Item 10.1 - Attachment 1
Fraud and Corruption Prevention Policy
Fraud and Corruption
Adopted by Council
Parramatta City Council (Council) is committed to high ethical standards. Council has a responsibility to protect taxpayer
funded resources and assets from fraud and corruption and to ensure that its
decisions and actions are free from any corruption.
This Policy provides guidance as to:
· Council’s actions and expectations in relation to
fraud and corruption.
· The responsibilities of Councillors, Council staff and
Council contractors for dealing with the risks of fraud and corruption.
This Policy sets out Council’s strategic approach to
fraud and corruption prevention, detection and investigation.
This Policy aims to reduce the likelihood of
Councillors, Council staff, Council contractors and members of the public
acting in a fraudulent or corrupt manner in their dealings with Council.
Legislation, Policies and Strategies
legislation, Council adopted policies and Council adopted strategies are
relevant to the interpretation and implementation of this Policy:
· Local Government Act 1993.
· Crimes Act 1900.
· Independent Commission Against
Corruption Act 1988.
· Protected Disclosures Act 1994.
· Guiding Principles.
· Code of Conduct.
· Whistleblowers Protection Policy.
· Customer Compliments and Complaints
· Performance Counselling and
· Policy for Interaction Between
Councillors and Staff.
· Criminal History Record Checks
· Fraud and Corruption Prevention
Strategy (currently under development).
and Council staff
Councillors and Council staff have the following
· Report all instances of
suspected or actual fraud or corrupt conduct in accordance with Council’s Code
of Conduct and Internal Reporting Policy (Whistleblowers Protection Policy).
· Report behaviour that
comprises an attempt or an inducement to engage in any fraud or corruption.
· Refrain from taking (or
encouraging other to take) any action or engage in any conduct against any person
who reports fraud, corruption, maladministration or serious and substantial
waste that is detrimental to the interests of any such person.
· To the extent that they are
reasonably capable of doing so, protect any person who reports fraud,
corruption, maladministration or serious and substantial waste from any action
or conduct that is detrimental to the interests of any such person if they become
aware of the identity of a person who has made any such report.
· Operate systems of internal
control that are established to prevent or detect fraud or corruption.
· Undertake relevant training relating
to the prevention, detection and investigation of fraud and corruption.
· Assist in investigations
undertaken in respect of any suspected or reported fraud or corruption
and Team Leaders
Council staff that holds the position of managers or
team leaders have the following responsibilities, in addition to their
responsibilities as Council staff stated elsewhere in this Policy
· Take appropriate measures to
ensure that their staff understand the standards of expected behaviour as
outlined in the Guiding Principles, Council’s Code of Conduct, and relevant
policies and procedures
· Ensure that any suspected
fraud or corruption, maladministration and serious and substantial wastage reported
to them are referred to the Manager, Service Audit & Review or the Chief
Executive Officer without delay. If a
report is received orally, they must take steps to record the report in writing.
· To the extent permitted by
law, maintain the confidentiality of people making reports and the subject
matter of those reports.
· Ensure that Council staff who
have reported any suspected fraud or corruption, maladministration and serious
and substantial wastage in accordance with this Policy are not disadvantaged or
suffer detrimental action
· Take steps to identify and
assess the risk of fraud or corruption occurring in their area of
· Take steps to ensure that systems
and controls are implemented to address any identified risks of fraud or
corruption in their area of responsibility, and monitor the continued operation
of those systems and controls.
· Demonstrate leadership in the
area of ethics and the minimisation of fraud and corruption.
· undertake regular reviews and
checks to detect irregularities
· use basic data mining tools
to detect possible fraud and corruption
· Ensure that all Council staff
in their area of responsibility have been made aware of this Policy, and that
this Policy is readily available for their inspection.
· Take reasonable steps to
require that Council contractors whose contracts they administer comply with this
Policy to the extent that it is relevant to their contractual arrangements and
adhere to the ethical standards described in this Policy.
Risk Assessment Reviews
Council staff that hold the position of managers or
· are primarily responsible for fraud and corruption
prevention and detection in their areas of responsibility;
· should conduct fraud and corruption risk assessments
in their area of responsibility. .
· implement systems and controls to minimise fraud or
corruption risks to an extent consistent with the objective of this Policy;
· On a biannual basis undertake
assessments of fraud or corruption risks in their area of responsibility
respect of fraud or corruption, and more frequently in areas that are
considered to have a higher risk of fraud or corruption. Assessments must be conducted in accordance
with best practice, prevailing domestic and international standards (such ISO
31000) and laws relating to fraud and corruption prevention.
These risk assessments will be reviewed, periodically
by an appropriately qualified risk management professional.
The implementation of systems and controls too
minimise fraud or corruption together with the assessment of fraud or
corruption risks must:
· be undertaken in consultation with the Manager,
Service Audit & Review; or General Counsel, and
· comply with any directions or guidelines issued from
time to time by the Chief Executive Officer, the Manager, Service Audit &
Review or General Counsel relating to any such assessments.
Councillor and Council Staff Awareness
Councillors and Council staff must participate in
training and education provided by Council that is directed towards to
communicating to them that fraud or corruption are unacceptable. Fraud and corruption control is the
responsibility of every person.
Council staff that hold the position of managers or
team leaders must be proactive in identifying behaviours that could result in
corruption, either real or perceived.
Council will provide training and education to assist
Councillors and Council staff in being able to identify and prevent fraud or
corruption in accordance with this Policy.
5.4 Customer and Community Awareness
Council must promote awareness among the community,
customers, contractors, suppliers and other third parties that fraud or
corruption in any dealings with Council is unacceptable.
Council staff that holds the position of managers or
team leaders must assist third parties to report any suspected fraud or
Reporting Suspected Fraud or Corruption
Ignoring fraud or corruption is tantamount to
endorsing it. Ignoring fraud or
corruption and turning “a blind eye” can lead to it becoming acceptable
behaviour that can taint whole sections of the organisation. Reporting fraud and corruption is an
obligation imposed by honesty.
Councillors, Council staff and Council contractors are
required to report any suspected fraud or corruption in accordance with the
procedures set out in the Code of Conduct or the Whistleblower’s Protection
Policy or both. Reports of suspected
fraud or corruption can be report to Council’s disclosure hot-line on 1300
30 45 50.
Council staff who hold the position of managers or
team leaders must ensure that Council staff are supported in reporting
suspected fraud and corruption, and facilitate the reporting of any suspected
fraud or corruption in accordance with the procedures set out in the Code of
Conduct or the Internal Reporting Policy or both.
Managers are responsible for establishing, documenting
and maintaining appropriate fraud and corruption controls and detection systems
in their areas. Regular internal audits
are also undertaken to detect fraud and corruption.
Crimes committed against the Council will be reported
to the police and any corruption will be reported to the Independent Commission
Against Corruption. Other external
authorities will be notified of fraudulent or corrupt conduct as considered appropriate
by the Manager, Service Audit & Review , the Chief Executive Officer, or
the General Counsel.
All suspected or alleged fraud or corruption will be
investigated. Councillors, Council staff
and Council contractors must cooperate fully in such investigations.
Investigations will be undertaken under the direct
authority of the Chief Executive Officer in accordance with appropriate
investigation standards and the principles of natural justice.
Conduct and Discipline
Councillors and Council staff must carefully read,
understand and observe the Code of Conduct.
Fraud or corruption is unacceptable and offenders will
face disciplinary action in accordance with the Code of Conduct.
Council may seek criminal prosecution for any fraud or
Council may institute civil or administrative legal proceedings
in respect of fraud or corruption. as considered appropriate by the CEO or
6.1 Fraud is:
dishonest activity causing
actual or potential financial loss to any person or entity including theft of
moneys or other property by employees or persons external to the entity and
whether or not deception is used at the time, immediately before or immediately
following the activity. This also
includes the deliberate falsification, concealment, destruction or use of falsified
documentation used or intended for use for normal business purposes or the
improper use of information or position.
· conduct of a person (whether or not a public official)
that adversely affects, or could affect the honest and impartial exercise of
public official functions, or
· conduct of a public official that involves the
dishonest or partial exercise of any of his or her public official functions,
· a breach of public trust, or
· the misuse of information or material acquired in the
course of a public official’s functions.
Additionally corrupt conduct
can also be conduct of any person (whether or not a public official) that
adversely affects or could affect the exercise of official functions and
involves conduct such as bribery, blackmail, fraud, forgery and various other
For conduct to be corrupt it
must be covered by one of the conditions above and also any one of the
· a criminal offence; or
· a disciplinary offence; or
· reasonable grounds for dismissal or dispensing or
terminating the Councils of a public official.
This policy was adopted by Council on XX/XX/2011.
This policy is scheduled for review eighteen months
after its authorization, and every twelve months thereafter.
Service Audit & Review Unit is responsible for this policy