Report of the Head of Internal Audit and Risk Management is attached

Members considered the report of the Head of Internal Audit and Risk Management which presented updated drafts of the Whistleblowing, Anti-Money Laundering and Anti-Bribery Policies for comment prior to approval. The role of the Audit Committee in seeking to obtain assurance over the Council’s corporate governance and risk management arrangements includes an overview of the key policies and procedures in respect of anti-fraud and anti-corruption arrangements.

The Chair invited questions from the Committee.

A member referred to the list of ‘possible signs of money laundering’ provided in Appendix B of the report and asked officers if this was a definitive list. Reference was also made to the whistleblowing and if council officers were comfortable with the current reporting arrangements.

In response, the Head of Internal Audit and Risk Management noted the point made on the extensive list of signs of money laundering and undertook to amend the policy text to reflect this. With reference to arrangements allowing employees to ‘whistleblow’, it was reported that staff were comfortable with the current mechanisms and information available to them. Any whistleblow issue would include a risk assessment and investigation to ensure that a matter had been raised in good faith and was justified.

A member referred to arrangements where a member of staff employed within the Council raised a matter relating to an issue under to control of integrated health services and asked where would the whistleblow be reported to.

It was reported that the employee would make a report to their employer and not the employer of the service relating to the area of concern. The Committee was informed that a process of alignment of policies and processes of the organisations involved would be required.

A member asked if a benchmarking process is used to measure the effectiveness of the whistleblowing policy and the routes used by staff that may indicate a preference to using an internal or external route. Reference was also made to the need to include a link to the external organisation regarding anti-bribery to mirror the links within the money laundering procedures.

It was reported that the Standards Committee receives a benchmarking report on the efficacy of the whistleblowing policy. The benchmarking report had indicated that the Council has a higher number of whistleblowing reports compared to other core cities. The suggestion was made that qualitative research on this could indicate that the council as an organisation has a good ‘speak up’ culture where staff are aware of information available and feel comfortable to raising matters. Reference would be made to this in the Annual Fraud report to the Audit Committee. The issue of consistency across the policy document would be addressed to include information and contact links to the external organisations.

A member referred to the involvement of the charity ‘Protect’ and officers were asked the charity could provide the same information awareness arrangement for health organisation staff. In addition, officers were asked what communication arrangements are in place to make staff aware of the whistleblowing process.

It was reported that the suggestion would be taken for discussion with colleagues in the CCG and the MHCC. A review of the whistleblowing helpline would be undertaken after six months to determine the use of the service for staff. The arrangements in place for communicating information to staff were crucial and the ‘Forum’ staff publication would include reference to whistleblowing and signposting. Managers willl include whistleblowing as an agenda item in staff meetings.

The Committee agreed that it was satisfied with the assurance provided by the Counter Fraud Policy provided within the report it had considered.

Decisions

1. To note and endorse the draft policies in the report submitted, in advance of approval by the Chief Executive.

2. To note the comments received.