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

11. Proactive anti-fraud initiatives

  • The Council must take steps to prevent fraud and corruption. The Council will regularly review and update the written rules
  • managers must ensure that suitable levels of internal checking are included in working procedures, particularly financial procedures. It is important that duties are organised so that no one person can carry out a complete transaction without some form of checking process being built into the system
  • managers must include and consider fraud risk on their departmental risk registers in accordance
  • managers are responsible for ensuring that pre-employment checks, appropriate to the nature of the post, are carried out. These may include checks on identity, qualifications, previous employment, permission to work in the UK, credit status and DBS. This applies to both permanent and temporary staff
  • managers are responsible for ensuring adequate and proportionate customer due diligence checks and anti-bribery measures are followed in any pre- and post-engagement with suppliers and/or contractors. All procurement exercises must be undertaken in accordance with the Corporate Procurement Processes
  • The Council will support the Police and other external agencies, such as local Housing Associations, the Department for Work and Pensions (DWP) and the Cabinet Office, in preventing fraud and corruption. The Council has established proper arrangements for co-operation and joint working with outside bodies and supports any initiatives aimed at detecting fraud and corruption
  • The Council also recognises the importance of criminal prosecution in deterring fraud and corruption and to this end will seek the prosecution of offenders where it has sufficient evidence to support a prosecution and where it is in the public interest
  • The Council supports the National Fraud Initiative (NFI), which is the country’s largest public sector antifraud programme. It is a computer-based system, which matches information held by several different organisations including local authorities, the NHS, police authorities, local probation boards and fire and rescue authorities across England. The matching process enables public bodies to share and compare information through a secure website, and to identify those taking services or money that they are not entitled to
  • in addition to NFI, the Council will continue to participate in Anti-Fraud initiatives established by the DWP’s Housing Benefit Matching Service