Anti-Fraud and Corruption Strategy, Policy and Response Plan RTFDocument Transcript
GLA Anti-Fraud and Corruption
Strategy , Policy and Response Plan
Anti-Fraud and Corruption Strategy
1.1 The Greater London Authority (GLA) is committed to protecting the public
funds that it administers. The GLA is therefore determined to prevent,
deter and detect all forms of fraud and corruption committed against it
both internally and externally. In pursuing this aim the GLA will seek to
adopt best practice and this Anti Fraud and Corruption Strategy will have
due regard to the implementation of the recommendations made by the
Nolan Committee, the Audit Commission and the Chartered Institute of
Public Finance and Accountancy (CIPFA).
1.2 The objective of this document is to provide an Anti-Fraud and
Corruption Strategy for the GLA. The Strategy is supported by the GLA’s
Anti-Fraud and Corruption Policy and Response Plan. This Strategy is
designed to integrate with the GLA’sorganisational objectives. In order to
deliver the GLA’saims, it is necessary to maximise the available financial
resources. Therefore this Strategy is designed to:
• Reduce losses due to fraud and corruption to an absolute minimum;
• Include all areas of the organisation and external stakeholders in
relation to fraud and corruption;
• Maintain a ‘zero-
tolerance culture to fraud and corruption;
• Maintain a stance of providing a strong deterrent;
• Undertake the detection and investigation of fraud and corruption;
• Encourage sanctions and the implementation of recovery of monies
where fraud is identified; and
• Prevent fraud and corruption by designing and continuing to review
policies and systems.
1.3 As part of its strategic risk management process, the GLA has to ensure
that there is robust framework in place to mitigate the risk of fraud and
corruption. The GLA is committed to an outcomes based strategy; that is,
the achievement of a real reduction of losses, or the risk of losses, to the
2. The GLA’ s approach
2.1 The GLA’sapproach is to develop a corporate anti-fraud and anti-
corruption culture and the prevention of fraud and corruption by
designing, implementing and continuously reviewing policies and
systems. This is further supported by the GLA’swork to detect and
investigate fraud and corruption and seeking to apply sanctions and
2.2 The application of the GLA’sStrategy to counter the risk of fraud and
corruption is based on:
• Awareness and training;
• Prevention, including deterrence and detection;
• Sanction; and
• Recovery of losses.
3. Awarenes s and Training
3.1 The GLA is committed to ensuring staff and management are aware of
their responsibilities with regard to preventing fraud and corruption. To
this end, the GLA will ensure that there is an on-going training
programme for staff regarding measures to minimise the risk of fraud and
corruption. The GLA also recognise that the organisation is exposed to
risk from external partners and suppliers. To this end, the GLA will
ensure there is an on-going programme of awareness to ensure external
partners and suppliers are aware of the GLA’scommitment to protect its
funds against fraud and corruption.
4. Prevention, including Deterrence and Detection
4.1 The GLA recognises that the most efficient way to protect its assets is to
undertake a scheduled plan of prevention work. This plan will include a
programme of work directed at deterring fraud. It will also include fraud
risk assessment work which will form part of the GLA’sstrategic risk
management process. The Fraud Prevention Plan will be developed on
an annual basis and include targeted prevention, deterrence, detection
and fraud risk assessment actions. The Fraud Prevention Plan will be the
responsibility of Internal Audit and will form part of the GLA’sInternal
5.1 The GLA is committed to investigating all suspected occurrences of fraud
and/or corruption. The GLA will undertake all investigations pursuant to
the Anti-Fraud and Corruption Policy and Response Plan.
6.1 The GLA is committed to pursuing all possible sanctions for proven
cases of fraud and/or corruption. The GLA’sAnti Fraud and Corruption
Policy and Response Plan will be adhered to regarding the appropriate
level of investigation of suspected cases. The GLA is committed to
pursuing internal disciplinary, criminal and civil sanctions where there is
evidence to support the occurrence of fraud and/or corruption. These
sanctions will be sought pursuant to the GLA’sAnti Fraud and Corruption
Policy and Response Plan.
7. Recovery of loss e s
7.1 The GLA is committed to seeking to minimise any potential loss due to
fraud and/or corruption. In all cases of suspected fraud the GLA will take
action to minimise the risk of further loss. In all cases of proven fraud
and/or corruption the GLA will take action where it is available to seek to
recover any funds lost due to fraud. The provisions of the GLA’sAnti-
Fraud and Corruption Policy and Response Plan will be adhered to in all
8.1 The GLA's expectation on propriety and accountability is that the Mayor,
Assembly Members, management and staff at all levels will lead by
example in ensuring adherence to legal requirements, rules, policy and
practices. The GLA also expects that individuals and organisations, e.g.
suppliers, contractors and service providers with whom it deals, will act
towards the GLA with integrity and without thought or actions involving
fraud and corruption.
8.2 The GLA has in place a structure of systems and procedures to assist in
the fight against fraud and corruption. These arrangements will be kept
under review to ensure that all opportunities to take advantage of
developments in techniques for preventing and detecting fraudulent or
corrupt activity are maximised. This Strategy fully supports the GLA's
desire to maintain a culture of openness, fairness, trust and dignity; free
from fraud and corruption.
8.3 This Strategy will be subject to regular review as necessary.
Anti-Fraud and Corruption Policy
1.1 Fraud is estimated to cost the public sector billions of pounds every year
and diverts resources from those who need them. Fraud also
undermines public and political confidence in public services and can
impact negatively upon staff morale across an organisation. The Greater
London Authority (GLA) is committed to the values of probity and
accountability that lead to a positive organisational culture. In developing
such a culture the GLA will seek to prevent, detect, investigate and deter
all forms of fraud and corruption.
1.2 The Mayor, Assembly Members and staff are expected to uphold the
highest standards of conduct in public life. The Mayor and Assembly
Members must ensure proper financial practice and adherence to all
codes of ethics and standards, Financial Regulations and Standing
Orders. The GLA expects that all individuals and organisations
associated with the Authority will act with integrity and without intent to
commit fraud or corruption.
1.3 The GLA requires staff and partners at all times to act honestly and with
integrity in order to safeguard the public resources for which they are
responsible. The GLA takes the risk of fraud and corruption extremely
seriously and does not tolerate any level of fraudulent activity. The threat
of fraudulent activity and impact on programme delivery is managed at
the highest level within the Authority, with overall responsibility resting
with the Chief Executive. The GLA subscribes to the seven principles of
public life set out in the Nolan Committee first report, Standards in
Public Life, which appear at Appendix 1.
1.4 The first line of defence for an organisation against becoming the victim
of fraud is professional staff, supported by the establishment and
maintenance of carefully designed and consistently operated procedures.
Managers have the prime responsibility for establishing internal control
arrangements to minimise the risk of fraud or corruption and other
irregularity within their areas of responsibility.
1.6 The GLA is committed to ensuring that opportunities for fraud or
corruption are prevented and that all cases of internal and external fraud
are investigated and reported in accordance with the Anti Fraud and
Corruption Response Plan. This policy statement, along with the
Response Plan, prescribes what the Mayor, Assembly Members and
staff should do if they suspect fraud or any wrongdoing in any business
associated with the GLA. By staff, this means all staff, whether they are
full-time, part-time, agency staff or staff employed by any of the GLA’s
1.7 The principles outlined in this document support the overall framework of
guidance for the Mayor and Assembly Members contained within their
Code of Conduct.
2 Purpose of the Policy
2.1 The purpose of the Policy is to outline how the GLA will manage the risk
of fraud and corruption. The Anti-Fraud and Corruption Response Plan
that complements this Policy details how the GLA will respond to
allegations of fraud, including who should be involved:
• If an allegation is made;
• During the investigation; and
• In post investigation reporting.
3 Scope of this Policy
3.1 This policy is applicable to the Mayor, Assembly Members, employees of
the GLA, temporary staff, secondees, contractors working within the
GLA, and other relevant external stakeholders.
3.2 This Policy forms part of the GLA’sAnti-Fraud and Corruption Strategy.
As part of that Strategy the GLA is committed to the prevention of the risk
of fraud and corruption and as such will have an annual pro-active Fraud
Prevention Plan. The Fraud Prevention Plan will follow the principles of
4 Definitions of Fraud and Corruption
4.1 For the purposes of this Policy, the definition of “fraud” as covered in
the Fraud Act 2006 (see paragraph 4.2 below) and is characterised by
dishonest acts, whereby the individual knowingly makes a false
representation, (including by omission), with the intention of acquiring a
gain for themselves and/ or others, or places the GLA at risk of a loss. It
is important to note that the Fraud Act 2006 focuses on the ‘intention of’
the act, so whether there has been an actual gain or loss is immaterial to
whether a fraud has been committed. Additionally, for the purposes of
this Policy, fraud includes acts such as forgery, theft, extortion, bribery,
embezzlement, misappropriation, false representation, concealment of
material facts and collusion. Fraud can be perpetrated by persons
outside as well as inside an organisation.
4.2 Many of the offences referred to as fraud were covered by the Theft Acts
of 1968 and 1978 with fraud for practical purposes defined as the use of
deception with the intent ion to obtain an advantage, avoid an obligation,
or cause loss to another party. This definition implied deliberate intent
and thus could exclude negligence. The Fraud Act 2006 makes it no
longer necessary to prove a person has been deceived. The focus is now
on the dishonest behaviour of the subject and their intent to make a gain
or loss. Many cases are still likely to be prosecuted under the Theft Acts
with the Fraud Act being used for matters after 15th January 2007.
4.3 For the purposes of this Policy, “corruption”is defined as the “offering,
giving, soliciting or acceptance of an inducement or reward, which may
influence a person to act against the interest of the organisation”.
Corruption relates to rewards or inducements, such as bribes. Under the
Prevention of Corruption Act 1916 any money, gift or consideration
received by an employee in public service from a person or organisation
holding or seeking to obtain a contract will be deemed by the Courts to
have been received corruptly unless the employee proves the contrary.
The criminal acts of corruption are covered in the Prevention of
Corruption Acts 1906 and 1916.
4.4 The impact of fraud and/or corruption on the GLA could include the
• Loss of resources (financial, staffing and other assets);
• Reputation and brand damage;
• Reputational impact on the GLA and/or the Mayor;
• Negative cultural impact;
• Outputs not delivered;
• Damage to the GLA’srelationship with partners and stakeholders;
• Disruption to service delivery;
• Damage to the working relationships between the GLA’sstaff;
• Investigation costs; and
• Recruitment, retention and morale issues.
4.5 The impact on a staff member who has perpetrated a fraud could
• Dismissal for gross misconduct;
• Criminal proceedings potentially leading to a criminal record, fines
• Professional disbarring;
• Serious damage to future employment prospects; and
• Civil recovery of the value of resources lost as a result of the fraud.
5.1 The Mayor and Assembly Members – The Mayor and Assembly
Members have a duty to protect the assets of the Authority and avoid any
suspicion of impropriety. The Mayor and the Assembly must ensure
proper financial practice and adherence to all codes of ethics and
standards, Financial Regulations and Standing Orders. The Mayor and
Assembly Members are expected to conduct themselves in line with the
regulations laid out in the Code of Conduct, and the seven Nolan
principles for public life. These principles have been included at
Appendix 1 to this document and are in summary: selflessness, integrity,
objectivity, accountability, openness, honesty and leadership.
5.2 The Audit Panel – The Audit Panel is the Assembly Committee with the
responsibility for scrutiny oversight of the GLA’sAudit function. A specific
responsibility of the Audit Panel is to ensure that there is an anti-fraud
culture, and promote probity and good practice within the GLA. The Audit
Panel reviews the Authority’sAnti-Fraud Policy and receives the reports
of Internal Audit, External Audit and any other Investigating Officers
where suspected fraud has been investigated.
5.3 The Standards Committee – The Standards Committee will advise
Members on ethical codes of conduct and monitor compliance with local
and national codes. The Committee will also take appropriate action on
all matters involving the Mayor and Assembly Members where there may
have been an alleged breach of the GLA’sCode of Conduct. In addition
the Committee retains an oversight of policies relating to GLA officers
and, along with the Assembly’sAudit Panel, receives and comments on
the Authority’sAnnual Governance Statement.
5.4 GLA Directors – It is the responsibility of the directors to take steps as
are reasonably open to them to prevent and detect fraud. This includes:
• Taking steps to provide reasonable assurance that activities of the
GLA are conducted honestly and that its assets are safeguarded
including assessing the fraud risk involved in the operations for which
they are responsible;
• Ensuring, that to the best of their knowledge and belief, financial
information, whether used in the GLA operations or for financial
reporting, is reliable;
• Establishing arrangements designed to deter fraudulent or other
dishonest conduct and ensuring that these arrangements are
complied with; and
• Implementing new controls to reduce the risk of similar fraud where
frauds have taken place.
5.5 GLA Managers – All staff in management positions are responsible for
ensuring there are procedures and systems of internal control in place to
safeguard the resources for which they are accountable. Management
has a responsibility to ensure their staff are aware and comply with
requirements of the GLA’sCodes of Ethics, Financial Regulations, and
other GLA policies and regulations. Managers should identify all areas
within their service that could be subject to fraud and corruption.
Managers must satisfy themselves that adequate controls are in place to
detect irregularities at the earliest opportunity. Internal Audit is there to
support all managers in this role and they should be contacted if any
manager requires advice or guidance.
5.6 GLA Staff – All staff are responsible for ensuring that their conduct
complies with the Rules for Staff Conduct laid out by the GLA, and the
seven principles of public life selflessness, integrity, objectivity,
accountability, openness, honesty and leadership (see Appendix 1).
Employees have a responsibility to carry out their duties carefully and
honestly and to follow the GLA’sprocedures and guidance from
managers. Such diligence will ensure that the GLA operates with integrity
and in the best interests of the people of London. The GLA expects its
Members and employees to lead by example in ensuring opposition to
fraud and corruption. These responsibilities will be enacted in the
• Complying with the law, the GLA’sFinancial Regulations and other
• Acting with propriety in the handling and use of official resources and
public funds including via cash and payments systems, receipts,
contracting and grant claims;
• Conducting themselves in accordance with the seven principles of
• Being alert to the possibility that unusual events or transactions could
be indicators of fraud;
• Reporting details immediately through the appropriate channel if they
suspect that a fraud has been committed or attempted or see any
suspicious acts or events; and
• Co-operating fully with whoever is conducting internal checks or
reviews or fraud investigations.
5.7 Employees should always be aware of the possibility that fraud and
corruption, including other offences such as theft and bribery, may occur
in the workplace. All employees are encouraged to take a positive role in
identifying all such irregularities. Employees should ensure that if they
have any suspicions of such irregularities, they follow the clearly laid
down procedures within the Anti-Fraud and Corruption Response Plan
5.8 GLA Auditors – It is not the Internal and External Auditors’responsibility
to prevent fraud and error. The fact that an audit is carried out may,
however, act as a deterrent. The primary role of Internal Audit is to
provide an independent appraisal of internal controls within the GLA’s
financial and management systems. In conducting this role, internal audit
may identify financial irregularity. Internal Audit should consider the risks
of fraud and corruption in the course of its assurance activities, and
assist in the deterrence and prevention of fraud by examining and
evaluating the effectiveness of controls. Management should ensure that
the work of Internal Auditors and investigators is complementary. The
role of External Audit is not to detect fraud and corruption. However, it
has a duty to report any potential instances of fraud that it comes across
in the normal course of its work. Other responsibilities of Internal Audit
with regards to the anti-fraud culture of the organisation are listed below:
• Act as an independent section for staff to report suspected frauds;
• Maintain expertise on counter-fraud measures for the Authority;
• Giving independent assurance on the effectiveness of the process put
in place by management to manage the risk of fraud;
• Providing or procuring any specialist knowledge and skills to assist in
fraud investigations, or leading investigations where appropriate and
requested by management;
• Playing a part in responding to staff who use the Whistleblowing
• Considering fraud risk in every internal audit undertaken; and
• Maintaining the Fraud Prevention Plan as a component of the Internal
5.9 Responsibility for corporately managing the risk of fraud is that of the
Executive Director of Resources. His responsibilities in relation to fraud
• Establishing an effective Anti-Fraud and Corruption Policy and
• Designing an effective and proportionate control environment to
prevent fraud; and
• Establishing appropriate mechanisms for:
(i) Reporting fraud risk issues;
(ii) Reporting significant incidents of fraud to the Mayor and
Assembly Members where necessary; and
(iii) Co-ordinating assurances about the effectiveness of the
Anti-Fraud Policy to support the Statement on Internal
5.10 Human Resources – Human Resources is responsible for:
• Providing advice and support to management in implementing
suspensions and any subsequent disciplinary investigation including
advising on the application of the GLA’sDisciplinary Policy;
• Ensuring employment matters are dealt with in a consistent and fair
way regarding any case of suspected fraud; and
• Being an integral part of the Fraud Response Group, where the
suspected fraud involves a member of staff.
5.11 Service Users and Members of the Public – If service users or the public
have any suspicions regarding irregularities within the GLA, including the
Mayor, Assembly Members and staff, they are positively encouraged to
report such concerns directly to the Executive Director of Resources,
Internal Audit or via the GLA’sComplaints Procedure or Fraud Hotline.
5.12 The Role of Contractors, Partners and Other Associated Bodies –
Contractors, partners and other bodies working with the GLA are
expected to conform to the same high standards of conduct and integrity
that the GLA operates to. Such partners:
• Are expected to have adequate internal controls in place to prevent
fraud and corruption that may affect the name of the GLA; and
• Must co-operate with the GLA’santi-fraud activity.
6 Fraud Response Plan
6.1 The GLA’sAnti Fraud and Corruption Response Plan details the GLA’s
procedures for responding to any incidents of suspected fraud. The
Response Plan sets out how suspicions should be raised and how
investigations will be conducted and concluded. The Response Plan
should be read in conjunction with this Anti-Fraud and Corruption Policy.
7 Confidential Reporting
7.1 The GLA has a whistleblowing policy which encourages staff to report
suspected instances of fraud in an open yet confidential manner. This
Policy follows the principles as laid down in the Public Interest Disclosure
Act 1998. Staff are actively encouraged to report genuine suspicions and
are required to co-operate with any Internal Audit activity. Their
anonymity will be respected and they will not be discriminated against for
8.1 Where initial evidence suggests that a criminal offence has been
committed the Executive Director of Resources will be consulted, via the
Fraud Response Group, about a referral to the police. Informal advice
may be sought from the police by the Assistant Director of Finance or the
Finance Manager at an early stage in an investigation as this may affect
the way the investigation is conducted.
8.2 It is the policy of the GLA that where there is prima facie evidence that a
criminal offence has been committed then the case will be referred to the
police for investigation. This does not affect disciplinary action or civil
recovery and those who perpetrate fraud will be liable to these sanctions
as well as possible prosecution. Liaison will take place with the police to
ensure that any other action instigated under the Response Plan does
not prejudice or interfere with criminal proceedings.
8.3 Where there is a requirement for GLA staff to liaise with the police, the
GLA will provide all support and assistance that may be required, or that
any GLA staff member feels that they need in assisting the police. This
support is extended to staff who are potential witnesses in matters
regarding the prosecution of fraud. It does not extend to any employees
or contractors who are subsequently charged by the police with fraud
offences committed against the GLA.
9.1 Staff suspected to be involved in fraudulent activity may be subject to
one or all of the following sanctions:
• Disciplinary with dismissal sought where the offence is considered to
constitute ‘grossmisconduct pursuant to the provisions of the GLA’s
• Criminal where the relevant law enforcement agency considers it to
be in the public interest to pursue a prosecution;
• Civil recovery of monies or assets fraudulently acquired; and
• Profes sional disbarring whereby the GLA will make a referral to the
employee professional regulatory bodies where appropriate.
10 Money Laundering
10.1 Money laundering is a process by which the proceeds of crime are
converted into assets which appear to have a legitimate origin, so that
they can be retained permanently or recycled into further criminal
enterprises. Legislation defines money laundering as ‘concealing,
converting, transferring criminal property or removing it from the UK;
entering into or becoming concerned in an arrangement which you know
or suspect facilitates the acquisition, retention, use or control of criminal
property by or on behalf of another person; and/or acquiring, using or
possessing criminal property.’ The Money Laundering Regulations 2007
apply to cash transactions in excess of €15,000 (approximately £10,000).
However, the Proceeds of Crime Act 2002 applies to all transactions and
can include dealings with agents, third parties, property or equipment,
cheques, cash or bank transfers.
10.2 Offences covered by the Proceeds of Crime Act 2002 and the Money
Laundering Regulations 2007 may be considered and investigated in
accordance with this Policy and the Anti-Fraud and Corruption Response
11.1 The GLA takes fraud and corruption extremely seriously and actively
seeks to prevent any level of fraud. All cases of actual or suspected fraud
or corruption will be vigorously and promptly investigated and appropriate
action will be taken. Staff must report suspected fraud or other
suspicious activity immediately.
Anti-Fraud and Corruption Response Plan
1.1 The purpose of the GLA’sAnti-Fraud and Corruption Response Plan
is to define responsibilities for action and reporting lines in the event
of a suspected fraud, corruption or irregularity. The use of the Plan
should enable the GLA to prevent loss of public money, recover
losses and establish and secure the evidence necessary for any civil,
criminal or disciplinary action.
1.2 The Response Plan should also provide direction to take appropriate
action against those responsible for any fraud or irregularity, deal with
requests for references for employees who have been disciplined
and/ or prosecuted for fraud, review the reasons for the incident, the
measures taken to prevent a recurrence, and any action needed to
strengthen future responses to fraud.
1.3 The Response Plan complements the Anti-Fraud and Corruption
Policy and forms part of the overall Anti-Fraud and Corruption
Strategy of the GLA.
2 Reporting suspected fraud
2.1 Staff must raise any concerns they have on issues of dishonesty,
fraud, corruption, money laundering, and other suspicions of
maladministration associated with the GLA. The GLA’s
Whistleblowing Policy is intended to encourage and enable staff to
raise concerns within the GLA.
2.2 There is a clear link between the Whistleblowing Policy and the Anti-
Fraud and Corruption Response Plan. The anonymity of employees
who make allegations will be protected under the Public Interest
Disclosure Act 1998 and any discrimination against such a person will
be a disciplinary offence. However, it will also be a disciplinary
offence for employees who maliciously or intentionally make false
2.3The first point of contact for staff to raise their concerns is usually
their line manager. However, staff can also report their concerns
direct to Internal Audit or the Executive Director of Resources, in
accordance with the Response Plan. Staff can also utilise the GLA’s
confidential Fraud Reporting Line to raise their concerns. The Fraud
Reporting Line is operated by trained staff who will take the initial
details of the concern and report them through to the Assistant
Director of Finance or the Finance Manager for further consideration.
Staff are encouraged to provide their details when raising a concern,
however calls made to the Fraud Reporting Line may be made
anonymously. All contact details are listed at the end of this
2.4Regardless of the initial reporting contact, all suspicions of fraud
raised are to be reported to the Executive Director of Resources. If a
concern relating to fraud is reported to a line manager, the manager
must report this concern to the Executive Director of Resources
before taking any action.
2.5Wherever possible, staff should retain any evidence and/or make
immediate notes, as this will assist the investigation. As the quality of
evidence is crucial, the more direct and tangible it is, the better the
chance of a successful investigation. Staff should not conduct their
own investigations, seek to gather evidence, or conduct surveillance
activities with regard to any report or suspicion of fraud.
3 Preliminary ‘fact-finding’
3.1 Upon receipt of a referral, the Assistant Director of Finance will
initially review the information to ascertain whether there is cause for
concern. There will be instances, when suspicions are unclear or
there is no substantial evidence, where the Assistant Director of
Finance requests preliminary ‘factfinding’ take place. This fact-
finding work will be led by an appropriately qualified fraud
investigator, nominated by and under the direction of the Assistant
Director of Finance. This would normally be the Finance Manager
leading on anti-fraud measures. Internal Audit will also be responsible
for assisting the Assistant Director of Finance with any fact-finding
3.2 Where preliminary ‘fact- finding’identifies evidence of fraud or
attempted fraud, the case will be referred to the Executive Director of
Resources who will convene the Fraud Response Group. This is to
ensure that any investigation is conducted in a professional manner
with the objective of ensuring that the interests of both the GLA and
the suspected individual(s) are protected.
3.3 Alternatively, where preliminary fact finding enquiries do not identify
evidence of fraud or attempted fraud the following outcomes are
(a) no further investigative work is required although internal controls
may need to be strengthened; and/or
(b) the matter should be dealt with under other GLA policies.
3.4A record will be kept of all referrals received by the Assistant Director
of Finance. This will be reviewed annually by the Executive Director
of Resources and the Audit Panel.
3.5When the Executive Director of Resources is notified of a suspected
fraud, s/he will ensure that an entry is made into the Special
Investigation Register. All entries into the register will be sequentially
numbered so there is a continuous record of all entries. The
Investigations Register will be maintained by the Finance Manager
leading on anti-fraud measures. An example of the Special
Investigation Register is shown at Appendix 2. All notifications of
suspected fraud will be entered, regardless of whether the notification
was made anonymously or not.
4 Fraud Response Group
4.1 Where evidence of a fraud is identified, the Executive Director of
Resources will convene the Fraud Response Group. This will not
prevent or delay immediate referral to the police in appropriate cases
where such action is required. The Group will consist of the following
staff (or individuals nominated by those staff in their absence):
• Executive Director of Resources (Chair);
• Head of Service of the area in which the suspected fraud has
• Assistant Director of Finance;
• The Finance Manager leading on anti-fraud measures;
• Chief Internal Auditor; and
• Head of Human Resources (where the fraud involves a GLA
member of staff).
4.2 The Fraud Response Group will decide whether the situation merits
investigation and will also agree and initiate where necessary other
urgent actions, such as the closing of system weaknesses, stopping
payments, informing insurers, applying for freezing injunctions and
requesting and acting upon advice from the Head of Legal.
4.4 The Fraud Response Group will meet on an on-going basis in relation
to any developments and findings.
4.5 Where for good reason it is not appropriate to involve a member of
the Fraud Response Group, an independent route is available via the
Chief Executive or through the Chair of the Audit Panel, who will in
such cases, carry out duties as per the Response Plan. If the
Executive Director of Resources is suspected of fraud and corruption,
then the suspicion must be reported to the Chief Internal Auditor or
the Chair of the Audit Committee or the Mayor. If police involvement
is necessary, then the Chief Internal Auditor will consult with the
Fraud Response Group prior to the Police being brought to the GLA.
Where necessary the Mayor will liaise with the police.
5 Fraud Investigation
5.1 On the decision being made that an investigation will be undertaken,
the Assistant Director of Finance will nominate an appropriately
qualified investigator – normally the Finance Manager leading on anti-
fraud measures – to undertake the investigation, the ‘Investigating
Officer The investigation will consist of, but not be limited to, the
interviewing of all necessary witnesses by the Investigating Officer,
and the collection and analysis of all relevant records available. The
investigation must be carried out by appropriately trained staff –
normally the Finance Manager leading on anti-fraud measures – and
must follow the requirements of relevant GLA policy and statute
legislation. The Assistant Director of Finance may seek direction and/
or assistance from Internal Audit.
5.2 The Executive Director of Resources and the Assistant Director of
Finance will determine whether external investigation resources are
required. The Executive Director of Resources and the Assistant
Director of Finance must be satisfied that whoever is appointed as
Investigating Officer has the requisite knowledge of criminal law, the
requirements of the Response Plan, and GLA policy that relates to
disciplinary investigations to ensure the interests of the individual(s)
being investigated and the GLA are being met. The Investigating
Officer will normally be the Finance Manager leading on anti-fraud
5.3 The Investigating Officer appointed will be in charge of the
investigation on a day-to-day basis and will report to the Assistant
Director of Finance. In cases where investigative work leads to a
widening of the scope, any new terms of reference will be agreed by
the Assistant Director of Finance, prior to that additional work taking
5.4 In the early stages of any fraud investigation the Assistant Director of
Finance, in conjunction with the Investigating Officer, will make an
assessment on the appropriateness of referring the matter to the
police. The Assistant Director of Finance will report any assessment
back to the Fraud Response Group prior to any final decision on
action being made.
5.5 Where necessary, the Assistant Director of Finance and the
Investigating Officer will liaise with the Head of Human Resources on
matters that may concern or influence any disciplinary proceedings.
5.6 Where the need for the investigation arises out of a GLA staff
member raising a concern, the Investigating Officer will hold a
preliminary interview(s) with the person(s) raising a concern. It is to
be made clear that, provided any allegation is made in good faith,
they will be protected by the GLA’sWhistleblowing Policy.
5.7 If the subject of an investigation is to be interviewed by the
Investigating Officer, the Fraud Response Group must ensure the
Investigating Officer is appropriately trained and a decision has been
made as to whether the interview is for internal disciplinary purposes
or for the suspicion of a criminal offence. Interviews for a criminal
offence should not be undertaken by staff who are not trained in the
requirements of the Police and Criminal Evidence Act 1984. Such
interviews should only occur if the police have been consulted
regarding the prospect of a criminal prosecution.
6. Preventing further loss
6.1 Where initial investigation provides reasonable grounds for
suspecting a member or members of staff or others of fraud, the
Fraud Response Group will decide how to prevent further loss. This
may require the suspension of the subject or subjects, under the
appropriate disciplinary procedure. It may be necessary to plan the
timing of suspension to prevent the subject(s) from destroying or
removing evidence that may be needed to support disciplinary or
criminal action. Any decision to suspend will follow the usual policy
requirements laid down by Human Resources.
6.2 In these circumstances, the subject or subjects will be approached
unannounced and will be supervised at all times before leaving the
GLA’spremises. They should be allowed to collect personal property
under supervision, but should not be able to remove any property
belonging to the GLA. Any security passes and keys to premises,
offices and furniture will be returned. System logins should also be
suspended along with remote access to the GLA’scomputer system.
6.3 The Fraud Response Group will consider whether it is necessary to
investigate systems other than that which has given rise to suspicion,
through which the subject may have had opportunities to
misappropriate the GLA’sassets.
7 Dealing with employees under suspicion
7.1 The Fraud Response Group will:
• Assess whether there is a need for any employee to be
suspended. The decision should be kept under review throughout
the investigation. The Head of Service of the member of staff
concerned should be kept informed where appropriate;
• Identify a course of action, including, following consultation with
the Police, whether to interview the employee under suspicion;
• Where considered necessary, require the Investigating Officer to
arrange a search of the suspected employee work area including
IT use. The Fraud Response Group must ensure that the
Investigating Officer has the appropriate knowledge to conduct
any such searches legally both under civil and criminal law so as
not to expose the organisation to any undue risk;
• Allow trade union assistance if requested, to support individuals
and to ensure the integrity of the evidence; and
• Ensure that strict confidentiality is maintained. This will include
ensuring that channels of communication, record keeping and
meeting locations are secure and confidential.
7.2 Human Resources will support all staff affected by a fraud
investigation, whether directly or indirectly, including directing
individuals towards sources of counselling and advice and applying
8.1 The Investigating Officer shall provide the Fraud Response Group
with periodic confidential updates throughout the investigation,
• Circumstances surrounding the case;
• Progress with the investigation;
• Quantification of losses where possible;
• Progress with recovery action;
• Progress with disciplinary action;
• Progress with criminal action; and
• Estimate of resources and actions required to conclude the
8.2 The Fraud Response Group will decide what, if any, specific action
should be taken as a result of the investigation and, more generally,
actions to be taken to prevent and detect similar incidents.
8.3 On completion of the investigation, the Investigating Officer will
submit a confidential written report to the Fraud Response Group,
• A description of the incident, including value of any loss, people
involved and the means of perpetrating fraud;
• Outcome of the investigation;
• The measures recommended to be taken to prevent a recurrence;
• Any action recommended to strengthen future responses to fraud.
9.1 No audit, fact-finding or investigation report or documentation is to be
made available to any person outside the Fraud Response Group
except as required for any legal reason. Staff who contravene this
rule could be liable to action under the GLA’sdisciplinary procedures.
9.2All evidence that is accumulated to support a disciplinary investigation
will normally be held for a period not less than equivalent to the
requirements of the GLA’sDisciplinary Policy. This information will be
held by the Executive Director of Resources or by an officer he
decides as appropriate.
9.3The Police will normally hold all evidence that is accumulated to
support a criminal investigation. However, if the evidence is held by
the GLA, all such information must be held for six years.
10 Contacting the Police
10.1 The GLA recognises that the experts in investigating crime are the
police, and that internal investigations have the potential to prejudice
police investigations. The Executive Director of Resources will have
the responsibility for requesting police involvement and liaising with
them after close consultation with the Fraud Response Group. Where
it appears more appropriate the Chief Executive may assume the role
of contact point with the police.
10.2 Any such request for police involvement will normally follow the
conclusion of the preliminary ‘fact-finding’exercise by the Assistant
Director of Finance where the Executive Director of Resources
considers, following advice from the Fraud Response Group, that
there is a potential criminal case.
10.3 If the Police decide that a criminal investigation is necessary, the
internal investigation and the police investigation will be co-ordinated
to ensure optimum use of resources and information and to avoid
jeopardising the police investigation. In all cases, the advice of the
police will be followed to avoid the risk of alerting subjects or the
contamination of evidence.
10.4 All staff will co-operate fully with any requests of police and of the
internal investigation. All contact with the police following their initial
involvement will be via the Investigating Officer or the Executive
Director of Resources.
10.5 The GLA may progress its own internal investigation in accordance
with this Anti-Fraud and Corruption Response Plan where the police
advise that a formal police investigation is not appropriate or are
content that the internal investigation will not hinder the criminal
11 Linkage between criminal and disciplinary proceedings
11.1 Where the outcome of a police investigation results in a criminal
conviction or an internal fraud investigation concludes that, on a
balance of probabilities, a fraud has occurred by a staff member, the
GLA’sDisciplinary Policy may be invoked. This process is informed
by the investigation and is to be managed by the relevant Head of
Service. Guidance from the Fraud Response Group and Human
Resources must be sought by the relevant Head of Service before
taking disciplinary action following a fraud investigation. Reference
and adherence to the Disciplinary Policy is required in these
11.2 In the circumstance where there is an on-going police investigation, it
may still be appropriate for the GLA to proceed with a disciplinary
investigation. Prior to commencing any internal disciplinary
investigation, advice is to be sought from the police to ensure there
will be no compromise of any on-going police investigation. The
interests of the GLA must be taken into account in these
circumstances and the Fraud Response Group will take a decision as
to whether to instigate internal disciplinary proceedings in parallel with
an on-going police investigation.
12 Civil recovery
12.1 Recovering losses is a major objective of any fraud investigation. The
Investigating Officer shall ensure that in all fraud investigations, the
amount of any loss will be quantified as far as possible. Repayment of
losses should be sought in all cases.
12.2 Where the loss is substantial, legal advice may be obtained about the
need to freeze the subject's assets through the court, pending
conclusion of the investigation. Legal advice may also be obtained
about prospects for recovering losses through the civil court, where
the subject refuses repayment. The GLA will normally seek to recover
its costs in addition to any losses as a result of the fraud. Clarification
should be sought from the Head of Legal on the appropriate action on
a case-by-case basis.
13 Profes sional disbarring
13.1 As a deterrent to fraud the GLA will make referrals regarding fraud
cases to individual’sprofessional regulatory bodies in order for them
to initiate their own disciplinary proceedings. Once again, care should
be taken to ensure such a referral does not impact upon criminal
investigations. Any such referrals will be co-ordinated by the Assistant
Director of Finance.
14 Media liaison
14.1 The Chief Executive, following advice from the Executive Director of
Resources and the Fraud Response Group, will have responsibility
for deciding upon an appropriate approach to deal with the media and
regarding internal communications during and after the investigation
with advice from, and liaison with, the Director of Communications.
15 Further Reporting and Counter Fraud Management
15.1 The Executive Director of Resources will decide how to provide, in
confidence, feedback to the person(s) who raised the initial concerns.
15.2 The Audit Panel will receive, as part of Internal Audit’sannual report,
summary information of the fraud referrals during the year.
15.3 The GLA’sAnti-Fraud Policy and Response Plan will be reviewed
15.4 The GLA has a duty to report all suspected frauds in excess of
£10,000 and all cases of corruption to its external auditors. The
Executive Director of Resources will formally advise the external
auditors of the commencement of all suspected fraud investigations
via submission of the AF70 fraud reports. These forms will be
submitted to the Audit Commission via governance- data@audit-
commission.gov.uk as required.
16 Dissatisfaction with the Investigation
16.1 Any complaints about the Investigation should be referred under
Grievance Procedure as appropriate.
FRAUD REPORTING – CONTACT DETAILS
Title Name Telephone No.
Executive Director of
Martin Clarke 020 7983 4435
Assistant Director of Finance David Gallie 020 7983 4000
Finance Manager Tom Middleton 020 7983 4257
Internal Audit Mike Clarkson or 07831748135
Richard Neal 07769952078
Confidential Reporting –
Fraud Reporting Line 0800 3280109
operated by Deloitte
The Seven Principles of Public Life
These standards, known as the Nolan principles, apply to all in the public
service including the Mayor, Assembly members and employees, temporary
staff, secondees and contractors working within the GLA.
Selfles sne s s
Holders of public office should act solely in terms of the public interest. They
should not do so in order to gain financial or other benefits for themselves, their
family or their friends.
Holders of public office should not place themselves under any financial or other
obligation to outside individuals or organisations that might seek to influence
them in the performance of their official duties.
In carrying out public business, including making public appointments, awarding
contracts, or recommending individuals for rewards and benefits, holders of
public office should make choices on merit.
Holders of public office are accountable for their decisions and actions to the
public and must submit themselves to whatever scrutiny is appropriate to their
Holders of public office should be as open as possible about all the decisions
and actions that they take. They should give reasons for their decisions and
restrict information only when the wider public interest clearly demands.
Holders of public office have a duty to declare any private interests relating to
their public duties and to take steps to resolve any conflicts arising in a way that
protects the public interest.
Holders of public office should promote and support these principles by
leadership and example.
FORMAT OF SPECIAL INVESTIGATION REGISTER
Fraud Date Fraud How was Person Person Who Brief Details of Who tasked Executive Director of
Investigation Reported Suspicion Reporting First Received Suspicion with Resources Approval
Number Reported Suspicion Suspicion Investigating of Investigation
1 11 June Line A. N. Other J. Bloggs Money taken from Internal J. Jill
2001 Management Donations Box Audit
2 13 June GLA Fraud Anonymous T. Boss Stolen Computer Internal J. Jill
2001 Line Audit