Contents

  1. Introduction to the anti-fraud, anti-bribery, anti-money laundering and anti-corruption policy
  2. Regulatory framework – scope of policy
  3. Responsibilities
  4. Anti-money laundering
  5. Expectations
  6. Reporting fraud, bribery and corruption
  7. Client identification procedure
  8. Record keeping procedures
  9. Risk assessment, management and internal control
  10. Gifts and hospitality
  11. Proactive anti-fraud initiatives
  12. Raising concerns (whistleblowing)
  13. Annex1 – Bexley’s procedural and regulatory framework
  14. Annex2 - statutory framework
  15. Annex3 - London Borough of Bexley - code of conduct
  16. Annex4 - anti-fraud, anti-bribery, anti-money laundering and anti-corruption policy

1. Introduction to the anti-fraud, anti-bribery, anti-money laundering and anti-corruption policy

The London Borough of Bexley (‘the Council’) is responsible for maintaining good systems of control and is committed to combating fraud and corruption. To maintain these good systems, this Policy (‘the Council’s Policy’ or ‘the Policy’) aims to reinforce the Council's commitment.

The Council's Policy is designed to:

  • identify a clear pathway for investigation
  • encourage prevention
  • promote detection

The document relates to Members, Senior Management, Council staff, contractors (and their staff), consultants and workers (agency staff or otherwise).