Anti-Fraud, Bribery and Corruption Policy
Anti-Fraud, Bribery and Corruption Policy
All schools must have a robust system of controls to safeguard themselves against fraud, bribery or improper use of public money and assets.
Hawkhurst Church of England Primary School is committed to the prevention of fraud, bribery and corruption and the promotion of an anti-fraud, bribery and corruption culture.
Hawkhurst Church of England Primary School takes a risk-based approach to fraud, bribery and corruption and requires all staff, governors and volunteers to act honestly and with integrity at all times, and to report all suspicions of fraud or financial wrongdoing.
Hawkhurst Church of England Primary School will investigate all instances of actual, attempted or suspected fraud, bribery and corruption and will seek to recover any losses and pursue appropriate sanctions against the perpetrators. This may include criminal prosecution, disciplinary action, legal proceedings and professional sanctions.
This policy applies to all staff (full time, part time, temporary and casual), consultants, volunteers and the school’s Governing Body.
Definition of Fraud
Fraud is deception carried out in order to gain an unfair advantage or to disadvantage another. It may involve the misuse of funds or other resources, or the supply of false information.
Examples might include:
Individuals caught committing fraud can be prosecuted under the Fraud Act 2006 if they make a false representation, fail to disclose information or abuse their position.
Definition of Bribery and Corruption
Hawkhurst Church of England Primary School defines corruption as the abuse of entrusted power for private gain; involving the offering, giving or soliciting of an inducement or reward which may influence a person to perform a function or activity improperly. This may involve:
Other forms of corruption include:
The Governing Body are responsible for:
The Head Teacher is responsible for:
Staff are responsible for:
The Seven Principles of Public Life
Selflessness – Holders of public office should take decisions solely in terms of the public interest. They should not do so in order to gain financial or other material benefits for themselves, their family or their friends.
Integrity – Holders of public office should not place themselves under any financial or other obligation to outside individuals or organisations that might influence them in the performance of their official duties.
Objectivity – 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.
Accountability – 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 office.
Openness – 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.
Honesty – Holders of public office should promote and support these principles by leadership and example.
The Governing Body and staff are an important element in the school’s stance on fraud and are required to raise any concerns that they may have. The Head Teacher and Governors will deal with any financial irregularities robustly.
Staff should immediately report any concerns about actual, attempted or suspected fraud to the Head Teacher. However, if the concerns relate to the Head Teacher, staff should report their concerns to the Chair of Governors.
Under no circumstances should staff investigate the matter themselves.
Members of staff, including the Head Teacher and/or Governors should seek advice about how to deal with an allegation of fraud, and report the matter to Kent County Council Whistleblowing helpline which is operated by Internal Audit. Alternatively, staff can email Kent County Council’s Internal Audit team.
The Public Interest Disclosure Act 1998 protects employees who raise concerns about certain matters of public interest in good faith. Staff can obtain free independent advice from the charity Protect by following https://protect-advice.org.uk/.
A copy of the school’s Whistleblowing Policy can be found in the staffroom and on the shared school staff file or can be obtained from Jodi Hacker, Headteacher.
Contact Details: email@example.com
Telephone: Kent County Council Whistleblowing Helpline 03000 414 500
Fraud, Bribery and Corruption Response Plan
Hawkhurst Church of England Primary School has established guidelines for senior staff and the Governing Body on the immediate actions to be taken in the event of a fraud being discovered or suspected. It covers how and when to seek professional advice, securing evidence and preventing further losses (see Appendix 1).
It is important that allegations of actual, attempted and suspected fraud aren’t ignored. Even seemingly insignificant concerns may later reveal a larger, previously unknown problem.
Step 1. Report
The first step to make if you suspected fraud or financial wrongdoing is to contact the Counter Fraud Team, in Internal Audit at Kent County Council. They are responsible for the investigation of fraud and financial irregularities that occur against Kent County Council and Schools.
They will listen to your concerns and advise on the best course of action to take in order to minimise the risk of the suspect being tipped off and destroying the evidence.
You can report the concerns by;
Step 2. Securing Evidence
You may be asked to provide a witness statement so ensure that any concerns are recorded fully. Whenever possible keep written notes that cover:
Never remove any physical evidence such as original invoices, receipts, letters, cheques and application forms unless you have sought advice from the Counter Fraud Team as this could alert the suspect and tip them off.
Under no circumstances discuss the matter with colleagues as this could be discussed with the suspect.
If an investigation is undertaken without following the appropriate policies, procedures and legislation, or if individuals are accused without sufficient evidence, it may lead to the perpetrators avoiding a disciplinary, criminal or civil sanction.
Step 3. Preventing Further Losses
It is important to minimise any additional losses. For example, if the allegations concern the theft or loss or banking passwords, PIN’s or similar credentials notify the bank immediately.
Equally, if the losses relate to a weak process, for example cash is routinely kept unsecured in a drawer, ensure that the process is changed, at least temporarily, until more permanent and improved processes can be implemented.
Support for Witnesses
Members of staff, Governors and the public may be feeling vulnerable before, during and after they have brought an allegation of fraud to the attention of the school.
Reassure witnesses that they have acted appropriately by raising their concerns. Members of staff should be provided with a copy of the Whistleblowing Policy and reminded that the school does not tolerate reprisals, victimisation or harassment and will take all reasonable action to protect them.
In addition, the school will take steps to minimise any difficulties members of staff may experience as a result of raising a concern. For instance, if they are required to give evidence in criminal or disciplinary proceedings, the school will advise or arrange for them to receive advice and support about the process being followed.
|Please note that the appendices for the above policy are only available in the downloadable policy PDF file due to being presented in landscape and not fitting within the limits of the website display.|