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Anti-Fraud & Corruption Policy and Procedures

Reporting Irregularities

  1. Members
    1. Where Members wish to report alleged irregularities, the normal reporting route should be through the Head of Paid Service or the Treasurer.
    2. The Head of Paid Service and Monitoring Officer must be informed where alleged irregularities involve Members. If allegations involve a breach of the Code of Conduct this will be referred to the Standards Committee where any appropriate action will be taken.
  2. Officers
    1. As indications of suspected irregularities could arise in many different ways it is possible that any of the Combined Authority’s officers could be the first to become alerted to a potential situation involving fraud or corruption.
    2. Any officer, becoming aware of a potential financial irregularity must, under normal circumstances, report the situation to his/her line manager as soon as possible. The manager in turn should also report through the management structure and to Internal Audit as soon as possible.
    3. At the appropriate management level, which is normally Chief Officer, the situation must be reported to Internal Audit which will then inform the Treasurer and agree a course of action.
    4. Internal Audit will advise on and instigate such action as considered necessary for investigating the alleged irregularity. This will take into account whether the alleged financial irregularity warrants investigation by Internal Audit, whether the Police should be referred to immediately or whether the Combined Authority should conduct its own investigation.
    5. Where an allegation or suspicion of fraud concerns an officer of the Combined Authority and is considered sufficiently serious to be investigated, then an Investigating Officer will be appointed. As appropriate and agreed Internal Audit will investigate fraud involving accounting and other records, evaluate systems and internal control and collate evidence providing an opinion on allegations made. This will be reported to the Investigating Officer who will have overall responsibility in taking the investigation forward for disciplinary purposes and reported to the Treasurer where system weaknesses and control issues are involved. The Combined 8 Version 2.0, Owner: Head of Governance 27/02/2017. Review: 27/02/2018 Authority will consider the full range of sanctions, disciplinary, regulatory, civil and criminal which will be applied as appropriate to each case. Where allegations are identified to have been made maliciously appropriate action will be taken.
  3. Reporting Directly to Internal Audit or the Statutory Officers of the Combined Authority
    1. If an officer feels it would not be appropriate to report alleged or suspected irregularities through the normal line management structure, then the officer should report to a Statutory Officer of the Combined Authority. If the officer feels uncomfortable with this approach they can report directly to Internal Audit.
    2. In certain circumstances it would be appropriate for an officer to report directly to Internal Audit anyway. For example, if there were reasons to believe that any subsequent investigation might be compromised if the situation were to be reported through managers. The most likely reasons for reporting direct to Internal Audit would include because line managers were implicated in the alleged irregularity and the officer was not sure who it was safe to report to within the team or there were reasons to believe that the situation might be suppressed or covered up by senior managers.
    3. The Combined Authority encourages people not to make anonymous reports so that a full and thorough investigation can be conducted. However, it is recognised that in some circumstances officers may wish to remain anonymous. In this instance there is the facility to report alleged or suspected irregularities via the WMCA website ‘Contact Us’ page ( https://www.wmca.org.uk/contact-us/ ), by leaving the name fields blank. Ensure that Whistleblowing and Fraud has been selected as the subject. Alternatively an email can be sent to internalaudit@wmca.org.uk
  4. Alternative Contact Points
    1. The Combined Authority provides the reporting lines above to ensure that Members and officers are satisfied that reports will be treated seriously and that action will be taken. If they consider this is not the case then matters could be taken outside the Combined Authority to other contact points. The process for this is described in more detail in the Whistleblowing policy and guidance.
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