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Counter Fraud Corruption Strategy

Last updated on: 09-Apr-2021

6. Roles and responsibilities

Statutory Officers

The Council has a statutory responsibility, under Section 151 of the Local Government Act 1972, to ensure the proper administration of its financial affairs and also to nominate one of its Officers to take responsibility for those affairs. The Council’s nominated Section 151 Officer is the Director of Corporate Services.

Their responsibilities include (but are not limited to):

  • reporting to Members and the External Auditors if the Council, or one of its representatives makes, or is about to make, a decision which is unlawful, or involves illegal expenditure or potential financial loss (Local Government Finance Act 1988 s.114)
  • Ensuring that public monies are spent appropriately under their duty to ‘protect the public purse’,
  • Liaising with the Council’s appointed Auditors.

Other operational duties relating specifically to the prevention, detection and investigation of fraud are delegated to the Head of Internal Audit & Counter Fraud.

The Council’s Monitoring Officer is responsible under Section 5 of the Local Government and Housing Act 1989 to guard against, inter alia, illegality, impropriety, and maladministration in the Council’s affairs.


All managers are responsible for:

  • maintaining internal control systems and ensuring that the Council’s resources and activities are properly applied in the manner intended
  • identifying the risks to which systems and procedures are exposed
  • developing and maintaining effective controls to prevent and detect fraud
  • ensuring that controls are being complied with and their systems continue to operate effectively
  • implementing new controls to reduce the risk of similar fraud occurring where frauds have taken place

Any Manager with information about suspected fraud, bribery or corruption activity must report this immediately to the Head of Internal Audit & Counter Fraud. Managers are also responsible for:

  • recording and securing all evidence received and collected
  • ensuring that evidence is sound and adequately supported
  • implementing Council disciplinary procedures where appropriate


Every member of staff is responsible for:

  • their own conduct and for contributing towards the safeguarding of corporate standards (including declarations of interest, gifts and hospitality offered and received, private working, Whistleblowing, etc)
  • acting with propriety in the use of Council’s resources and the handling and use of funds whether they are involved with cash, receipts, payments, or dealing with suppliers
  • conducting themselves with selflessness, integrity, objectivity, accountability, openness, honesty, and leadership
  • being alert to the possibility that unusual events or transactions could be indicators of fraud
  • alerting their manager when they believe the opportunity for fraud exists e.g., because of poor procedures or lack of effective oversight
  • reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events
  • cooperating fully with whoever is conducting internal checks, reviews, or fraud investigations.

Contractors, suppliers and consultants

Those organisations employed to work on behalf of the Council are expected to maintain strong counter fraud principles. The Council’s contract partners will be expected to have adequate recruitment procedures and controls when they are administering finance on behalf of the Council.

The Council expects its partners to have adequate controls in place to minimise fraud and to provide access to their financial records as they relate to the Council’s finances, and their staff will be required to assist fully in any investigation.

The Council will seek the strongest available sanctions against contractors that commit fraud against the Council or who commit fraud against public funds. The Council will request that the organisation takes necessary action against the individual and the Council will require them to be removed from its account.

Internal Audit & Counter Fraud

The Council’s Internal Audit team is responsible for examining, evaluating and reporting on the adequacy of the control environment. They evaluate its effectiveness in achieving the organisation's objectives. This work includes the review of the existence and effectiveness of the Council's internal control arrangements.

Any review work undertaken by the internal audit function will give due consideration to the risk of fraud or corruption within the area subject to audit and where necessary will make recommendations to put in place or improve the design of an effective control environment to prevent fraud, bribery, and corruption.

The council’s Counter Fraud function is responsible for:

  • acting as the Council’s consultant on issues of fraud and corruption
  • completing assessments of the Council’s fraud risks associated with each of the key organisational objectives
  • establishing an effective counter fraud response plan, in proportion to the level of fraud risk identified
  • undertaking proactive work to support management in strengthening fraud resilience
  • undertaking proactive work to identify fraud committed against the Council
  • ensuring that appropriate counter fraud training is made available to Members, Directors and staff as required
  • ensuring that appropriate action is taken to minimise the risk of identified frauds occurring again in the future
  • establishing appropriate mechanisms for:
    • reporting fraud risk issues
    • reporting suspicions of fraud or corruption
    • reporting significant incidents of fraud or attempted fraud to the Chief Executive
  • the investigation of allegations and suspicions of internal fraud or corruption, including advising and leading the Council, in conjunction with Human Resources (HR) and Legal Services, with regard to prosecution, disciplinary, or alternative sanctions
  • the investigation of allegations and suspicions of fraud perpetrated against the council by third parties, including advising and leading the Council, in conjunction with Legal Services, with regard to prosecution or alternative sanctions

Conclusions to all investigations will be based on fact, allowing management to take forward any required disciplinary and/or criminal proceedings as they determine appropriate.

Once an investigation is completed the Counter Fraud function may have responsibilities in relation to:

  • recommending improvements to systems
  • attendance at disciplinary hearings and tribunals
  • attendance at Court as a witness
  • reporting to the Finance & Audit Committee

External Audit

As part of its statutory duties, the External Auditor has specific responsibilities for:

  • reviewing the stewardship of public money
  • considering whether the Council has adequate arrangements in place to prevent fraud and corruption

The External Auditor also has powers to independently investigate fraud and corruption.

Elected Members

Each elected member of the Council is responsible for:

  • their own conduct and for contributing towards the safeguarding of corporate standards (including declarations of interest, gifts and hospitality offered and received, Whistleblowing, etc)
  • contributing towards the safeguarding of corporate standards by compliance with the Members Code of Conduct

Members of the Finance & Audit Committee will also have responsibility for oversight of the councils Audit & Counter Fraud Service and will receive regular reports detailing (but not limited to):

  • the performance of the service
  • the findings and recommendations resulting from completed assurance reviews
  • progress in relation to key activities, such as participation in NFI
  • the results of identified fraud cases, including the value involved in proven offences and details of actions taken


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