Corporate Anti-fraud

and Corruption Strategy

Index

1 Introduction

1.1 Hampshire County Council is determined to discharge its responsibilities to safeguard public funds and is committed to fighting fraud and corruption whether attempted from inside or outside of the Authority. The Council is committed to the highest ethical standards and requires Members, Chief Officers and all other staff to comply with the seven principles of public life, as outlined below; the Council's anti-fraud and corruption policy; and codes of conduct as set out in the appendices to this corporate anti-fraud and corruption strategy.

1.2 The Council believes strongly in the honesty and integrity of its Members and employees and has achieved a reputation for maintaining effective systems of control. The Council also expects that all outside individuals and organisations, including suppliers, contractors and claimants will act towards the Council with honesty and integrity. The Council will not tolerate fraud, corruption or other irregularities, regardless of the perpetrator. The Council is therefore determined to prevent, deter and detect all forms of fraud and corruption committed against it and take appropriate action where fraud or corruption is detected.

1.3 The Council's commitment to protecting public funds is set out in the anti-fraud and corruption policy statement shown at Appendix A and the Prosecution and Recovery Policy shown at Appendix B, which were approved by the Governance Committee on 10 March 2005.

1.4 The purpose of the anti-fraud and corruption strategy is to aim to put into place mechanisms that will prevent, deter and detect fraud and corruption. The strategy summarises the responsibilities of Members, Chief Officers and employees and outlines the process to be followed where there is suspicion of financial irregularity. The strategy applies equally to all organisations with which the Council has joint working relations.

2 Key Principles and Culture

2.1 The anti-fraud and corruption strategy endorses and adopts the seven principles of the Nolan Committee in seeking to create a culture of honesty and opposition to fraud, corruption and irregularity:

Selflessness

Holders of public office should take decisions solely in terms of the public interest. They should not do so in order to gain financial or other material benefits for themselves family or friends.

Integrity

Holders of public office should not place themselves under any financial or other obligation to outside individuals or organisations that might influence them in the performance of their official duties.

Objectivity

In carrying out public business, including making public appointments, awarding contracts, or recommending individuals for rewards and benefits, holders of public office should make choices on merit.

Accountability

Holders of public office are accountable for their decisions and actions to the public and must submit themselves to whatever scrutiny is appropriate to their office.

Openness

Holders of public office should be as open as possible about all the decisions and actions that they take. They should give reasons for their decisions and restrict information only when the wider public interest demands.

Honesty

Holders of public office have a duty to declare any private interests relating to their public duties and to take steps to resolve any conflicts arising in a way that protects the public interest.

Leadership

Holders of public office should promote and support these principles by leadership and example.

2.2 Irregularities includes, theft, fraud and corruption:

Definitions

Theft is "the dishonest taking of property belonging to another person with the intention of permanently depriving the owner of its possession"

Fraud is "the intentional distortion of the financial statements or other records by a person internal or external to the organisation which is carried out to conceal the misappropriation of assets or otherwise for gain"

Corruption is "the offering, giving, soliciting or acceptance of an inducement or rewards which may influence the action of another person".

Irregularity may also include, failure to comply with Financial Regulations, Standing Orders, national and local codes of conduct, Health and Safety Regulations and all other relevant laws and legislation that result in an avoidable loss to the Authority.

2.3 Honesty, openness and integrity is at the core of the Council's objectives, which positively encourages a culture that is opposed to fraud and corruption. Staff are expected, and are positively encouraged to raise any concerns relating to fraud and corruption which they become aware of. These can be raised in any way that the employee prefers, including with their line manager, through a chief officer, internal audit, or through the guidance provided in the Council's Reporting Concerns at Work procedure shown at Appendix C. This sets out the means by which Members and employees may raise any concerns that they have on issues associated with the Council's activities. Whichever route is chosen the employee can be assured that concerns raised in good faith will be fully investigated and, wherever possible, the employee will be dealt with in confidence.

3 Prevention

3.1 The Council's corporate governance framework contributes to the prevention of fraud and corruption. Key elements include:

· Codes of conduct for Members and Officers

· Financial Regulations and Procedures

· Contract Standing Orders

· Effective Internal Audit

· Risk Management Policy

· Reporting Concerns at Work procedure

· Complaints procedure

· Disciplinary procedures

· Prosecution and Recovery Policy.

In addition, the Council is subject to external scrutiny from a variety of bodies. These include the Local Government Ombudsman, Audit Commission, Central Government Departments and Parliamentary Committees, HM Customs and Excise, Inland Revenue and external inspectorates.

3.2 Responsibilities of Members

3.2.1 The elected Members of the Council have a duty to protect the funds and assets of the Council from all forms of abuse. This is achieved through the issue of the anti-fraud and corruption policy statement and this strategy, the effectiveness of which shall be monitored by the Governance Committee.

3.2.2 Members must maintain the highest standards of accountability and probity and therefore will comply, at all times, with the Code of Conduct for Members.

3.3 Responsibilities of the Monitoring Officer

3.3.1 The Head of Corporate and Legal Services is designated by the County Council as the Monitoring Officer under Section 5 of the Local Government Act 1989. With this role is attached responsibility for ensuring lawful and fair decision making.

3.3.2 If the Monitoring Officer is of the opinion that any decision or omission would give rise to either unlawfulness or maladministration, the Monitoring Officer has a duty to either ensure that the situation is rectified or report on the matter to full Council. In the event of the latter situation the effect of the Monitoring Officer's report will be to stop the act or omission until full Council has considered the matter.

3.3.3 The Head of Corporate and Legal Services is also authorised by the County Council "to commence, defend or participate in, any legal proceedings in any case, where necessary, to give effect to the decisions of the Council, or in any case where the Head of Corporate and Legal Services considers it necessary to protect the Council's interests".

3.4 Responsibilities of Managers

3.4.1 Management at all levels within the Council have a responsibility to ensure that there are sound systems of internal control. Management are responsible for ensuring that their staff are aware of Financial Regulations and Procedures, and Contract Standing Orders and that these are being followed. Management should ensure that staff know how to deal with concerns at work and that staff are aware of the Reporting Concerns at Work procedures.

3.4.2 For contracted out services and partnership arrangements, Management should determine the risk of fraud and corruption and incorporate appropriate controls and safeguards within tender documentation, contracts and partnership agreements.

3.4.3 Management should implement agreed audit recommendations within appropriate timescales.

3.4.4 Managers must report all suspicions of theft, fraud and irregularity to the Chief Internal Auditor immediately.

3.5 Responsibilities of employees

3.5.1 Employees should comply with the Council's Code of Conduct and the requirements of the Financial Regulations and Procedures and Contract Standing Orders. Employees are expected to maintain honesty and integrity at all times and act with propriety in the use of official resources and corporate funds.

3.5.2 Employees should always be aware of the possibility that fraud, corruption and theft may exist in the workplace and have a duty and a right to share any concerns they may have with management or through the Reporting Concerns at Work procedure.

3.5.3 The Reporting Concerns at Work Procedure gives alternative ways of raising concerns including externally, if employees feel unable to use the internal routes. Contact details listed include external audit and Public Concern at Work, which is a charity.

3.5.4 Staff are reassured that they will be protected from possible reprisals or victimisation if they have disclosed information in good faith. However if an allegation is made maliciously or for personal gain, disciplinary action may be taken against the individual. Management will investigate all concerns raised by staff and the Reporting Concerns at Work procedures explain the courses of action that can be expected to occur.

3.6 Responsibilities of contractors, suppliers, customers and members of the public

3.6.1 The Council shall expect that contractors are able to demonstrate, through the tendering process, that they have adequate systems of control to ensure the prevention and detection of fraud and corruption in relation to services provided on behalf of the Council.

3.6.2 Suppliers, customers and members of the public are also encouraged to report concerns through the Public Complaints Procedure and Reporting Concerns at Work.

3.7 Responsibilities of partnerships and voluntary organisations

3.7.1 All partnerships and joint working arrangements that are in receipt of Council funding or resources shall be expected to demonstrate appropriate mechanisms for control. Partnership agreements should refer to the adopted Financial Regulations and Codes of Conduct, which govern the partners and to the internal audit arrangements.

3.7.2 Voluntary organisations should be encouraged to follow the standards set by the Council and the Council's anti-fraud and the corruption strategy should be made available where the voluntary organisations is in receipt of grant funding.

3.8 Responsibilities of Internal Audit

3.8.1 Internal Audit is responsible for undertaking an annual risk assessment of the Council's framework of internal control and for producing an annual audit plan in accordance with the approved Internal Audit Strategy. The County Treasurer, as the s151 Officer to the Authority (Local Government Act 1972), should approve the annual plan.

3.8.2 In accordance with the annual plan, Internal Audit will review the Council's systems and where necessary, make recommendations to the appropriate level of management on improvements to control and agree an action plan. Whilst conducting their reviews, auditors will plan and evaluate their work so as to have a reasonable expectation of detecting fraud and to identify any significant weaknesses in internal controls. Internal Audit shall be responsible for assessing that agreed actions arising from significant risks identified have been implemented.

3.8.3 The Chief Internal Auditor shall provide the departmental management teams with an annual audit opinion on the adequacy of the department's internal controls and provide an annual assurance statement to the Governance Committee on the overall effectiveness of the Council's framework of internal control, highlighting any serious weaknesses.

3.9 Recruitment and induction

3.9.1 The Council recognises that one of the most important issues in relation to the prevention of fraud and corruption is the recruitment of appropriate staff. Managers are required to:

· obtain satisfactory references prior to appointments being made

· verify and retain copies of certificates for stated qualifications

· comply with Section 8 of the Asylum & Immigration Act regarding entitlement to live and work in the UK

· undertake Police checks where it is appropriate to the post.

3.9.2 Managers should ensure that staff induction includes raising fraud awareness and the responsibilities of staff to report suspicious activity to their line manager or through the Reporting Concerns at Work procedures.

3.10 Register of interests and gifts and hospitality

3.10.1 All Members of the County Council are required to register their financial and other appropriate personal interests, in accordance with the provisions of the Code of Conduct applying to them, in a register maintained in the Chief Executive's department. The Chief Executive's department sends a reminder to all Members at least annually. Members are also required to declare any personal interests prior to the commencement of Council meetings or immediately before a matter in which they have a personal interest is discussed. If a member has a prejudicial personal interest in any matter coming before the Council they must not be present in the meeting room and must refrain from improperly influencing the decision.

3.10.2 A member must also, by virtue of the provisions of the Code of Conduct, within 28 days of receiving any gift or hospitality over the value of £25 provide written notification of such to the Monitoring Officer.

3.10.3 Generally, employees are required to decline offers of hospitality, particularly personal gifts from contractors and outside suppliers. There is a duty for all staff to act within statutory regulations including the Local Government Act 2000 particularly in relation to disclosing pecuniary interests, conflicts of interest, gifts and hospitality. A register is held by the Head of Democratic Services, Chief Executive's department. As a guideline, gifts/hospitality with a value of £25 or above are required to be registered. Chief Officers should ensure that staff are aware of this requirement.

4 Deterrent and detection

4.1 The Council has put in place systems and procedures to manage and discharge its functions in an efficient and effective way. These systems incorporate internal controls to prevent and deter fraud and corruption, including adequate separation of duties where appropriate.

4.2 Financial Regulations require that Chief Officers ensure that controls are properly maintained, that staff ensure that working practices comply with the systems and that Internal Audit regularly check the existence, appropriateness and effectiveness of the controls.

4.3 Prosecution and recovery policy

4.3.1 The Council has adopted a Prosecution and Recovery Policy, which encompasses both internal and external fraud perpetrated against it. The Policy is designed to deal with proven wrongdoers in the strongest possible terms and deter others from committing offences against the Council. The Prosecution and Recover Policy is shown at Appendix B.

4.3.2 Where theft, fraud or corruption is proved and the Council has suffered a financial loss, then the Council will seek to recover the full value of any loss from the perpetrators. In some cases this may involve civil proceedings being instigated through the courts.

4.4 Disciplinary action

4.4.1 The Council will invoke disciplinary procedures against employees where there is evidence of theft, fraud or irregularity. The procedures are set out in the Code of Conduct and the disciplinary action may result in dismissal from the Council's service. In addition, consideration will be given to referral to the police or the Council instigating criminal proceedings and/or civil recovery, dependent on the circumstances of each case.

4.5 Publicity

4.5.1 The Council will publicise all proven cases of theft, fraud and corruption referred to the criminal courts as a deterrent to others.

4.6 Proactive fraud initiatives

4.6.1 Internal Audit are developing a proactive fraud programme as part of the annual plan to deter and detect fraud. This will cover known areas of high risk and include unannounced visits and spot checks.

4.6.2 The computer audit team also has a role to play in fraud investigation and detection work and will manage the provision of specialist skills in computer forensics and the handling of electronic evidence.

4.6.3 Through Internal Audit, the Council participates in the Audit Commission's, National Fraud Initiative (NFI). Data from some of the Council' main systems is matched with data supplied from other Local Authorities and other external agencies to detect fraudulent activity. All NFI matching is done in compliance with the Data Protection Act.

4.6.4 The Council is a member of, and contributes funding to, the National Anti-Fraud Network. This provides the Council with confidential intelligence relating to possible fraudulent activity. Similarly, on a local level, Internal Audit is a member of the Hampshire Fraud Group, which consists of participating local authorities in Hampshire and aims to develop fraud initiatives across the County.

4.7 Reporting concerns at work

4.7.1 It is the Council's policy that all employees have a duty to report irregularities and bad practice within the Council's operations and services. The Reporting Concerns at Work procedure gives a vehicle by which employees may voice concerns (the SpeakOut procedure should be used within the Social Services department). The Reporting Concerns at Work procedure is shown at Appendix C.

5 Investigations

5.1 Investigations into suspected and alleged acts of theft, fraud or corruption, will be undertaken professionally and sensitively by appropriately trained staff. The Chief Internal Auditor will manage and control all investigations, including when to involve the Police. Investigations staff will be required to comply with the Council's "Investigators Code of Conduct" (to follow as Appendix D).

5.2 Investigations staff will comply with the Council's policies and directives and all other relevant legal requirements. In particular, investigations staff must have regard to:

· the Equal Opportunities Policy

· observance of the Police and Criminal Evidence Act (PACE), where those suspected of committing a criminal act will be advised of their rights and evidence will be obtained, collated and secured in accordance with the Act

· any surveillance that is deemed necessary will be conducted in accordance with the Council's policy on surveillance to comply with the Human Rights Act 1998 and Regulation of Investigatory Powers Act 2000.

5.3 Internal Audit will ensure that its investigators are fully trained in carrying out their responsibilities and that this training is maintained. Wherever possible, investigators will be encouraged to attain suitable, relevant qualifications.

5.4 Paragraph 3.4.4 of this document outlines the responsibilities of management to refer cases of suspected fraud and irregularity to the Chief Internal Auditor. It is essential that contact is made with Internal Audit as soon as any fraud or irregularity is suspected so that the investigation can commence and the risk of inappropriate action is minimised.

5.5 In addition, any significant weakness identified in any system or control should be identified immediately to the Chief Internal Auditor.

5.6 The scope of fraud and irregularity that should be referred to Internal Audit for investigations should not be limited to that which has a direct financial impact, but anything that could have a damaging or undermining effect on the County Council. For example, the unauthorised access and/or release of confidential information held on strategic decisions, commercial information relating to contracts let or being let and personal information on staff and/or customers.

5.7 Where there is evidence that County Council staff are committing fraud, Internal Audit will liaise with Human Resources and the appropriate manager from the department concerned. Where appropriate, disciplinary action will be taken.

5.8 Action must be taken to recover any loss of Council monies from the employee, and/or claim made on insurance funds. Where a criminal act has been committed against the Council, then prosecution will be considered in accordance with the Council's Prosecution Policy.

5.9 Resignations by employees, where there are grounds to dismiss them for dishonesty, will not be accepted.

5.10 Where the Council is victim of fraud by a third party, action will be taken to recover any loss of Council money and prosecution will be considered in accordance with the Council's Prosecution Policy.

5.11 The Council will work jointly with other agencies and local authorities for the prevention and detection of fraud and corruption and will share intelligence with these agencies. These will mainly include:

· Hampshire Constabulary

· Neighbouring local authorities

· Audit Commission

In addition, Internal Audit may liaise with the Department of Social Security and Benefits Agency for the purposes of the prevention and detection of fraud and corruption.

6 Monitoring

6.1 The monitoring of the overall progress of the Council's anti-fraud strategy will be the responsibility of the County Treasurer, as part of the monitoring of the Internal Audit Annual Plan.

6.2 A half yearly report and annual report on significant issues arising from fraud and corruption investigative work will be incorporated within the Internal Audit reports presented to the Governance Committee.

7 Conclusion

7.1 The Council sets and maintains high standards and a culture of honesty, openness and integrity. This strategy fully supports the Council's desire to maintain an authority free from fraud and corruption.

7.2 The Council has in place a network of systems and procedures to assist in dealing with fraud and corruption when it occurs. It is determined that these arrangements will keep pace with any future developments in techniques to both prevent and detect fraudulent or corrupt activity that may affect its operation.

7.3 The Council will maintain a continuous review of all these systems and procedures through Internal Audit.

Appendix A

Anti-fraud and Corruption Policy

Appendix B

Prosecution and Recovery Policy

Appendix C

Reporting concerns at work

Introduction

Hampshire County Council is committed to the highest standards of openness and accountability. It is the County Council's policy that all employees have a duty to report irregularities and bad practice within the Council's operations and services. The Public Interest Disclosure Act 1998 provides special rights for people making disclosures - "whistle-blowers"' - to encourage reporting of malpractice.

Apart from dealing with an issue of good employment practice, this corporate "whistleblowing" policy, known as the Reporting Concerns at Work Policy, fulfils the County Council's legal requirements under the Public Interest Disclosure Act 1998 to provide workers with protection from victimisation and dismissal for making a "qualifying disclosure". The Act encourages workers to raise matters internally with their employer in the first instance. Disclosures will be protected if they meet the legal requirements, which generally require the worker to be acting in good faith.

Employees who believe that there is a serious problem within the County Council may feel reluctant to express their concerns because they feel that speaking up would be disloyal to their colleagues or to the Council. They may also fear harassment or victimisation. This policy document makes it clear that employees have a duty and a right to disclose concerns, in confidence, without fear of subsequent victimisation, discrimination or disadvantage. Any employee should raise serious concerns within the Council rather than ignoring a problem or `blowing the whistle' outside.

This policy applies to all employees (including temporary, part time and casual workers), contractors, trainees, agency workers on assignment within the Council, volunteers, students, secondees, suppliers and those providing services under a contract with the Council. Where the word `staff' is used within this document, it is intended to cover all these people.

The policy is in addition to the County Council's internal complaints procedures and other mechanisms such as the grievance procedure and reporting under the Financial Regulations. It is to be used when other policies and procedures do not apply. SpeakOut already operates as a `whistle-blowing' policy in the Social Services Department and is endorsed by this corporate policy, which has been drawn up to ensure that all the County Council's staff have the same opportunity to have access to a means of disclosure. This policy is also separate from external complaints procedures for use by service users and members of the public.

The standards expected of the County Council's employees are set out in the Code of Conduct and in departmental and local procedures and guidance relating to specific issues. The policy is also consistent with the rights and responsibilities outlined in the Staff Charter.

Aims and Scope

This policy aims to:

· encourage staff to question and act upon concerns about bad practice and to feel confident in raising serious concerns

· provide avenues for staff to raise those concerns

· ensure that staff raising concerns receive feedback on any action taken

· provide guidance to staff on how to take matters further if they are not satisfied

· reassure staff that they will be protected from possible reprisals or victimisation if they have made the disclosure in good faith.

There are existing procedures in place that enable staff to raise a grievance relating to their own employment and the Dignity at Work guidelines outline how to deal with cases of harassment or bullying in the workplace (both these documents can be obtained from departmental personnel officers, or viewed on Hantsnet).

This policy is intended to cover major concerns that fall outside the scope of other procedures, such as those mentioned in the paragraph above (although the SpeakOut procedure should be used within the Social Services Department). Possible issues include:

· conduct which is an offence or a breach of law

· miscarriages of justice

· health and safety risks (to members of the public as well as to staff)

· damage to the environment

· unauthorised use of public funds

· fraud and corruption

· abuse of clients

· abuse or intimidation of staff

· other unethical conduct.

These may be breaches of the Council's Standing Orders or policies, or may be matters that staff are concerned about in relation to established local standards of practice or their own experience.

Where there are complaints procedures in place for addressing problems with service issues, these should continue to be used by service users, other organisations and members of the public.

How concerns can be raised

Most concerns should be resolved simply and effectively at the lowest possible level within a member of staff's section, team or work area. This will normally entail staff raising concerns with their immediate manager or supervisor. However this will depend on the seriousness and sensitivity of the issues involved and who is suspected of malpractice (all concerns relating to financial malpractice should be raised with the Chief Internal Auditor). If it is believed that management is involved, or the issue cannot be resolved at that level, the member of staff should contact one of the following, as appropriate:

· their personnel officer

· a senior departmental manager or chief officer.

However, if this does not resolve the situation the member of staff should contact one of the following:

· in the Social Services Department, the SpeakOut scheme

· the Monitoring Officer (Head of Corporate & Legal Services)

· the Chief Internal Auditor

· the County Personnel and Training Officer

· the Chief Executive.

Disclosures can be made orally or, preferably, in writing. They should include the background and history of the concern, including relevant dates, and the reason why the situation gives particular cause for concern. Although staff are not expected to prove beyond doubt the truth of an allegation, they will need to demonstrate to the person contacted that there are reasonable grounds for concern.

Concerns should be raised as early as possible, as this will make it easier to take action and enable any problems to be resolved quickly. However it is recognised that some bad practices can develop over a long period of time, delaying the opportunity for disclosure, or could be discovered after they have become well-established. There is no definite time limit on raising concerns; whether an issue can viably be dealt with after a long period of time will depend on the circumstances.

Staff may wish to discuss their concern with a colleague first and may find it easier to raise the matter if there are two (or more) people who have had the same experience or concerns. However, staff should also be prepared to give their own individual account during the investigation process.

Staff may be accompanied by a trade union representative or colleague during any meetings or interviews in connection with the concerns they have raised.

How the County Council will respond

The County Council will always respond to concerns raised by staff and there should be an investigation by management. Further courses of action will vary, depending on the issue, but could include:

· using the Council's disciplinary process

· investigation by Corporate & Legal Services, resulting in the use of the disciplinary process if appropriate

· investigation by Internal Audit, again resulting in use of the disciplinary process if appropriate

· referral to the District (External) Auditor

· referral to the police.

When deciding on whether an investigation is appropriate, and what form this should take, the Council will consider public interest as an overriding principle.

Within 10 working days of the concern being raised, the officer receiving the disclosure will write to the member of staff to:

· acknowledge that the concern has been received

· indicate how it is proposed that the matter will be dealt with (ie whether further investigations will take place, and what form these will take)

· indicate whether any initial enquiries have been made

· give an estimate of how long it will take to provide a final response

· supply information on staff support mechanisms.

The amount of contact between the officers considering the issue and the member of staff who raised the issue will depend on the nature of the matters raised, the potential difficulties involved and the clarity of the information provided. If necessary, further information will be sought from the person making the disclosure, ensuring that confidentiality is maintained.

The Council accepts that staff making a disclosure need to be assured that the matter has been properly addressed. Subject to legal constraints, staff who have raised a concern will always be informed of the outcome of the investigation.

Safeguards

The County Council recognises that the decision to report a concern can be a difficult one to make. If the member of staff feels that they have a genuine concern, there should be nothing to fear because he or she will be fulfilling their duty to their employer and to the public for whom the Council provides services.

All concerns will be treated in confidence and every effort will be made to preserve the anonymity of the person making the disclosure where necessary. However, at the appropriate time it may be necessary for the person making the disclosure to come forward as a witness, for example, as part of the internal investigation, disciplinary process or legal proceedings.

The Council will not tolerate any harassment, bullying or victimisation (including informal or subtle pressures) and will take appropriate action to protect staff who raise a concern in good faith. The Council's Dignity at Work policy provides more details in this respect.

Investigations into allegations of potential malpractice will not influence, or be influenced by, any disciplinary or redundancy procedures that a member of staff may already be subject to. However, any allegations of bad practice within the disciplinary process itself will only be dealt with through that procedure, ie a disciplinary appeal.

Wherever possible, staff are encouraged to put their name to an allegation, as concerns expressed anonymously can be less effective and more difficult to investigate properly.

Anonymous disclosures will be considered by the Council, but whether further action is taken will depend on the seriousness of the issues raised and the likelihood of confirming the allegation from attributable sources.

If a member of staff makes an allegation in good faith but it is not confirmed by the subsequent investigation, no action will be taken against them. However if an allegation is made maliciously or for personal gain, disciplinary action may be taken against the individual.

The Council will take steps to minimise any difficulties which a member of staff may experience as a result of raising a concern. For instance, if they are required to give evidence in criminal or disciplinary proceedings the Council will arrange for advice and support to be provided. The Council will also consider practical issues such as travel costs and the implications of spending time away from the workplace.

Support is available at all stages of the above process from the County Council's confidential counselling and support service, esl. Contact details are given at the end of this section.

How the matter can be taken further

If a member of staff raising a concern is dissatisfied with the action taken, and wishes to take the matter outside the Council, the following are examples of appropriate contact points:

"Semi-external" contacts:

· an elected Member of the Council

· the External Auditor (Audit Commission)

· a trade union

· the Local Government Ombudsman.

"Fully external" contacts:

· the Citizens Advice Bureau

· Public Concern at Work (a national charity that gives advice on "blowing the whistle")

· appropriate professional bodies or regulatory organisations

· the police.

Full contact details are given at the end of this section.

If the matter is taken outside the Council, the member of staff should ensure that confidential information is not disclosed, such as personal details about colleagues, or restricted financial information.

Staff raising a concern externally should consider carefully whether this is the most appropriate course of action for resolving the issue and whether all reasonable, possible internal steps have been taken.

Contact details

For general concerns (as appropriate):

· your manager

· your personnel officer

· a senior manager in your department

· the County Personnel and Training Officer

· the Monitoring Officer

· the Chief Executive.

For all financial issues (fraud, corrupt practices and other irregularities):

· the Chief Internal Auditor

· the Audit Consultant;

· the Audit Senior.

For contact details please refer to Hantsnet.

For reporting concerns within the Social Services Department:

For confidential support and counselling:

Employee Support Line (esl), tel: 01962 846388, profs: eslhelp

Alternatively contact the National Charity:

Other external contacts:

Your Personnel Officer will have a complete list of external contacts, a few examples from this list are:

Your trade union.

A Citizens' Advice Bureau.

A relevant voluntary organisation.

The Police (local police stations are listed in the telephone directory).