Issue - meetings

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 an updated Chief Executive statement and added link to the Schools Financial Value Standards.

The Whistleblowing Policy has been updated with the inclusion of a formal officer decision record template to cover the course of action to be followed in accordance with Stage 3 (Initial response for a Formal Resolution). The link and summary guidance contained in the Academy Trust Handbook, in respect of required whistleblowing arrangements, has been updated.

Some changes have been made to the Council’s Declaration of Interests, Gifts & Hospitality Policy (for Officers) which include additional guidance on declaring ‘other employment’ and defining responsibilities of line managers in assessing declarations made by employees. A requirement for line managers to pass completed Form 1’s to the Service Director for their consideration has been added alongside the Service Director’s responsibility to determine if decisions made by line managers are appropriate. Some further general guidance on the declaration form completion process has also been added.

The Regulation of Investigatory Powers Act (RIPA) and Investigatory Powers Act (IPA) Policy has been updated to include links to associated BCP Council strategies and policies.

The Head of Audit and Management Assurance (HAMA) presented a report, a copy of which had been circulated to each Member and a copy of which appears as Appendix 'F' to these Minutes in the Minute Book.

Members were referred to the second paragraph in the minute on the Financial Regulations report for an explanation of the annual evolutionary approach for keeping policies within its remit up to date. An annual review of the following Council policies had taken place to ensure they were updated in line with best practice and legislation. The main changes were set out in the report. The HAMA highlighted a number of specific points as follows:

·       Anti-Fraud & Corruption Policy: this now included an updated Chief Executive statement, demonstrating commitment at the highest level.

·       Whistleblowing Policy: this now included a Stage 3 decision record template which reflected good practice and was useful for tribunals. From 6 April 2026, legislative changes required the inclusion of sexual harassment under certain circumstances as a qualifying disclosure.

·       Declaration of Interests, Gifts & Hospitality Policy (for Officers): of the policies reviewed, this policy had been strengthened the most. It included additional guidance on declaring ‘other employment’ in response to the growing national fraud threat of ‘polygamist’ working

·       Regulation of Investigatory Powers Act (RIPA) & Investigatory Powers Act (IPA) Policy: this had been updated to include links to associated BCP Council strategies and policies.

The HAMA responded to a question about the definition of a polygamous worker and what was/wasn’t permitted. Additional guidance in the policy stipulated that employees were required to declare details of other employment, full or part time, and should not work for anyone else without prior approval. The aim being that employees were not working excessive hours to the detriment of the Council.

RESOLVED that the Committee approves 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 2026/27 financial year.

Voting: Unanimous