Decision details

Counter-Fraud and Corporate related investigative policies

Decision status: Recommendations Approved

Is Key decision?: No

Is subject to call in?: Yes




That the Cabinet:


1.    Agree to the implementation of the following policies attached in Appendix A:


·         Fraud Response Plan

·         Anti-Bribery Policy

·         Anti-Money Laundering Policy

·         Surveillance & RIPA Policy


2.  Agree that the policies in Appendix A are reviewed on a 3-year cycle by Cabinet unless there are formal legislative changes necessitating a review at an earlier stage, where the Corporate Director of Finance, in conjunction with the Cabinet Member for Finance, may authorise the changes required.


3.  Authorises the Cabinet Member for Finance to sign-off the yearly review of the Surveillance & RIPA Policy in line with the Investigatory Powers and Commissioner’s Office (IPCO) requirements.


4.  Agree to retire the Corporate Prosecution & Sanctions Policy and the Internal Investigations Protocol for the reasons set out in the report.


Reasons for decision


Cabinet considered and agreed updated counter fraud and related investigative policies, following a review.


The Leader of the Council, in Councillor Goddard’s absence, presented the report on counter fraud and corporate investigative policies. The Leader detailed the suite of policies that would guide the investigation of fraud, money laundering, and other criminal activities. These policies stood independently and offered transparency to the public on the Council’s investigative processes, providing a framework for both the Council and its officers. The Leader highlighted the Counter Fraud team’s recent successes in recovering substantial sums of money and assets, including addressing fraud in homelessness services where landlords had claimed for unoccupied temporary accommodations. Over 100 properties were recovered from council tenants who had been unlawfully subletting. The team’s efforts had been nationally recognised. The Leader of the Council gave particular emphasis on the policy on the use of CCTV and the necessary considerations for its deployment as an investigative tool.


Alternative options considered and rejected


An alternative would be for the Council not to update its policies; however, this would have had a negative impact as the Council would not be following best practice or legislative requirements. 



Relevant Select Committee

Finance and Corporate Services

Expiry date for any scrutiny call-in / date decision can be implemented (if no call-in)

Cabinet’s decisions can be called in by a majority of the select committee by 5pm, Friday 26 April 2024

Officer(s) to action

Alex Brown





The report and any background papers relating to this decision by the Cabinet are available to view on the Council's website or by visiting the Civic Centre, Uxbridge.




Publication date: 19/04/2024

Date of decision: 18/04/2024

Decided at meeting: 18/04/2024 - CABINET

Effective from: 27/04/2024

Accompanying Documents: