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Counter Fraud Corruption Strategy

Last updated on: 09-Apr-2021

5. Framework

Corporate Governance

Our Constitution sets out how we operate, how decisions are made, and the procedures to follow to ensure that these are efficient, transparent, and accountable to local people. While some of these processes are required by law, others are a matter for the Council to choose.

The council has adopted a Code of Corporate Governance (the Code). The Code acts as the cornerstone to the council’s governance framework by which it is accountable to its users and wider community stakeholders. Within that framework, the Code sets out a commitment as to how the council carries out its functions, and the procedures and processes by which it undertakes to deliver the adopted Corporate Objectives.

There are a number of corporate policies and procedures which formulate the Council’s framework for minimising risk and the prevention of fraud and corruption. These include:

  • Counter Fraud and Corruption Strategy
  • Audit & Counter Fraud Charter
  • Contract Procedure Rules
  • Finance Procedure Rules
  • Human Resources Disciplinary Policy and Procedure
  • Human Resources Code of Conduct for Employees
  • Human Resources Recruitment and Selection Code of Practice
  • Members’ Code of Conduct
  • Anti-Money Laundering Policy
  • Risk Management Policy and Strategy
  • Scheme of Delegation
  • Whistleblowing Policy; and
  • Anti-Bribery Policy

It is the responsibility of senior managers to ensure that policies and procedures remain relevant and up to date, including necessary amendment to take into account any changes to legislation or regulations, ensure that all staff have access to the relevant policies and procedures, and that staff receive suitable training as necessary.

Members and employees must ensure that they read and understand the policies and procedures that apply to them and act in accordance with them.

System of internal control

The risk of fraud and corruption can be minimised by good financial management, sound internal control systems, effective management supervision, and by raising public, Member, and employee awareness of fraud.

Internal control is the whole system of controls, financial and otherwise, established to provide reasonable assurance of:

  • proper aims and objectives
  • efficient and effective operations
  • reliable management information and reporting
  • legitimate expenditure
  • compliance with laws and regulations
  • performance management
  • security of assets and income

Responsible officers are expected to ensure that effective internal control arrangements are incorporated into the design or development of systems and procedures. Weaknesses in the design and operation of administrative and financial internal control systems may increase the risk of fraud. Systems should contain efficient, effective, and well documented internal controls that cover the following:

  • adequate segregation of duties
  • proper authorisation and approval procedures
  • adequate physical security over assets
  • reliable monitoring and reporting arrangements
  • to protect the council from error, misappropriation, or loss

It is management’s responsibility to install adequate internal controls and rectify weaknesses if they occur. To help management discharge this responsibility, systems may be subject to review by both Internal and External Audit. Auditors are responsible for reporting to management on significant weaknesses in the control environment, including deficiencies in the operation of internal controls and highlighting exposure to the risk of fraud. Audit recommendations to address control weaknesses are followed up to ensure that they are appropriately actioned.

Assurance of the effective operation of internal control arrangements is requested from management annually as part of the Council's arrangements for preparing the Annual Governance Statement. Managers are required to specifically provide assurance on the effective operation of internal control arrangements and staff awareness of this Strategy.

Management should instigate occasional deterrent compliance checks on the operation of internal controls within their service and are encouraged to seek advice from the Audit & Counter Fraud Service on what checks should be carried out. This work should also be used to inform the Annual Governance Statement.

Members and officers are required to declare any financial and other interest in any outside bodies or organisations, which could be considered or perceived as having an influence on their actions on behalf of the Council.

The Council operates a policy for Improving Performance which incorporates the Council's disciplinary procedure, which applies to all employees. The Council has established a Standards Committee to deal with matters relating to the Member’s Code of Conduct.

The Finance and Audit Committee also have a role in providing independent assurance to the Council on the adequacy of the Council’s control environment.  This role is discharged by the committee through the receipt of regular reports on the work and findings of internal and external audit, and the Council’s governance and risk arrangements.

Risk management

Our Corporate Risk Register that details the most significant risks to the council being able to deliver its corporate objectives. Fraud risks relating to individual services should be included within Service Risk Registers and subject to regular review to ensure that appropriate controls are in place to mitigate those risks.


We recognises that a key preventative measure in the fight against fraud, corruption and bribery is to take effective steps at the recruitment stage to verify the propriety and integrity of the previous records of potential employees of the organisation.

Employee recruitment is required to be in accordance with procedures set out in the council’s recruitment guide. This guidance requires a number of checks at the recruitment stage to establish and confirm the previous records of potential employees, including:

  • verifying the identity of the applicant
  • obtaining satisfactory references prior to appointment
  • verifying the applicant is able to legitimately work in the UK
  • verifying and retaining copies of certificates for stated qualifications,
  • undertaking Disclosure and Barring Service checks, where appropriate

These practices apply to all permanent appointments including those where employees have entered the organisation as an agency worker or consultant in the first instance.


Training is a vital tool in implementing a successful Counter Fraud and Corruption strategy, by ensuring that both officers and Members clearly understand their roles and responsibilities within the organisation and carry these out within the Council's framework of policies and procedures. Training is particularly important where employees are required to operate within financial systems or handle monies or personal/confidential information.

It is often the alertness to the possibility of fraud and corruption, of all those involved in a business activity with the Council, that enables detection to occur. Accordingly, we will promote a general awareness of fraud, bribery, and corruption to all employees and Members, with specific training provided to officers engaged in the prevention and detection of such activity to ensure that they have the necessary skills to carry out these functions. This specifically includes periodic circulation of counter fraud strategy and policy documents.

We are committed to developing staff who are involved in investigating fraud and corruption and suitable training will be provided where necessary.

Working with others

The nature and scope of fraud perpetrated against local authorities is varied and often cross-jurisdiction. Accordingly, the Council is committed to working with other organisations to prevent and detect fraud, bribery and corruption. There arrangements are in place to encourage the exchange of information between the Council and other agencies on national and local fraud and corruption activity. This includes participation in the National Fraud Initiative (NFI), which matches data across a wide range of public service organisations in order to detect fraud or erroneous payments

Though not intended to be exhaustive, the Council currently works with the following:

  • the Cabinet Office (NFI)
  • Police
  • Department for Works and Pensions (DWP)
  • Home Office
  • Kent Investigation Officers Group
  • National Health Service
  • HM Revenues & Customs
  • UK Border Agency


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