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Document Sample
Appendix E
Managing the Risk of Fraud –
Self Assessment
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
1. ADOPTING THE RIGHT STRATEGY - KEY ELEMENTS OF A STRATEGIC APPROACH
1.1 Does the organisation have a Yes The Council has an Anti- The Policy and the Strategy will Audit and 2009/10 (for Review of
counter fraud and corruption Fraud, Theft and Corruption need to be reviewed in due course Risk ATF&C Policy and
strategy that can be clearly linked to Policy and Strategy (AFTCP to ensure that it continues to reflect Manager Strategy)
the organisation's overall strategic & S) and a Whistle blowing present practice. The scheduled (via the
objectives? Policy in place. The AFTCP date of review is 2009/10. Corporate
& S was updated and Governance
approved by the Executive in Group)
November 2007
An Anti Fraud and Corruption
leaflet was published and
circulated to all Council and
Liberata staff in October 2007
A whistle blowing leaflet was
circulated in August 2008 and
publicised in the Staff
Newsletter.
st
1.2 Is there a clear remit 'to reduce Yes The AFT&C Strategy makes it There is a need to ensure that there Audit and By 31 March 2010
losses to fraud and corruption and clear that the Council will is a consistent message given to all Risk
corruption to an absolute minimum' seek to recover losses as a staff, Members and Contractors Manager
covering all areas of fraud and result of fraud, theft or used by the Council that Fraud,
corruption affecting the corruptions where possible Theft and Corruption are not
organisation? and financially viable. acceptable. This will be done by:-
The AFT&C Strategy o Promoting awareness of the
identifies the role of various Anti-Fraud, Theft and Corruption
parts of the organisation in Policy;
reducing losses to fraud and o Informing staff/Members of the
this is reinforced by the Council’s stance on F,T & C at
Council’s Financial Procedure induction;
Rules which allocate o Ensuring Contracts include
responsibilities for preventing reference to the Council’ stance;
and detecting fraud. In o Ensuring applications forms for
particular, the AFT&C Council services make it clear
outlines the role of:- that fraud, theft and corruption
o Members are not acceptable.
o Management
o Employees
2
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
o Internal Audit
1.3 Are there effective links Partly The Council has developed Further work needs to be Audit and Audit and Risk Manager
between ‘policy’ work (to develop an AFT&C Policy to provide undertaken to produce a clear plan Risk
an anti-fraud and corruption and direction in relation to its work of actions to be taken to pro-actively Manager By Sept 2009
‘zero tolerance’ culture, create a in this area. Complementing detect, and where necessary,
strong deterrent effect and prevent this an AFT&C Strategy has investigate, fraud.
fraud and corruption by designing been produced to implement
and redesigning policies and the Policy.
systems) and ‘operational’ work (to
detect and investigate fraud and
corruption and seek to apply
sanctions and recover losses where
it is found)?
1.4 Is the full range of integrated Partly The AFT&C Strategy includes A review of the actions to be taken Audit and By Sept 2009
action being taken forward or does a range of actions, some of needs to be undertaken in Risk
the organisation ‘pick and choose’? which have been conjunction with the outcome of this Manager
implemented. self assessment.
1.5 Does the organisation focus on Yes Until 2007/08, no information Each year a report will be submitted Audit and Annually in June of each
outcomes (i.e. reduced losses) and on the Council’ activities to to the Accounts and Audit Risk year.
not just activity (i.e. the number of prevent, detect and Committee on the Council’s Manager
investigations, prosecutions, etc.)? investigate fraud had been activities to detect and prevent
formally reported to fraud, theft and corruption.
Members.
Reports are now prepared
annually and have been
submitted in 2008 and 2009.
1.6 Has the strategy been directly Yes The Anti-Fraud, Theft and The Strategy will be kept under Audit and Annual Review.
agreed by those with political and Corruption Policy and review and updated as and when Risk
executive authority for the Strategy and the Whistle required. Manager
organisation? blowing Policy were reviewed
and approved by the
Council’s Executive.
3
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
2.0 ACCURATELY IDENTIFYING THE RISKS – MEASURING FRAUD AND CORRUPTION LOSSES
2.1 Are fraud and corruption risks Yes o Identified on the o Fraud, theft and Corruption to Audit and o As an when Risk
considered as part of the Council’s Strategic and be considered when Risk Risk Registers are reviewed
organisation’s strategic risk Operational Risk Registers are reviewed. Manager (on at least a quarterly
management arrangements? Register (as required) o Internal Audit to continue using basis)
o Taken into consideration the possibility of fraud, theft o Annually as part of the
in the development of and corruption as key issues in Internal Audit Planning
the Internal Audit Plan. the risk based approach to process (and 3 yearly
audit planning. as part of the Strategic
Planning process).
2.2 Is the organisation seeking to Partly Generally, on the basis of In view of the negligible level of n/a n/a
identify accurately the nature and experience to date and given fraud, theft and corruption
scale of losses to fraud and the robustness of the experienced at the Council, it is not
corruption, using a Council’s present system of considered a good use of resources
internal control, it is not to undertake further work in this
proper definition of fraud based considered necessary to area. This matter will, however, be
in civil law for making accurate commit resources to this subject to annual review as part of
estimates? work. the review of this self assessment.
Professional statistical Should it be necessary to change
methodology for making The Council does, however, this assessment, further work will
accurate estimates and actively participate in the be undertaken.
building in a proper level of National Fraud Initiative
independent validation? which helps to focus limited
resources.
2.3 Does the organisation use Partly The Council uses its past Continued reference to past Audit and Annually as part of the
accurate estimates of losses to knowledge and experience of knowledge and experience will be Risk Internal Audit Planning
make informed judgements about fraud, theft and corruption to used to determine the extent of Manager process.
levels of budgetary investment in determine the amount of investment in work to counter fraud
work to counter fraud and resources required for dealing and corruption.
corruption? with potential occurrences.
The size and workload of the
Benefit Fraud Investigation
Team is a matter of
monitoring by the Client
Management Team of the
Council.
4
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
3.0 CREATING AND MAINTAINING A STRONG STRUCTURE – HAVING THE NECESSARY AUTHORITY AND SUPPORT
3.1 Do those tasked with countering Yes Details of authority are set out No further action necessary n/a n/a
fraud and corruption have the in the:-
appropriate authority needed to
pursue their remit effectively, linked o ATF&C Policy and
to the organisation’s counter fraud Strategy;
and corruption strategy? o Council’s Scheme of
Delegation
o Financial Procedure
Rules
3.2 Is there strong political and Yes The ATF&C Policy and No further action necessary n/a n/a
executive support for work to Strategy has been approved
counter fraud and corruption? by both the Council and the
Executive.
An annual report on activities
around detecting and
preventing fraud, theft and
corruption will be submitted to
the Accounts and Audit
Committee.
3.3 Is there a level of financial Yes The Council uses its past Continued reference to past Audit and Annually as part of the
investment in work to counter fraud knowledge and experience of knowledge and experience will be Risk Internal Audit Planning
and corruption that is proportionate fraud, theft and corruption to used to determine the extent of Manager process.
to the risk that has been identified? determine the amount of investment in work to counter fraud
resources required for dealing and corruption
with potential occurrences.
The size and workload of the
Benefit Fraud Investigation
Team is a matter of
monitoring by the Client
Management Team of the
Council.
5
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
SPECIALIST TRAINING AND ACCREDITION
3.4 Are all those working to counter Partly o Benefit Fraud Training in counter fraud techniques Audit and Training to be determined
fraud and corruption professionally Investigators are to be arranged. Risk as part of annual Personal
trained and accredited for their Professional In Security Manager Development Plans (or
role? (PINS) trained. sooner if possible and
within resources).
o Internal Audit do not
have formalised training
qualifications but attend
the annual Fraud Forum
organised by CIPFA
each year to keep up to
date on fraud issues
3.5 Do those employees who are Yes o Benefit Fraud The provision of ongoing training Relevant Annually as part of the
trained and accredited formally Investigators attend will continue to be identified Service Personal Development
review their skills base and attend refresher training annually as part of the Personal Managers Planning process.
regular refresher courses to ensure provided by National Development Plans of each
they are abreast of new Anti-Fraud Network. member of staff.
developments and legislation?
o The Benefit Fraud
Manager attends a
quarterly network group
of East Lancs authorities
to share good practice
and discuss topical items
of benefit fraud.
o The Audit and Risk
Manager attends CIPFA
Better Governance
Forum workshops and
the annual CIPFA fraud
Forum.
3.6Are all those working to counter Yes Benefit Fraud Investigators No further action n/a n/a
fraud and corruption undertaking and Internal Audit employees
this work in accordance with a clear have signed Codes of
6
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
ethical framework and standards of Conduct pertinent to their
personal conduct? roles in addition to being
subject to the Council’s
overall employee code of
conduct
PROPRIETY CHECKS
3.7 Is an effective propriety Yes o The Council’s Human No further action n/a n/a
checking process – implemented by Resources Section
appropriately trained staff – in place ensures that all
that includes appropriate action appointments are
where individuals fail the check? subject to references.
o Criminal Records
Bureau checks are also
undertaken where it is
considered necessary
for both Members and
Staff.
o When contracts are let,
there is some checking
of the propriety of
contractors
3.8 Does the organisation regularly Yes Internal Audit undertake an The Annual Internal Audit Plan Audit and Annually, as part of the
review its propriety checking and annual audit of the Council’s should continue to include these Risk Audit Planning process.
are random checks carried out to Human Resources reviews as a key risk area. Manager
ensure that it is implemented? procedures and procedures
for letting contracts. The
outcome of these audit is, if
necessary, reported to
Management and thereafter
to the Accounts and Audit
Committee.
DEVELOPING EFFECTIVE RELATIONSHIPS WITH OTHER ORGANISATIONS
3.9 Are there framework Yes o 3 year SLA with No further action n/a n/a
agreements in place to work with Department for Work
other organisations and agencies? and Pensions
7
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
o Subscription to National
Anti Fraud Network
o Joint Working as part of
the National Fraud
Initiative
o Joint working with the
Police as and when
necessary.
3.10 Are the framework agreements Yes As above As above n/a n/a
focussed on the practicalities of
common work?
3.11 Are there regular meetings to Yes o Regular liaison takes No further action n/a n/a
implement and update these place between DWP,
agreements? Benefit Fraud
Investigators and NAFN
o East Lancashire network
of Benefit Managers,
Fraud Managers etc.
4.0 TAKNG ACTION TO TACKLE THE PROBLEM – TAKING THE FULL RANGE OF ACTION AND INTEGRATING DIFFERENT STRANDS
4.1 Is the organisation undertaking Partly Via pro-active fraud work It is accepted that further work Audit and To be determined
the full range of necessary action including:- could be undertaken in this area Risk
(see also 1.3)? learning from best practice Manager /
o Review of AFT&C Policy examples of other organisations Benefit Fraud
and Strategy; Team
o Reviewing Financial
Procedure Rules;
o Producing leaflets on the
AFT&C Policy and
Strategy for all staff;
o Maintaining Risk
Registers to ensure the
potential for fraud, theft
and corruption continue
to be recognised issues;
o Actively participating in
8
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
the National Fraud
Initiative;
CULTURE, DETERRENCE AND PREVENTION FRAMEWORK
4.2 Does the organisation have a Partly o A reminder is circulated Further action is required, for Audit and
clear programme of work attempting to all staff in November example:- Risk
to create a real anti-fraud and /December each year. o Consideration needs to be Manager
corruption and zero tolerance The Whistle blowing given to ways of raising
culture (including strong policy, the AFT&C awareness of the potential for
arrangements to facilitate whistle Policy, Gifts and fraud, theft and corruption and
blowing)? Hospitality Code of how this can be prevented;
Conduct, financial and o Likewise, the Council’s
contract procedure rules arrangements for
are all referred to. Whistleblowing need to be
refreshed and re-launched.
st
o As from 2009 a slot will By 31 July 2009
be taken in the Induction
process for all incoming
staff with regard to
awareness of Anti Fraud,
Theft and Corruption
strategies.
4.3 Are there clear goals for this Yes The aim is always to No further action n/a n/a
work (to maximise the percentage maximise the percentage of
of staff and public who recognise staff and public who
their responsibilities to protect the recognise their
organisation and its resources)? responsibilities and to protect
the organisation and its
resources.
4.4 Is this programme of work being Partly Following the Use of Actions are required which seek to Chief By August 2009
effectively implemented? Resources Assessment for improve the Council’s Use of Finance
2007, the External Auditors Resources scores in this area. Officer
commented that the Council These actions are specifically set
9
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
has ‘a strong anti-fraud out in the Use of Resources Action
culture which covers both Plan.
Council services and its key
partners’
The Council received a score
of 3 for its internal control
system and 3 for having
proper arrangements in place
to promote and ensure
probity and propriety in the
conduct of its business.
4.5 Are there arrangements in place Partly An Anti Fraud Survey will be Further work needs to be Audit and By December 2009
to evaluate the extent to which a launched in June 2009 to all undertaken to assess the results of Risk
real anti-fraud and corruption employees. Consideration to the survey and determine further Manager
culture exists or is developing be given to a similar survey strategy to develop the AF &C
throughout the organisation? for Council Members culture throughout the organisation.
4.6 Are agreements in place with Yes o Regular liaison takes No further action n/a n/a
stakeholder representatives to work place between DWP,
together to counter fraud and Benefit Fraud
corruption? Investigators and NAFN
o East Lancashire network
of Benefit Managers,
Fraud Managers etc.
o 3 year SLA with
Department for Work
and Pensions
o Subscription to National
Anti Fraud Network
o Joint Working as part of
the National Fraud
Initiative
10
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
o Joint working with the
Police as and when
necessary.
4.7 Have arrangements been made Partly As above No further action n/a n/a
to ensure that stakeholder
representatives benefit from
successful counter fraud and
corruption work?
DETERRENCE
st
4.8 Does the organisation have a Partly The Council has approved an Further work is required to promote Audit and By 31 March 2009
clear programme of work attempting AFT&C Policy and Strategy awareness of the Council’s stance Risk
to create a strong deterrent effect? as part of its work to create a on fraud, theft and corruption both Manager
strong deterrent effect. internally with staff, members and /Benefit
contractors and externally to the Fraud Team
public.
This may take the form of better
coverage on the Council’s website,
through local newspapers and
potentially having fraud awareness
campaigns.
4.9 Does the organisation have a Partly o The Council has made
clear programme of work to available the AFT&C
publicise the: Policy and Strategy to all
members of staff and
hostility of the honest Members;
majority to fraud and o A leaflet about the
corruption AFT&C Strategy and
effectiveness of Policy has been
preventative arrangements circulated to all staff and
sophistication of Members;
arrangements to detect o The Council applies
fraud and corruption sanctions appropriate to
professionalism of those the incidence of fraud,
investigating fraud and theft or corruption;
corruption and their ability o Where possible, the
11
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
to uncover evidence Council publicises the
likelihood of proportionate outcome of material
sanctions being applied; fraud investigations;
and o A whistle blowing leaflet
likelihood of losses being was circulated in August
recovered? 2008 and publicised in
the Staff Newsletter.
4.10 Has the organisation Yes o Press releases are made No further action. The Council Audit and Ongoing
successfully publicised work in this jointly by the DWP and seeks to achieve a balance Risk
area? the authority (DWP lead between publication of fraudulent Manager /
role) activity Human
Resources
o Extract from Lancashire Manager /
Evening Telegraph Benefits
Fraud Team
Leader
4.11 Has the publicity been targeted Yes Major frauds involving Publicity to be sought when it is Audit and Ongoing
at the areas of greatest fraud financial loss carried out in considered appropriate to the Risk
losses? partnership with the DWP circumstances of the fraud and the Manager /
need to promote deterrence Benefits
Fraud Team
Leader
PREVENTION
4.12 Does the organisation seek to Yes o As new policies and Continue to encourage involvement Audit and Ongoing
design fraud and corruption out of systems are devised and of Internal Audit in the development Risk
new policies and systems and to where it is considered of policies and systems at an early Manager
revise existing ones to remove appropriate, access to stage to ensure
apparent weaknesses? Internal Audit is available opportunities/weaknesses that
to comment as might result in fraud, theft or
necessary on aspects of corruption are minimised.
the system;
o As part of general
internal audit work, the
Internal Audit Unit review
existing systems and the
application of policies to
determine weaknesses
12
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
that could result in fraud,
theft and corruption.
Recommendations are
made to improve
systems as a
consequence.
4.13 Do concluding reports on Yes For those investigations that Ensure that each report following an Audit and Ongoing
investigations include a specific have taken place, and where investigation has a mandatory Risk
section on identified policy and the policy and systems section for identified weaknesses Manager
systems weaknesses that allowed weaknesses have been and proposed improvements.
the fraud and corruption to take identified, specific
place? recommendations are made
to make improvements in the
systems/policy as a
mechanism to prevent future
potential frauds, theft and
corruption.
4.14 Is there a system for Yes Where weaknesses are No further action n/a n/a
considering and prioritising action to identified as part of the
remove these identified Internal Audit process,
weaknesses? recommendations are made
to auditees which are
prioritised according to:-
o The level of control
weakness (whether it
is major, important or
minor weakness);
o The perceived
financial risk (based
on the value of
potential financial
loss if the
weaknesses are dealt
with)
13
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
DETECTION
4.15 Are there effective ‘whistle Partly Following the Use of Actions are required which seek to Audit an Risk By August 2009
blowing’ arrangements in place? Resources Assessment for improve the Council’s Use of Manager
2007, the External Auditors Resources scores in this area.
commented that the Council These actions are specifically set
has ‘a strong anti-fraud out in the Use of Resources Action
culture which covers both Plan.
Council services and its key
partners’
The Council received a Use
of Resources score of 3 for its
internal control system and 3
for having proper
arrangements in place to
promote and ensure probity
and propriety in the conduct
of its business.
4.16 Are analytical intelligence Yes The Council does not No further action n/a n/a
techniques used to identify potential specifically use its own
fraud and corruption? bespoke analytical
intelligence techniques to
identify potential fraud and
corruption other than through
the normal course of internal
audit work.
The Council does, however,
actively participate in the
National Fraud Initiative
which does such techniques.
4.17 Are there effective Yes As indicated elsewhere, the No further action n/a n/a
arrangements for collating, sharing Council does have
and analysing intelligence? arrangements in place to
collate, share and analyse
intelligence. This is with
organisations such as:-
14
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
o Department for Work
and Pensions;
o National Anti-Fraud
Network;
4.18 Are there arrangements in Yes The AFT&C Strategy includes No further action n/a n/a
place to ensure that suspected a Fraud, Theft and Corruption
cases of fraud or corruption are Response Plan which states
reported promptly to the appropriate clearly, using flowcharts, what
person for further investigation? actions should be taken if
fraud, theft and/or corruption
is reported.
4.19 Are arrangements in place to Yes As indicated above, as part of No further action n/a n/a
ensure that identified potential AFT&C Strategy, there is a
cases are promptly and Response Plan which drives
appropriately investigated? when an investigation is
necessary and how it is
conducted.
4.20 Are proactive exercises Yes Pro-active work is undertaken No further action n/a n/a
undertaken in key areas of fraud as part of the Annual Internal
risk or known systems Plan. Annually, the Audit Plan
weaknesses? is reviewed to determine
areas of key risk (where
policies or systems may have
changed resulting in a
heightened risk of fraud, theft
or corruption).
INVESTIGATION
4.21 Is the organisation’s Partly Following the Use of Further action is need to focus on Audit and By March 2009
investigation work effective? Resources Assessment for outcomes from investigative work, Risk
2007, the External Auditors and in particular the recovery of Manager /
commented that the Council losses arising from fraud, theft Benefit Fraud
has ‘a strong anti-fraud and/or corruption. This self Team
culture which covers both assessment will be the basis of
15
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
Council services and its key developing this work.
partners’
The Council received a score
of 3 for its internal control
system and 3 for having
proper arrangements in place
to promote and ensure
probity and propriety in the
conduct of its business .
The Council’s general
investigative work is
considered to be effective
and in particular in Benefits,
in conjunction with the DWP,
there have been at least 3
significant successes in
uncovering and prosecuting
major fraud.
4.22 Is it carried out in accordance Yes As part of the AFT&C, there No further action n/a n/a
with clear guidance? is a specifically designed
flowchart outlining the
procedures to be followed in
conducting an investigation.
4.23 Do those undertaking Yes The Council’s Financial No further action other than Audit and Ongoing
investigations have the necessary Procedure Rules, Scheme of ensuring that staff skills and Risk
powers, both in law, where Delegation and the knowledge remain up to date in Manager /
necessary, and within the arrangements between the areas such as PACE, RIPA etc Benefit Fraud
organisation? Council and Liberata provide Team
the necessary powers for
staff to undertake
investigations.
Relevant staff have training in
PACE and use of RIPA.
16
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
4.24 Are referrals handled and Yes Each investigation is different No further action n/a n/a
investigations undertaken in a and as a consequence it is
timely manner? not possible to place
timescales on progress.
However, each is handled as
efficiently as possible and is
referred when it is considered
necessary to do so.
4.25 Does the organisation have Partly Following the Use of Further action is needed to focus on Audit and By August 2009
arrangements in place for Resources Assessment for outcomes from investigative work, Risk
assessing the effectiveness of 2007, the External Auditors and in particular the recovery of Manager /
investigations? commented that the Council losses arising from fraud, theft Benefit Fraud
has ‘a strong anti-fraud and/or corruption. This self Team
culture which covers both assessment will be the basis of
Council services and its key developing this work.
partners’
The Council received a score
of 3 for its internal control
system and 3 for having
proper arrangements in place
to promote and ensure
probity and propriety in the
conduct of its business. As
indicated elsewhere, the
External Auditors
SANCTIONS
4.26 Does the organisation have a Yes o The Council has No further action n/a n/a
clear and consistent policy on the disciplinary procedures
application of sanctions where fraud which would be used
or corruption is proven to be where staff commit
present? offences (and
notwithstanding Police
involvement thereafter);
o The Council also has a
Standards Committee
which would deal with
17
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
matters related to
Members;
o In relation to Benefit
Fraud, the Council
utilises those sanctions
available (administrative
penalties for example)
depending on the
circumstances of each
fraud committed.
4.27 Are all possible sanctions – Yes The Council considers all No further action n/a n/a
disciplinary/regulatory, civil and sanctions appropriate to the
criminal – considered? offence committed and in the
context of what is considered
by Management as best in
the public interest.
4.28 Does the consideration of Yes Any consideration of No further action n/a n/a
appropriate sanctions take place at sanctions is only made
the end of the investigation when all following a thorough
the evidence is available? investigation. This is set out
in the Council’s procedures
for investigations.
4.29 Does the organisation monitor Yes Benefit Fraud Team monitors Subject to resources being Audit and By December 09
the extent to which the application the amount of overpayments available, consideration will be Risk
of sanctions is successful? recovered in all sanction given to what further action the Manager /
cases. Council could undertake to Benefit Fraud
Internal Audit apply sanctions determine the extent of success Team
to fraud cases wherever with the application of sanctions
applicable and recover
monies wherever possible.
REDRESS
4.30 Does the organisation have a Yes The Council’s AFT&C Policy The Policy and the Strategy will Corporate 2009/10 (for Review of
clear policy on the recovery of states that the Council will:- need to be reviewed in due course Governance ATF&C Policy and
losses incurred to fraud and to ensure that it continues to reflect Group Strategy)
corruption? ‘Take all necessary and present practice. The scheduled
appropriate actions where date of review is 2009/10.
evidence of fraud, theft and
18
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
corruption comes to light’.
Equally it states that the
Council will pursue
prosecution where it is
considered relevant to do so.
Recent incidences of benefit
fraud demonstrate that the
Council, in conjunction with
other Agencies, will use both
criminal and civil court to
recover losses where
possible.
4.31 Is the organisation effective in Yes During 2008/09, the Council Consider providing monitoring Audit and Ongoing
recovering any losses incurred to has issued 44 sanctions and information on cases other than Risk
fraud and corruption? had successful prosecutions Benefit Fraud Manager/
on 22 occasions. Benefits
Manager
In relation to benefit fraud
overpayments, these are
either recovered from
ongoing benefit entitlement,
direct invoicing or bailiff/legal
action
HB Fraud overpayments and
recovery are monitored on a
quarterly basis and figures for
08/09 were reported to A & A
Committee June 09.
4.32 Does the organisation use the Yes The Council’s AFT&C Policy No further action n/a n/a
criminal and civil law to the full in states that the Council will:-
recovering losses?
‘Take all necessary and
appropriate actions where
evidence of fraud, theft and
corruption comes to light’.
19
Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
Equally it states that the
Council will pursue
prosecution where it is
considered relevant to do so.
Recent incidences of benefit
fraud demonstrate that the
Council, in conjunction with
other Agencies, will use both
criminal and civil court to
recover losses where
possible.
4.33 Does the organisation monitor Yes Given the incidences of fraud, Details of the monitoring will be Audit and Annually, in June of each
proceedings for the recovery of theft and/or corruption incorporated into the Annual Report Risk year.
losses? generally is low, monitoring on Benefits work which will be Manager /
of the proceedings for the reported to the Accounts and Audit Benefit Fraud
recovery of losses is Committee in June of each year. Team
undertaken on a case by
case basis.
In relation to Benefits,
monitoring of recovery in
relation to fraud is monitored
by Liberata and is reported
along with other information
on overpayments
4.34 What is the organisation’s n/a This information is being n/a n/a n/a
successful recovery rate? collated at present
5.0 DEFINING SUCCESS – FOCUSING ON OUTCOMES AND NOT MERELY ACTIVITY
5.1 Are there clear outcomes Yes The ultimate aim of work to No further action n/a n/a
described for work to counter fraud counter fraud, theft and
and corruption? corruption is to minimise the
occurrence of such activity
and therefore the financial
loss to the Council and tax
payers of Pendle.
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Yes /
No / Target date for
Action Partly Evidence / reference Further Action to be Taken By Who? completion
The AFT&C Policy and
Strategy details clearly the
outcomes anticipated from
the work undertaken in this
area.
5.2 Do the desired outcomes relate Yes The AFT&C Policy and No further action n/a n/a
to the actual sums lost to fraud and Strategy indicate that the
corruption? Council outcome of work in
this area is to seek to recover
losses as a result of fraud,
theft and corruption.
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