Anti bribery Risk Assessment
The Deputy Chief Executive provided a presentation on the arrangements in place for anti-fraud, bribery and corruption. The Chief Internal Auditor confirmed that Internal Audit considered the CIPFA tracker report and data analysis to identify key frauds nationally, their relevance to Monmouthshire and to ensure appropriate mitigation is in place. Following the presentation, questions and feedback were invited:
· A Member asked about cyber risk, specifically:
- if staff training and refresher courses are available;
- if it is mandatory for relevant staff;
- how the profile of anti-fraud, bribery and corruption is raised with staff; and
- if there is a whistleblowing policy.
The Deputy Chief Executive confirmed the existence of a whistleblowing policy; communicated to staff upon induction. It was accepted that the training is a work in progress, also the degree to which it is mandatory. Work is in hand to introduce a new learning management system to assess individual training needs, including mandatory training for each role.
The Chief Internal Auditor informed the Committee that the draft training for anti-fraud, bribery and corruption had been presented to the previous Committee and was rolled out to Internal Audit and Procurement staff. There is further refinement required before further roll out to all relevant staff. The Anti-fraud, Bribery and Corruption Policy is available on the Intranet and will be on the Internal Audit page on The Hub. The Whistleblowing Policy is available on The Hub should a member of staff wish to report concerns. Induction training will include online anti-fraud, bribery and corruption training.
Regarding cyber risk, the Deputy Chief Executive noted that this is contained in the Strategic Risk Register. An annual report on the Management of Cyber Security is on the Forward Work Plan and the previous report will be made securely available to committee members.
· A Member asked if there is enhanced vetting for key staff. The Deputy Chief Executive explained that safeguarding checks are made via DBS (Disclosure and Barring Service). There are no financial checks or checks for criminal activity. The Deputy Chief Executive will contact the Member outside the meeting to discuss further.
· A Member enquired about any benefits or impact on procurement due to the collaboration with Cardiff City Council. The Deputy Chief Executive explained that it is proving to be a good collaboration that has enhanced capability and expertise. Other councils in the region are now considering the same arrangement. It was explained that the procurement strategy is scrutinised by the Performance and Overview Scrutiny Committee. The Chief Internal Auditor explained that audits include checks on compliance with council policies and procedures including the Contract Procedure Rules and Financial Procedure Rules.
· A Member queried if there is a user-friendly guide for raising concerns (including a process to determine the level of concern). The process for members of the public to raise concerns was questioned. The Deputy Chief Executive informed the Committee that the policy will be updated this financial year to include simple guidance. The Chief internal Auditor explained that there are several ways an allegation is reported. Often concerns will be made directly to him. An assessment in terms of substance will be made. If appropriate a direct referral will be made to the Police. Members were informed that they may make concerns relating to bribery, fraud, or corruption to the Chief Internal Auditor. All new Members are to be made aware of this route of referral.
The Committee considered the Council’s approach to anti-bribery, fraud, and corruption. Overall, it was considered that the arrangements are effective. There is a relatively low incidence of fraud but no room for complacency especially in respect of cyber security.
- Audit Committee - Anti-Bribery update and risk assessment - Oct 2022 -0.2, item 4. PDF 213 KB
- Anti-Fraud Bribery and Corruption Policy Statement - Revised and Updated 1, item 4. PDF 221 KB