A Member commented that he would like to have seen a red line version of the report showing the changes that had been made against the previous policies. The HAA explained that the policies presented were a complete overhaul of the previous versions and there would be too many tracked changes. A discussion took place regarding how policies should be benchmarked. The Head of Audit and Assurance explained that there was no formal benchmarking process but she had looked at other boroughs where protocols were robust before drafting the LBB policies.
A Member asked if all departments had counter fraud and corruption classified as a risk. The answer to this was no. The Head of Audit and Assurance made the point that when drafting the new strategy she wanted to highlight that everybody had a role to play in dealing with fraud and corruption and she wanted to strengthen the role of managers in being accountable for risks in their own departments.
With respect to whistle blowing and raising concerns, a discussion took place as to whether ‘policy’ or ‘procedure’ should come first. It was noted that the Chairman and Vice Chairman could be emailed directly, but the Chairman pointed out that he believed that officers including the Chief Executive should be contacted first in most cases.
A Member asked if there was a record of how many whistle blowing allegations were made. The Head of Audit and Assurance said that only two were recorded in the last year. It was not clear if there were no concerns to raise or whether it was simply the fact that people were not raising concerns. She felt that the issue of raising concerns and whistle blowing should be publicised much better and should be part of the induction process. A Member expressed concern that having elected officials as part of the whistle blowing process could possibly hold people back from raising concerns.
It was suggested that stronger and clear language should be used in the policy so that it was clear that whistle-blowers would be protected and would be free from any sort of reprisal. Reference was made to section 1.4 of the whistle blowing policy where it had been written that employees should feel confident in raising ‘genuine’ concerns. It was agreed that on the next review the term ‘genuine’ concerns should be modified so that it would refer to concerns raised in ‘good faith’. It was also agreed that a section should be added to the policy making it clear that whistle-blowers would be free from reprisals.
Members noted the Anti-Bribery Policy and there was a discussion regarding how these matters should be reported.
Members noted the anti-money laundering policy and procedure. It was commented that 8% of the money in general circulation was believed to be laundered.
1) The policies be noted and agreed with an amendment as outlined below.
2) That the term ‘genuine’ concerns should be modified so that it would refer to concerns raised in ‘good faith’. It was also agreed that on the next review, a section should be added to the policy making it clear that whistle-blowers would be free from reprisals.
3) The proposals for International Fraud Awareness week be noted.