Anti-fraud and corruption policy, code of practice and fraud response plan for the MPA

Report: 8
Date: 20 June 2002
By: Treasurer

Summary

This report and the attached appendix 1 set out the proposed MPA policy on dealing with fraud and corruption. The report also gives an outline of the areas that will need to be covered to ensure that the MPA has an adequate anti fraud and corruption policy and Fraud Response Plan in place. A detailed paper agreed with the MPS will be presented to the next Audit Panel.

A. Recommendations

1. Members are asked to endorse the draft policy as the policy of the Metropolitan Police Authority.
2. Members agree the proposal to bring a full Code of Practice and Fraud Response Plan to the September Audit Panel

B. Supporting information

Current situation

1. The Audit Commission and good corporate governance practice for public bodies requires that the Metropolitan Police Authority has in place a clear policy for dealing with fraud and corruption. District Audit has made specific reference for the need to have such a policy in place in their Annual Audit Letter on the 2000/2001 Accounts. The policy should include a code of practice as well as a plan for responding to incidences of fraud and corruption.

2. The MPA has approved a number of documents concerning the proper conduct of its business and the MPS has in place a number of strategies and established procedures for dealing with fraud and corruption. These include:-

• MPA Model Code of Conduct for Members of the Authority
• MPA Financial Regulations
• Police Code of Conduct
• Civil Staff Discipline Procedures
• MPS Corruption and Dishonesty Strategy
• MPS Prevention and Detection of Fraud and Theft Special Notice.

3 The aim of this current exercise is to bring the appropriate parts of these documents together to create a coherent policy for the MPA and MPS in relation to fraud and corruption. Also to set out specific responsibilities for ensuring action is taken to minimise the opportunity for fraud and corruption as well as the response when it is suspected of having taken place.

Policy

4. The intrinsic nature of the Authority's responsibilities requires that a very clear policy statement is agreed and widely communicated within the MPA and MPS. The standards expected of the MPA and MPS, including members, police officers and civil staff, have to reflect public expectations of the appropriate behaviour for those responsible for policing and monitoring the police service in London. The policy set out in appendix 1 to this report reflects the standards expected.

Code of Practice

5. The Code of Practice outlined at appendix 2 will be the means by which the standards expected by the Authority's policy are communicated within the MPA, MPS and to all those with whom they have contact.

Fraud Response Plan

6. The fraud response plan will set out responsibilities for action within the MPA and the MPS when suspected fraud or corruption is reported.

Next Steps

7. Subject to the Panel agreeing the policy statement, MPA Internal Audit will enter into a dialogue to develop the Code of Practice and the Fraud Response Plan with the MPS through the Director of Resources and directly with Professional Standards, Human Resources and the Fraud Squad in the Specialised Crime Command Unit of the MPS. A paper agreed with the MPS will be presented to the next Audit Panel.

C. Financial implications

This report has no financial implications as this activity is covered within existing budget allocations.

D. Background papers

None.

E. Contact details

Report author: Peter Tickner, Director of Internal Audit, MPA.

For information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

Appendix 1: Draft anti fraud and corruption policy statement

Introduction

The Metropolitan Police Authority is committed to a culture that is one of honesty, integrity and propriety in the use of public funds and the holding of public office.

Application of this Policy

This policy is applicable to members and officers of the MPA, police officers and civil staff under the control of the Commissioner and all external persons with whom the MPA conduct business.

Policy

The policy of Metropolitan Police Authority in relation to fraud and corruption is set out below. The Authority requires that:-

• Members, police officers and civil staff at all levels will lead by example in ensuring compliance with legal requirements, rules, procedures and practices, including those relating to acceptance of gifts and hospitality and outside business interests. In the words of the MPS Corruption and Dishonesty Strategy 'integrity is not negotiable'.
• Members will conduct themselves in accordance with the spirit and letter of the Model Code of Conduct.
• Senior officers of the MPA and MPS are required to deal swiftly and firmly with those who defraud the Authority or are corrupt.
• Individuals and organisations such as suppliers, contractors, service providers that it conducts business with, will act towards the Authority with integrity and a total absence of fraudulent or corrupt practices.
• All police officers paid by the MPA and employees of the MPA, including MPS civil staff, have a duty to report any suspected fraudulent or corrupt practice affecting the MPA or the MPS to the appropriate line manager or senior officer at the earliest opportunity.
• Members have a duty to report any fraudulent or corrupt practice coming to their notice that may affect the MPA or the MPS to the Clerk at the earliest opportunity.
• All fraud and corruption affecting the MPA or the MPS, including suspected cases, will be reported immediately to the Director of Internal Audit on behalf of the Treasurer, irrespective of whether the matter is the subject of a criminal investigation. The Treasurer will bring to MPA member attention those cases he regards as sufficiently serious so to do.
• In those cases where sufficient evidence is available, criminal or disciplinary action will be taken.
• Civil recovery (including civil court action) of funds lost by fraud and corruption will be considered in all established cases.
• Managers at all levels will ensure that effective procedures, practices and controls are in operation in their areas of responsibility to minimise the opportunities for fraud and corruption.
• A memorandum of understanding exists between MPA Internal Audit and the MPS Directorate of Professional Standards to facilitate effective action in responding to cases of suspected fraud and corruption.

Appendix 2: Outline code of practice – dealing with fraud and corruption

1. Metropolitan Police Authority Policy
2. What is meant by fraud and corruption to the MPA
   1. Fraud is defined for the purposes of this code as a theft perpetrated or concealed by the distortion or manipulation of financial statements or records. It can range from the simple alteration of documents to complicated, sophisticated and technical manipulation.
   2. Corruption is the offering, giving, soliciting or acceptance of an inducement or reward that may influence the action of any person to the detriment of the MPA or its authorised agents.
3. Your Duty
4. What to do if you suspect fraud or corruption
5. Responsibilities of line management, Human Resources, the police and Internal Audit
6. Using the Right Line to report wrongdoing (internal whistle-blowing)
7. Reporting to Public Concern at Work (external whistle-blowing)
8. The Law

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