Anti Fraud and Anti Corruption Policy

This policy offers clear guidance for councillors, employees, contractors, suppliers, partners, volunteers and service users on the council’s stance and arrangements to counter fraud and corruption. It aims to deter wrongdoing, encourage reporting, and safeguard public assets by embedding proportionate controls, awareness and assurance across services.

2.1 Links to the Council Strategy

Community Resilience & Wellbeing:

• Community resilience – Promotion of fraud awareness and development of fraud risk management supports development of resilient communities.
• Listening and community engagement: Transparency and robust governance arrangements serve to foster trust between the council and the public.
• Equality, diversity and inclusion: Ensuring a fair and consistent handling of fraud cases supports fair treatment across all communities.

Local Economy:

• Community wealth building: Ensuring a fair distribution of resources, preventing corruption that could undermine growth.
• Planning / support for local retail – Supports a fair procurement and contract practice giving local business an equal opportunity.
• Support local land industries – prevents fraud in land used and development schemes protecting local agriculture and land-based enterprises.
• Start, scale and invest – Safeguarding investment funds and grants encouraging business growth.
• Rural tourism – Ensures tourism funding is used appropriately enhancing local attractions and infrastructure.
• Sustainable construction and retrofit – Prevents fraud in construction contracts and retrofit schemes supporting green and ethical development.

2.2 National Context

The UK Government unveiled its Fraud Strategy 2026-2029 (the strategy) setting out how the government will combat fraud against individuals and businesses over the period 2026 to 2029. The strategy will see government, regulators, law enforcement, national security agencies, industry and nonprofit organisations collaborate to implement a three-pronged strategy: Disrupt, Safeguard, Respond.

Fraud

Any act of dishonesty intended to secure gain or cause loss, including misrepresentation, concealment of information, or abuse of position.
Fraud Act 2006 provides 3 main offences of fraud:

1. Fraud by false representation (Section 2)
2. Fraud by failing to disclose (Section 3)
3. Fraud by abuse of position (Section 4)

Corruption

Dishonest or improper behaviour in the exercise of power, often involving bribery, personal interest or undue influence.

Bribery

Offering, promising, giving, requesting or accepting an advantage as an inducement for an action which is improper or a breach of trust.

Theft

Dishonest appropriation of property belonging to another with the intention of permanently depriving the other of it.

• Fraud Act 2006 — provides for a general offence of fraud with three ways of committing it, which are by false representation, by not disclosing information and by abuse of position.
• Bribery Act 2010 — sets out the offences of active and passive bribery, bribery of a foreign public official, and the corporate offence of failure to prevent bribery.
  • Seven principles of public life (also known as the Nolan Principles) – The council is committed to the highest standards of ethical behaviour. All councillors, officers, contractors, and individuals acting on behalf of the council are expected to uphold the Nolan Principles (outlined below). These principles form the foundation of integrity, openness, and accountability in public service and are reflected in the Member and Officer Codes of Conduct.
  • Selflessness – Holders of public office should act solely in the public interest and must not seek financial or other personal gain for themselves, their family, or associates.
  • Integrity – They should avoid placing themselves under any obligation that might influence—or appear to influence—their performance of official duties.
  • Objectivity – Public decisions should be made impartially, fairly, and on merit, using evidence and without discrimination or bias.
  • Accountability – Holders of public office are accountable to the public for their decisions and actions and must submit themselves to proper scrutiny.
  • Openness – They should act and take decisions in an open and transparent manner. Information should only be withheld when there is a clear and lawful justification for doing so.
  • Honesty – They must be truthful and declare any private interests that may conflict with their public duties.
  • Leadership – Holders of public office should demonstrate these principles in their own behaviour and actively promote and support them in others.
• Delivering Good Governance in Local Government (CIPFA/SOLACE) — provides the principles for the Local Code of Corporate Governance and annual assurance.
• Global Internal Audit Standards (GIAS) — the practice of internal audit is guided by the GIAS.
• Data Protection Act 2018 and UK GDPR — ensure lawful, fair and transparent processing of personal data, including in data‑matching and analytics.
• National Fraud Initiative (NFI) — statutory data matching to prevent and detect fraud and error.
• Fighting Fraud and Corruption Locally (FFCL) — national local‑government counter‑fraud strategy providing the 5‑pillar model (as outlined in Section X).
• Economic Crime and Corporate Transparency Act 2023 — introduced a corporate offence of failing to‑prevent fraud offence for qualifying organisations.
• Annual Governance Statement (AGS) and Local Code of Corporate Governance (LCCG)
• Council Constitution 
• The Council’s Values
• The Wealden District Council Strategy – mid-term update 
• Council’s Risk Management and Policy framework

The Audit & Governance Committee provides independent oversight of risk, internal control, audit and anti‑fraud arrangements, including approval and monitoring of internal audit strategy and performance.

The Annual Governance Statement provides an overview of the council’s governance framework. It looks to provide assurance on the effectiveness of these arrangements and identifies areas for future improvement. This statement is formally approved by the council’s

Audit and Governance Committee on an annual basis and signed by the leader and chief executive. It should be read in conjunction with the council’s Local Code of Corporate Governance.

The Corporate Management Team (CMT) sets the ethical tone, ensures resources and champions a fraud‑aware culture across the council and its services.
CMT consists of the statutory officers whose roles and duties are summarised below:

• Chief Executive: It is the role of the chief executive, also known as the Head of Paid Service, to ensure that all the authority’s functions are properly co-ordinated as well as organising staff and appointing appropriate management.
• Section 151 Officer: Section 151 of the Local Government Act 1972 requires local authorities to make arrangements for the proper administration of the Council’s financial affairs and appoint a S151 Officer, also known as a Chief Financial Officer (CFO), to have responsibility for those arrangements.
• The Monitoring Officer has responsibilities to report on matters they believe to be illegal or amount to maladministration, to be responsible for matters relating to the conduct of councillors and officers and, to be responsible for the operation of the council’s constitution.

The council’s Investigations Team deliver professional counter‑fraud services, including proactive prevention, training, investigations, analysis and recovery of losses.

Council and committees

• Set policy, provide oversight, and ensure resources are in place to manage fraud risks and deliver effective assurance.

Managers

• Identify and assess fraud risks, design proportionate controls, ensure staff awareness, and support investigations and recovery.

Employees and councillors

• Act with integrity, follow Codes of Conduct, declare interests, gifts and hospitality, and report concerns promptly.

Internal audit

• Provide independent assurance on the adequacy and effectiveness of governance, risk management and control, and recommend improvements.

Investigations team

• Undertake proactive and reactive investigations, apply sanctions and recovery, share intelligence and strengthen controls. Working with partners, stakeholders, and colleagues, internally, locally and nationally.

Contractors and suppliers

• Meet the council’s standards, make fraud and corruption declarations during procurement and accept contractual remedies for non‑compliance.

Partners and stakeholders

• Co‑operate with investigations, information sharing and joint working to prevent and pursue fraud.

The key principles are laid out in the pillars and themes:

1. Having robust arrangements and executive support to ensure antifraud, bribery and corruption measures are embedded throughout the organisation.
2. Accessing and understanding fraud risks. Committing the right support and tackling fraud and corruption. Demonstrating that it has a robust anti-fraud response. Communicating the risks to those charged with Governance
3. Making the best use of information and technology. Enhancing fraud controls and processes. Developing a more effective anti-fraud culture. Communicating its’ activity and successes.
4. Prioritise fraud recovery and use of civil sanctions. Developing capability and capacity to punish offenders. Collaborating across geographical and sectoral boundaries. Learning lessons and closing the gaps.
5. Protecting itself and its Residents. Recognising the harm that fraud can cause in the community. Protecting itself and its’ residents from fraud.

7.1 Govern

• Embed strong governance, leadership and accountability for counter‑fraud across the organisation, meeting CIPFA/SOLACE principles and integrating fraud risk within corporate risk management and assurance.

7.2 Acknowledge

• Recognise the threat and keep an up‑to‑date fraud risk assessment; promote awareness and reporting; allocate trained resources to address priority risks.

7.3 Prevent

• Maintain proportionate internal controls, segregation of duties and management checks.
• Use data analytics and targeted data matching to identify vulnerabilities and strengthen controls.
• Provide regular fraud awareness and targeted training for high‑risk roles.
  • Build fraud prevention into policies, system design and change programmes.
• Using the fraud triangle to assess circumstances to prevent potential issues arising (See Appendix 1 below).

7.4 Pursue

• Encourage and enable confidential reporting by staff, councillors, contractors and the public.
• Investigate all credible allegations proportionately and impartially, using trained investigators.
• Apply the full range of disciplinary, civil, contractual and criminal sanctions, and publicise outcomes where lawful as a deterrent.
• Recover losses using all available legal powers, including Proceeds of Crime Act remedies where applicable.

7.5 Protect

• Safeguard residents, services, assets and the public purse against harm from fraud, cyber‑enabled crime and organised criminality.
• Participate in secure intelligence‑sharing networks and national initiatives (e.g., NFI) to detect, prevent and deter fraud.
• Invest in technology, analytics and data integration to identify emerging risks and enable early intervention.

The council has established a dedicated phone number and an email facility to enable the confidential reporting of suspected fraud, corruption or malpractice (excluding Reporting Benefit Fraud). The contact phone number is 01323 443350 and the email address is investigations@wealden.gov.uk

Our counter fraud webpage provides an explanation of the work that is covered by the team and the ways on how to report a fraud. 

The investigations team also accepts referrals from the revenues and benefits team and the DWP, these come directly to the Investigations emails address.

All reports will be treated seriously and, where appropriate, investigated by the investigations team.

The council has a Whistleblowing and Speaking Up Policy and Toolkit which supports individuals to raise genuine concerns about wrongdoing, malpractice or unlawful conduct without fear of repercussions.

The council collaborates with a wide range of stakeholders, including:

• Local and national law enforcement – e.g. Sussex Police, National Crime Agency, Government Counter Fraud Authority.
• Government departments – e.g. Department for Work and Pensions (DWP), HM Revenue & Customs, Boarder Force.
• Oversight and regulatory bodies – e.g. External Auditors, Local Government Ombudsman, Parliamentary Committees, Information and surveillance commissioners.
• Sector networks – e.g. National Anti-Fraud Network, CIPFA Counter Fraud Centre, Southeast Investigation Officers Group, National Investigations Officers Group.
• Local forums – e.g. Sussex and South East Tenancy Fraud Forums, East Sussex Counter Fraud Hub.
• Other councils and registered social landlords – for joint investigations and intelligence sharing.

The council has a dedicated investigations team that plays a vital role in detecting, investigating, and addressing fraudulent activity. Investigations will be conducted following legal and regulatory requirements and council policies. Internal disciplinary processes may go ahead independently of criminal investigations. Sanctions may include disciplinary action, civil recovery, contractual remedies and referral to law enforcement. The council will pursue the recovery of all identifiable losses and, where appropriate, the confiscation of criminal assets.

• Use advanced analytics and data warehousing tools (e.g., IDEA) to identify anomalies, patterns and potential fraud.
• Undertake local data matching and take part in national data matching through the NFI.
• Share intelligence securely with partners and sector networks following information governance requirements.
• Process personal data lawfully, fairly and transparently, with proper safeguards in place.

Effective risk management is an integral part of the council’s control environment and demonstrates effective use of resources and sound governance. The council maintains a Risk Management Policy and Framework. This is overseen by the Audit and Governance Committee and requires councillors to review the Corporate Risk Register and operation of the Risk Management Framework on a six-monthly basis.

All service areas within the council maintain a risk register with a cyclical review of risk registers is in operation.

Managers should incorporate fraud risk within service, project and programme risk assessments and review risks where operations or the external environment change. The council monitors known high‑risk areas such as tenancy, right to buy, procurement, council tax, business rates, grants, payroll, direct payments, money laundering, insurance and cyber‑enabled fraud, and will target preventative and detective activity accordingly.

• Internal audit provides independent assurance on the effectiveness of governance, risk management and control and reports to the Audit and Governance Committee.
• An annual counter fraud report assesses performance against the FFCL framework across Culture, Capability, Capacity, Competence, Communication and Collaboration.
• The AGS summarises key assurances and governance issues and is approved by Members.
• This policy, the AGS and LCCG will be reviewed annually and updated as required.

• Zero tolerance for offering, requesting, giving or receiving bribes or improper inducements.
• No gifts or hospitality intended to influence a decision or secure an unfair advantage.
• No political or charitable contributions made with the intention of securing operational or commercial benefit.
• Maintain accurate and transparent records of financial transactions and third‑party payments.
• Encourage reporting and protect whistleblowers from retaliation.

• Wealden Constitution including Procurement and Contracting Procedure and Financial Procedure Rules
• Annual Governance Statement
• Local Code of Corporate Governance
• Members’ and Employees’ Codes of Conduct
• Whistleblowing and Speaking Up Policy
• Anti‑Money Laundering Policy
• Disciplinary Policy

The fraud triangle is a framework used to understand the factors that lead to fraudulent behaviour. It consists of three key components:

• Opportunity: The ability to commit fraud, often due to weak internal controls.
• Incentive/Pressure: The motivation behind committing fraud, which can stem from financial difficulties or personal gain.
• Rationalization: The mindset that allows individuals to justify their fraudulent action as acceptable

The fraud triangle is an important part of the fraud awareness process for staff. Highlighting characteristics and further linking them to actions that may in turn be a cause for concern.