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

3. Responsibilities

The roles and responsibilities of Members, the Council and its officers are set out below:

GroupResponsibility
CouncilThe Council must ensure value for money, accountability, and effective use of resources across all services.
Elected MembersMembers must act with integrity, uphold the law, and ensure Council resources are used efficiently and effectively.
Chief ExecutiveThe Chief Executive oversees the Authority’s Paid Service and is informed where fraud, corruption, or irregularities are suspected.
DirectorsDirectors ensure departments comply with Financial Regulations and have suitable systems and controls in place.
Monitoring Officer / Deputy Director Legal and Democratic ServicesResponsible for reporting unlawful actions, maladministration, and acting as the Money Laundering Reporting Officer (MLRO).
Director of Finance and Corporate ServicesResponsible for the proper administration of financial affairs and determining investigations into suspected fraud or corruption.
Internal Audit, Counter Fraud and Risk ServiceInvestigates alleged fraud and corruption, reviews systems and procedures, and raises fraud awareness across the Council.
Deputy Directors and Heads of ServiceMust report suspected fraud or corruption and consider fraud risks within operational risk registers.
ManagersResponsible for maintaining internal controls, safeguarding resources, and preventing and detecting fraud and corruption.
StaffAll staff must report suspected fraud or irregularities to their Deputy Director or Head of Service.
Human ResourcesSupports investigations into fraud or corruption and initiates disciplinary action where appropriate.
External AuditReviews the Council’s arrangements for preventing and detecting fraud, corruption, and irregularity.
General Purposes and Audit Committee (GP&A Committee)Oversees internal control, risk management, financial reporting, and anti-fraud and whistleblowing arrangements.