employees to complete. The Assistant Director for Finance and Deputy Section 151 Officer explained no more than an hour, he highlighted support services were available and for employees with no online access then in person training was available.

RESOLVED: The Committee recommended adoption of the Anti-Fraud and Corruption Framework and agreed to receive a year end update in support of the Anti-Fraud and Corruption Strategy.