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Anti-Fraud & Corruption Policy and Procedures


  1. Fraud
    1. The legal definition of fraud contained within the Fraud Act 2006 includes; fraud by false representation; fraud by failing to disclose information and fraud by abuse of position. Fraud is typically associated with financial loss however this policy relates to acts of dishonesty 3 Version 2.0, Owner: Head of Governance 27/02/2017. Review: 27/02/2018 whether or not financial loss is incurred. For the purposes of these procedures fraud may include but is not limited to:
      1. the intentional distorting of statements or other records by persons internal or external to the Combined Authority which is carried out to conceal the misappropriation of assets, evasion of liabilities or otherwise for gain;
      2. unauthorised use of the Combined Authority’s property; or
      3. theft of monies or other property of the Combined Authority by persons internal to the Combined Authority.
    2. The theft of the Combined Authority’s property carried out by persons external to the Combined Authority through for example break-ins, burglary and opportunist theft falls outside the scope of the Anti-Fraud and Corruption Policy. Thefts of this nature should continue to be reported by Chief Officers directly to Internal Audit and the police in the normal way.
    3. Fraud is a deliberate act of commission or omission by an individual or group of individuals. Fraud can occur in a number of ways including:
      1. fraud perpetrated against the Combined Authority by members of the public or other third parties;
      2. fraud perpetrated against the Combined Authority by Members or officers of the Combined Authority
      3. fraud perpetrated jointly by members of the public or other third parties in collusion with officers or Members of the Combined Authority.
    4. Areas which may be most at risk in respect of fraud include but are not exclusively related to the following:
      1. cash collection (any situation where cash or cheques are received or collected) – misappropriation, failure to account, borrowing by delaying paying monies in, falsifying of receipts, not issuing receipts;
      2. credit income – suppression of invoices, issuing invoices for wrong amounts, unauthorised writing off of debts;
      3. payroll – falsification of records (time sheets, overtime claims); creation of fictitious officers;
      4. creditor payments – payments for work not completed or not in accordance with the specification, or for goods not supplied or not in accordance with the original order;
      5. expenses claims – over claiming of expenses;
      6. false, fictitious or contrived claims. The unauthorised setting up or amendment of claims by officers (including payments to self, family, friends etc.). Officers aiding or abetting third parties in the completion or submission of false claims;
      7. bank accounts and imprest accounts – use of accounts for unauthorised purposes;
      8. equipment and vehicles – unauthorised personal use.
  2. Corruption
    1. Corruption is defined as the offering, giving soliciting or acceptance of an inducement or reward that may influence the action of any person.
    2. The main law relating to corruption in public bodies is contained the Bribery Act 2010
    3. The Bribery Act 2010 creates four new criminal offences:
      1. a general offence covering offering, promising or giving a bribe
      2. a general offence covering requesting, agreeing to receive or accepting a bribe
      3. a separate offence of bribing a foreign official to obtain or retain business;
      4. a strict liability offence for commercial organisations where they fail to prevent bribery by those acting on their behalf.
    4. The Act includes severe penalties for offences. Individuals can receive unlimited fines and up to a ten year custodial sentence; organisations can receive unlimited fines. Senior officers can also be convicted of an offence where they are deemed to have given their consent or connivance to giving or receiving a bribe or bribing a foreign public official. These offences could involve Members or officers of the Combined Authority, members of the public or other third parties.
    5. Areas which may be most at risk in respect of corruption include but are not exclusively related to the following:
      1. tendering and award of contracts;
      2. settlement of contractors’ claims for loss and expense, compensation, additional payments, or work not done or substandard;
      3. award of permissions, consents, licences;
      4. lettings; and
      5. disposals of assets.