1.1 Bournemouth Borough Council expects the highest standards of conduct and integrity, not only from its employees but also from Elected Members and members of the public who have dealings with it. The Statement of Anti-Fraud and Corruption Strategy, therefore, applies to employees, Elected Members and members of the public who have dealings with Bournemouth Borough Council. All these groups are reminded that as per the Statement of Code of Conduct for Employees, the Council is fully aware of the high expectations of the public and the extent of scrutiny to which large public bodies are subject.

1.2 The Council is committed to the elimination of fraud and corruption. For this purpose:

• Fraud is any act of deception which acts to the financial detriment of the Council, and
• Corruption describes a situation where an Elected Member or Employee, either alone or with another person(s), carries out, or fails to carry out, an action as a result of an inducement or bribe.

The Council is determined to protect itself and the public from such unlawful activities, whether they are attempted from within the Authority, or by an outside individual, group or organisation.

2.0 Prevention of Fraud and Corruption

2.1 Framework

2.1.1 The Council operates within a framework of:
Statutes
Regulations
Codes of Conduct
Proper Systems and Procedures.

These are designed to prevent fraud and corruption and to enhance accountability to the public.

2.1.2 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. In Bournemouth, this nominated officer is the Head of Financial Services.

2.1.3 The Council has in place systems and procedures that incorporate internal controls, including separation of duties. Managers are required to ensure that such controls are properly maintained.

The Internal Audit Section independently reviews the existence and effectiveness of these controls.

2.1.4 The Head of Law and Administration is the Council’s Monitoring Officer, with responsibility under Section 5 of the Local Government and Housing Act, 1989, to guard against, among other things, illegality, impropriety and maladministration in the Council’s affairs.

2.1.5 Arrangements are in place which encourage the exchange of information on fraud and corruption between the Council and other agencies, such as:
The Police
The External Auditor
Government Departments
Other Local Authorities

2.2 Employees

2.2.1 Employees are bound by the above provisions and, where appropriate, also by the standards laid down by their Professional Bodies.

2.2.2 Section 117 of the Local Government Act, 1972, requires that employees must disclose any personal interest in contracts that have been, or are proposed to be, entered into by the Council.

Section 117 also prohibits the acceptance of fees, gifts or rewards; other than by way of proper remuneration from the Council, or otherwise where this has been specifically authorised by a Director and where it has been recorded in the Hospitality Register maintained by the Chief Executive.

All these requirements are reinforced by the Council’s Standing Orders.

2.2.3 The Council’s Standing Orders on contracts and financial matters place an obligation on employees to act in accordance with those rules and also best practice, when dealing with the Council’s affairs.

2.2.4 The Council’s Code of Conduct for Employees requires them:

• To declare Membership of outside bodies and organisations as defined in the Code of Conduct.
• To declare to their Head of Establishment, Head of Business Unit or Director, as appropriate, any outside paid employment or business, which must not conflict with the interests of the Authority.
• Not to accept significant personal gifts or hospitality. Any gifts or hospitality accepted or declined must be recorded in the Register that is held by the Chief Executive.

2.2.5 A Disciplinary Procedure is operated by the Council, which applies to all employees. This contains provisions for dealing with, among other things, allegations of fraud and corruption.

2.3 Elected Members

2.3.1 Elected Members are required to operate within:

• The Council’s Standing Orders
• The National Code of Local Government Conduct
• Sections 94 – 97 of the Local Government Act, 1972

2.3.2 These matters are brought to the attention of Elected Members as part of the induction procedure. Members should refer any queries to the Head of Law and Administration.

The Council operates a style of open management whereby the Chief Executive, Directors; Heads of Business Unit and Heads of Establishment have an ‘open door’ policy. This is reinforced by the following paragraphs.

3.1 Employees

3.1.1 Employees are encouraged and, indeed, expected to raise any concerns that they may have, without fear of recrimination. Such concerns will be treated in the strictest confidence and will be properly investigated. As far as possible, a request from an employee for anonymity will be respected.

3.1.2 In the first instance, an employee can choose to contact his/her line manager, or approach one of the following officers:

• The Head of Financial Services (Tel: 01202 451537 – direct line)
• The Council’s Chief Auditor (Tel: 01202 451283 – direct line)
• The Director of Central Services (Tel: 01202 451131 – direct line)
• The Council’s Chief Executive (Tel: 01202 451130 – direct line)
• A Director (Tel: 01202 451451 – main switchboard)

3.2 Elected Members

3.2.1 Elected Members should normally report any concerns to:

• The Chief Executive (Tel: 01202 451130 – direct line)
• The Director of Central Services (Tel: 01202 451131 – direct line)
• The Head of Financial Services (Tel: 01202 451537 – direct line)
• The Head of Law and Administration (Tel: 01202 451167 -– direct line)

3.3 The Public

3.3.1 The General Public are also encouraged to report any concerns through any one of the above Officers

3.4 Any information concerning suspected fraud or corruption involving an Elected Member will be referred to the Chief Executive. Such matters will then normally be referred to the District Auditor and/or the Police.

3.5 In the event that any person feels unable to raise their concerns with one of the Council Officers named above, they may wish to report those concerns to the District Auditor, as the Council’s External Auditor (Tel: 01962 852717), or otherwise to the Police.

4.0 Action following the Allegation

4.1 Senior Managers

4.1.1 Any senior manager who has received information about any suspected fraud or corruption must report it immediately to the Head of Financial Services who will, where appropriate, ensure that the Chief Executive is also informed.

4.1.2 Senior managers of the Authority will also:

• Co-operate fully with Internal Audit and the Police during any investigation.
• Implement the Council’s Disciplinary Procedure, where appropriate.
• Take prompt action to remedy any weaknesses discovered in internal control procedures.
• Deal swiftly, fairly and firmly with those who offend against the Council.

4.2 Internal Audit

In respect of any case of suspected fraud or corruption discovered by or referred to them, Internal Audit will:

• Deal promptly with the matter.
• Maintain full documentation of all evidence received.
• Ensure that the evidence is sound and adequately supported.
• Report findings to the Head of Financial Services and also to the Chief Executive, where appropriate.
• With the agreement of the Chief Executive, refer the matter to the Police, as appropriate.
• Assist in any disciplinary proceedings.

4.3 Abuse of the Reporting Process

The reporting and investigation process must not be misused. Any abuse, such as raising allegations without reasonable foundation or else maliciously will be dealt with as follows:

4.3.1 Employees

Such matters will be dealt with in accordance with the Council’s Disciplinary Procedure.

4.3.2 Elected Members

Cases involving Elected Members will be referred to the relevant Political Group Leader(s) for appropriate action to be taken.

4.3.3 The Public

Where members of the General Public are suspected of misusing the reporting and investigation process, details will be referred to the Head of Law and Administration, for consideration of any necessary Civil or Criminal action, involving the Police where appropriate.

5.0 Conclusion

5.1 This statement sets out the Council’s clear commitment to fight fraud and corruption and also its arrangements for the prevention, detection and investigation of such activities. The Council expects the highest standard of probity in all its activities.