The Anti-Fraud and Corruption Framework

10. This framework is not just about controls and procedures. Whilst these are important in ensuring that the mechanisms are in place to prevent, detect, investigate and deter fraud and corruption, the underlying culture of the organisation sets the tone for the behaviour of all those associated with it. As important, is that the Authority demonstrates its approach to fraud by its deeds as well as by its words. The framework therefore encompasses the following aspects.

11. The Anti-Fraud and Corruption Policy: This high-level document sets out the Authority’s overall approach to the prevention of Fraud and the response to incidents where fraud is suspected or detected. This document has the status of a policy applicable to both Members and employees. The current policy is available here. (insert link to latest policy on publication)

12. The Anti-fraud and Corruption Plan: This document sets out the key objectives for the Authority in developing and improving the anti-fraud and corruption framework and the main activities planned to prevent, detect, investigate and address the key fraud risk issues. It includes an action plan to implement any improvements to the processes and procedure in place to address any risks identified through the fraud risk assessment. Link to the Anti-Fraud and Corruption Plan for 2025-27 (insert link to latest policy on publication)

13. Key Procedures, Processes and Financial Regulations: Whilst all activities involving financial or other assets, information management or personnel related activities, there is a need to be mindful of the potential for bribery fraud and corruption and as such, make appropriate arrangements to minimise the risks associated with these activities. There are a number of key processes which are essential to ensure an effective and cohesive response to these threats. These processes, which need to specifically address the issue of Bribery, form an integral part of this framework, they are: -

Anti-Money Laundering Policy & Procedures.
Anti-Bribery Policy.
Code of Ethical Conduct (employees).
Code of Conduct for Members of the Fire Authority.
The Speak Up Policy.
The Gifts and Hospitality Policy.
Declaration of Interests and Related Party Transactions Procedures.
Disposals Policy.

14. The National Fraud Initiative: This is a biennial government initiative coordinated by the Cabinet Office involving the downloading of data from payroll, pension and creditor databases and cross matching with similar data from other government and public sector bodies. The intention is to identify data matches which could potentially indicate fraud or financial loss. The Authority is required to participate in the exercise and to investigate any matches that arise from the process. The output from the data matching exercise also forms an important part of the risk assessment process by identifying those areas subject to the highest risk of problems and is a useful barometer of the likelihood of fraud being perpetrated against the Authority.

15. The Fraud Response Plan: The fraud response plan sets how the Authority would respond to suspected or apparent irregularities, fraud or corruption perpetrated against it. It is important that employees in general and managers in particular are clear about what to do if they suspect a fraud or other irregularity has been perpetrated. The fraud response plan provides guidance and contact information to enable such incidents to be promptly reported investigated and resolved to mitigate further losses, initiate recovery where possible, instigate additional preventative measures and identify the perpetrator as quickly as possible. The Fraud Response Plan is available here. (insert link to latest policy on publication)

There are a number of other internal control procedures which also contribute to the anti-fraud framework. These include the Procurement Regulations, Recruitment and Selection Procedures, Financial Regulations and Information Technology Policy, Artificial Intelligence Policy and the Data Protection Policy. Whilst the key policies and procedures referred to in paragraph 13 detail “what” the Authority will do to combat fraud and corruption, these procedures set out “how” it is done and therefore constitute an important element of the framework as a whole.