Agenda item

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 link to the new e-learning system, adding references to The Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) Regulations 2024 and the need for enhanced due diligence checks for high-risk customers, and the removal of the reference and link to the CIPFA School Fraud Risk Assessment tool.

The Whistleblowing Policy has been reviewed and no changes are proposed to the policy as part of the annual evolution other than the version update for 2025/26.

Some minor changes have been made to the Council’s Declaration of Interests, Gifts & Hospitality Policy (for Officers) including adding directorship as a business role example that requires declaring if there is a business relationship with the Council, clarifying that employees should not accept gifts from organisations the Council is receiving services from, providing reordered guidance on accepting incidental promotional items valued at less than £25, stating the definition of hospitality for this policy, adding guidance on the Council receiving and giving prizes, and also including a link on how to edit PDFs in MS Word on Forms 1 and 2.

The Regulation of Investigatory Powers Act (RIPA) and Investigatory Powers Act (IPA) Policy has been updated with some minor changes including adding reference and a link to Investigatory Powers (Amendment) Act 2024, and also including  brief guidance on use of technology (including artificial intelligence) with regard to surveillance.

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 'D' to these Minutes in the Minute Book.

Members were reminded of Committee’s agreed approach to keeping certain policies up to date by way of a ‘business as usual’ annual evolution. The evolutionary changes shown in red text were retained in the live document for clarity. Staff were made aware of changes and copies were updated on the internet/intranet. The Committee received annual reports on the implementation of these policies.

The report provided a summary of changes made to the following policies to ensure they were updated in line with best practice and legislation: Anti-Fraud & Corruption Policy, Whistleblowing Policy, Declaration of Interests, Gifts & Hospitality Policy (for Officers) and  Regulation of Investigatory Powers Act (RIPA) & Investigatory Powers Act (IPA) Policy. It was noted that the majority of changes were minor in nature. The Head of Audit and Management Assurance drew attention to the proposed delegations in recommendations ii and iii, to enable further amendments to be made during the year should legislation and internal review procedures require.

A Member asked if there were any changes to the Anti-Fraud and Corruption Policy, with reference to a matter previously raised in respect of a Business Bounce Back grant. Members were reminded that the committee had looked at this particular issue several times now, with the reports finding that correct governance procedures were followed and correct information provided to verify the spending. The matter had been scrutinised as far as it was possible to do so. It was noted that the Covid inquiry was looking into the grants systems to see what had gone well and what hadn’t. The Committee was assured that robust processes were in place for the allocation of BCP Council led grants. A Member commented on the role of councillors in ensuring a zero-tolerance culture towards fraud and corruption. It was noted that the voluntary sector was subject to numerous checks and due diligence procedures for relatively small amounts of grant.

RESOLVED that

1. 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 2025/26 financial year, be approved

2. Delegation be approved to the Head of Audit & Management Assurance to amend the Anti-Fraud & Corruption Policy during the year via the addition of an appendix to cover new legislation coming into force on 1 September 2025 regarding the Economic Crime and Corporate Transparency Act 2023 creation of a new corporate criminal offence of ‘failure to prevent fraud’. The Head of Audit & Management Assurance will include the updated policy in the annual report to the Audit & Governance Committee of counter fraud activity in October 2025

3. Delegation be approved to the Head of Audit & Management Assurance for any changes required as part of the review of the Anti-Fraud & Corruption Policy and Whistleblowing Policy by the Equalities Impact Assessment Panel on 12th March 2025.

Voting: Unanimous