North East Lincolnshire Council

Fraud and corruption

As with other large organisations, the size and nature of the council’s services puts it at risk to loss due to fraud and corruption both from within the council and outside it.

We are committed to making sure that the opportunity for fraud and corruption is reduced to the lowest possible risk. Where there is the possibility of fraud, corruption and other related problems, we will deal with it in a firm, consistent and controlled manner.

Anti fraud strategy

View our Anti Fraud strategy (PDF).

An important part of this approach is the anti-fraud strategy which the council uses to advise and guide members and staff on its approach to the serious issues of fraud and corruption. This document provides an overview of our policy in this matter and includes a fraud response plan which provides more detailed guidance on how we will deal with fraud and corruption.

The main message is that we expect all members, employees, consultants, contractors, and service users, to be fair and honest, and to provide any help, information and support we need to deal with fraud and corruption.

We annually report the councils anti-fraud activities. These can be found in the documents section below.

Policies relating to the fraud strategy can be viewed below using the expandable menu.

You can report a fraud by telephoning the council’s 24 hour fraud hotline on 01472 326298 option 1. A voicemail facility is available out of hours and weekends.

Any type of fraud where you believe someone has told the council something that is not true in order to receive some financial help or other assistance can be reported on the fraud hotline, including:

Council Tax Support fraud – If you believe someone is claiming help to pay their Council Tax that they shouldn’t be, for example, because they have a partner who has moved in with them or they have started work.  Alternatively you can report Council Tax Support fraud online.

Council Tax Discount Fraud – If you believe someone is receiving a discount on the amount of Council Tax they have to pay that they shouldn’t be receiving, for example, a person receiving a single adult residency discount when they have other adults living in their home or a student discount when they are no longer a student.

Blue badge fraud – If you believe that someone is misusing a disabled persons blue badge. This could include someone other than the badge holder  using the badge for their own benefit. View more information on our Blue badge scheme page.

Insurance fraud – If you believe that someone has made a false insurance claim against the council.

Employee & Councillor Fraud – If you suspect that an employee or councillor is involved in any fraudulent or corrupt act, this should be reported in line with our Whistleblowing Policy (PDF).

Benefit fraud

If you believe that someone is committing Housing Benefit fraud, please report this to the Department for Work & Pensions:

Helpline: 0800 854 4400 (textphone 0800 320 0512)

Post:  NBFH, PO Box 224, Preston, PR1 1GP

Money laundering is the process by which the proceeds of crime are changed so that they appear to come from a legitimate source.

The council’s money laundering policy explains what money laundering is and the legal and regulative framework that is in place to govern it. It also specifies the processes the council needs to put in place to ensure that it does all it can to prevent the council and its employees being exposed to money laundering and to ensure that the council complies with all legal and regulatory requirements.

The key aspects of the policy are the:

  • designation of the Chief Financial Officer as the Money Laundering Reporting Officer (MLRO)
  • establishment of procedures for employees/members to report any suspicions to the MLRO
  • establishment of procedures for employees/members to report any suspicions to the MLRO
  • provision of training to relevant employees/elected members in respect of the requirements of the legislation including the identification of suspicious transactions, identity verification and reporting procedures.

There are a number of money laundering offences specified in the regulatory framework that the council and its employees could be subject to. However, given the nature of the council’s activities the overall risks to the council of contravening the legislation are considered low. The council cannot however be immune from the risks surrounding money laundering.

Read our Anti-Money Laundering Policy (PDF).

Bribery is an inducement or reward offered, promised or provided to gain personal, commercial, regulatory or contractual advantage. It is a criminal offence.

To use a third party as a conduit to channel bribes to others is a criminal offence. We do not, and will not, engage indirectly in or otherwise encourage bribery.

We are committed to the prevention, deterrence and detection of bribery. We have zero-tolerance towards bribery, and prohibits bribery in any form whether direct or indirect, and by or for the council. We do not, and will not, pay bribes or offer improper inducements to anyone for any purpose, nor do we or will we, accept bribes or improper inducements.

A breach of policies or procedures relating to bribery could lead to disciplinary action.

The Bribery Act

The Bribery Act came in to force 1 July 2011 and may have an impact on the activities of the council.

There are four key offences under the Act:

  • bribery of another person (section 1)
  • accepting a bribe (section 2)
  • bribing a foreign official (section 6)
  • failing to prevent bribery (section 7)

The offences carry criminal penalties for individuals and organisations. For individuals, a maximum prison sentence of ten years and/or an unlimited fine can be imposed; for organisations, an unlimited fine can be imposed.

Action

We have reviewed our anti-bribery policy and procedures and need to ensure they are sufficiently robust to prevent bribery and to mitigate the risk of committing a bribery offence.

Read our Anti-Bribery Policy (PDF).

The further action we take needs to be proportionate to the risk the council is exposed to. We will firstly carry out an organisation-wide risk assessment. Dependent on those results we can then determine the activity required to implement, review or change procedures so that we comply with the 6 principles laid down in the Act.

  • Up-to-date and regular risk assessment
  • Procedures proportionate to the risk
  • Top-level commitment
  • Due diligence
  • Communication and training
  • Monitoring and review

If you have a concern regarding a suspected instance of bribery or corruption, please speak up – your information and assistance will help. The sooner you act, the sooner it can be resolved, You can raise your concerns through the council’s whistleblowing policy.

For further information about the Bribery Act and the council’s anti bribery policies please contact us by email at internalaudit@nelincs.gov.uk or by phone on 01472 323799.

North East Lincolnshire Council is committed to the highest possible standards of openness, probity and accountability in all its affairs. It is determined to develop a culture of honesty and opposition to fraud and corruption.

This Fraud Response Plan reinforces the council’s robust approach by setting out the ways in which employees or members of the public can voice their concerns about suspected fraud or corruption. It also outlines how the council will deal with such allegations.

Read our Fraud Response Plan (PDF).

We are required by law to protect the public funds that it administers. It may share some information with other bodies responsible for auditing or administering public funds, in order to prevent and detect fraud. It may also share this information with other bodies responsible for auditing or administering public funds for these purposes.

The Cabinet Office is responsible for auditing the accounts of the council. It is also responsible for carrying out data matching exercises.

Data matching involves comparing computer records held by one body against other computer records held by the same or another body to see how far they match. This is usually personal information. Computerised data matching allows potentially fraudulent claims and payments to be identified. Where a match is found it shows that there is an inconsistency which needs further investigation. No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.

The Cabinet Office requires us to take part in a data matching exercise to assist in the prevention and detection of fraud. We have to give some sets of data to the Cabinet Office for matching in each exercise, and these are set out in the guidance, which can be found on the Gov.uk website.

From 1 April 2015, responsibility for National Fraud Initiative (NFI) passed from the Audit Commission to the Cabinet Office. Future NFI exercises will use the powers given to the Minister for the Cabinet Office by Part 6 of the Local Audit and Accountability Act 2014. The existing code of data matching practice will continue in effect until the Minister for the Cabinet Office issues a new code.

Data matching follows a Code of Practice that you can find on the Gov.uk website.

For further information on the legal powers and the reasons why it matches particular information, visit the Gov.uk website.

Our policy on raising concerns, which includes whistleblowing has recently been updated. Its aim is to encourage employees, councillors and members of the public to express any concerns they have about illegal or illegitimate practices involving the council or those organisations delivering services on its behalf, without fear of victimisation, discrimination or disadvantage.

An example of whistleblowing might be theft or misuse of council resources, a breach of safety regulations or where information relating to wrongdoing is being covered up.

Read our Whistleblowing Policy (PDF).

Raising a concern

If you would like to tell us about what you believe is an illegal or illegitimate practice involving the council or one of its partner organisations, please contact us by email at res-customerservices@nelincs.gov.uk or by phone on 01472 326298.

How will my referral be dealt with?

All referrals are confidential and will be treated sensitively. We will channel them to the most appropriate officer and will keep you informed of who is dealing with the referral and how.

You will not be given any copies of investigative reports or audits, but we may advise you informally of the conclusions of the investigation.

Not all whistleblowing referrals will warrant a full investigation as it may be that the matter can be resolved informally.

North East Lincolnshire Council’s policy and employee guidance relating to the Regulation of Investigatory Powers Act 2000 (RIPA)

It is sometimes necessary for the Council to use covert surveillance, obtain communications data or deploy an undercover officer or informant as part of criminal investigations to protect the public finances or the health and well-being of the public.

The Regulation of Investigatory Powers Act 2000 (RIPA) provides a framework to ensure that any such interference with an individual’s right to privacy is lawful and can be justified.

To support the use of RIPA, the Council has a corporate RIPA policy and has developed a RIPA Employee Guide, to assist officers on the use of RIPA powers. The documents can be accessed by opening the links under Document Downloads on this page.