An annual review of the Council’s:
· Anti-Fraud & Corruption Policy,
· Whistleblowing Policy,
· Declaration of Interests, Gifts & Hospitality Policy (for Officers)
· Regulation of Investigatory Powers Act (RIPA) & Investigatory Powers Act (IPA) Policy
has taken place to ensure they are updated in line with best practice and legislation.
Some changes have been made to the Council’s Anti-Fraud & Corruption Policy including adding links to ‘Other Relevant Legislation’ and adding guidance on examining identity documents. Appendix C of the policy ‘Anti-Money Laundering Requirements’ has been updated with a statement that the Council will cooperate fully with law enforcement authorities, regulatory bodies, and other relevant agencies in combating money laundering and terrorist financing.
The Whistleblowing Policy has been updated with some changes including adding the seriousness/impact of a person knowingly making a false accusation and adding a note to explain that a whistleblowing referral will not affect, stop or delay any investigation into a theft/fraud/disciplinary/employment dispute involving the whistleblower. Other changes include adding a ‘Protect’ reference and website link (was previously Public Concern at Work) and allocating a unique reference number for each referral. The ‘Preliminary Enquires’ process in the Whistleblowing Procedure has been expanded to include additional potential outcomes and the introduction of a formal decision record.
Some minor changes have been made to the Council’s Declaration of Interests, Gifts & Hospitality Policy (for Officers) including the addition of a ‘In Year Amendments and Editing Log’, and also the need to keep declarations confidential clarified under Service Director and Monitoring Officer responsibilities.
The Regulation of Investigatory Powers Act (RIPA) and Investigatory Powers Act (IPA) Policy has been updated with some minor changes including the addition of a Contents front page and ‘In Year Amendments and Editing Log’, the update of Authorising Officer job titles, and inclusion of the consequence that subjects of surveillance may bring their own proceedings on Human Rights grounds if correct procedures are not followed.
Additional documents:
Minutes:
The Head of Audit and Management Assurance presented a report, a copy of which had been circulated to each Member and a copy of which appears as Appendix 'B' to these Minutes in the Minute Book.
The Committee was advised that an annual review of these four policies had taken place to ensure they were updated in line with best practice and legislation. The Head of Audit and Management Assurance outlined how the reviews had been undertaken, including the use for the first time of Artificial Intelligence (AI). Changes made to the policies as part of the annual evolution process were summarised in paragraphs 5 to 12 of the report. The changes were set out in full in red text in each policy document, attached as appendices to the report. It was noted that the red text remained in the live document. The policies would be republished and further staff training and awareness would be carried out. The Committee was due to receive a report on the effectiveness of the policies later in the year.
The Head of Audit and Management Assurance highlighted additions to the Whistleblowing Policy including a note in paragraph 4.3 to explain that a whistleblowing referral will not impact any investigation into a theft / fraud / disciplinary / employment dispute involving the whistleblower. This had always been the case in practice but had not been explicitly specified in the policy.
The Head of Audit and Management Assurance responded to questions and comments on the report. He explained that there was a general growth in the use of AI and an increasing awareness of the benefits, including the speed at which AI could undertake what would otherwise be a time-consuming task. He explained the methods used to train staff in fraud awareness, including mandatory training using the E learning portal, additional specialist/face to face training as required and regular internal communications to all staff. Information on training was included in the annual report on the effectiveness of the policy.
Members were advised that the Committee received an annual report on whistleblowing incidents. It was noted that the policy included a procedure for a whistleblower to escalate their concerns by contacting either the Head of Audit and Management Assurance, the Monitoring Officer or the Head of Paid Service. Members were advised that if the concerns related to one or more of these officers, the disclosure could be made to the Council’s External Auditors or any another relevant ‘prescribed’ person or body. This was also specified in the procedure and could be explained further in training.
RESOLVED that the Council’s Anti-Fraud & Corruption Policy, Whistleblowing Policy, Declaration of Interests, Gifts & Hospitality Policy (for Officers) and the Regulation of Investigatory Powers Act (RIPA) & Investigatory Powers Act (IPA) Policy for the 2024/25 financial year, be approved.
Voting: Unanimous