Anti-Fraud and Corruption Policy

1. Statement of Policy

Dyfed-Powys Police and the OPCC is committed to operating a framework for the prevention and detection of fraud, bribery and corruption within the workplace.

It is acknowledged that fraud, theft and corruption may be perpetrated by those inside the force and the OPCC as well as those external to the organisation. The prevention of fraud and corruption is an essential element in maintaining the reputation of the force and the OPCC.

Fraud and corruption are serious matters that warrant robust investigations and outcomes. Those found guilty of committing fraud and corruption can expect to face potential criminal prosecution and / or dismissal.

A person does not have to benefit from the fraud to be guilty of an offence – as soon as they make a dishonest / false representation, they have committed fraud; where someone has made a genuine mistake there is no fraud.

This policy and the accompanying protocol is intended to assist all staff and volunteers to recognise when fraudulent activities may be taking place and to educate staff and volunteers to understand when suspected fraud should be reported and how this should be done. This policy also guides officers, staff and volunteers on the Sponsorship and Donations process. A separate Sponsorship and Donations Procedure document is available for guidance on the force intranet.

Early identification of fraudulent activity will enable early intervention and escalation through the appropriate channels for an effective investigation to take place where necessary.

Compliance with this policy and associated protocol will foster a continuing culture of accountability and ensure that all officers, staff and volunteers maintain the required level of Honesty and Integrity.

Applies (but not limited) to: All categories of Dyfed-Powys Police officers and staff, whether full-time, part-time, permanent, fixed term, temporary (including agency staff, associates and contractors), seconded staff and volunteers. Police Officers, staff and volunteers accessing and using Force assets and property must have due regard to the contents of this policy.

 

2. Policy Scope

This policy and accompanying Anti-Fraud and Corruption protocol should be used in order to empower all staff and volunteers to acknowledge and understand fraud risks. All staff and volunteers should familiarise themselves with the content of this policy and protocol so that they are equipped in aiding in the prevention and detection of fraudulent behaviours. All staff and volunteers should familiarise themselves with their responsibilities to challenge and report suspected fraudulent behaviour.

This policy is designed to ensure that Dyfed-Powys Police and the OPCC ensure compliance in promoting the reporting requirements of suspected fraudulent activity. It is incumbent upon all staff to discharge expectations of propriety and accountability and to lead by example in ensuring adherence to legal requirements, rules, procedures, and practices.

This policy should be read in conjunction with the Corporate Governance Framework.

It is important for all staff and volunteers to be able to recognise fraudulent activity and to have both knowledge of and confidence in the options available to them to deal effectively with the issues. The separate protocol provides clear direction in this regard.

A lack of awareness of this policy and protocol could result in instances of Fraud and corruption going undetected and / or unreported.

A lack of governance in this area will likely lead to an erosion of public trust and confidence in the police service.

 

3.  Powers and Policy/Legal Requirements

Fraud and corruption can take many forms. In relation to this policy, the following definitions and legislation are relevant; although it is important to state that this list is not exhaustive:

The term ‘Fraud’ can be used to describe such acts as criminal deception, forgery, blackmail, corruption, conspiracy and concealment of material facts and collusion. For practical purpose fraud can be defined as the use of deception with the intention of obtaining an advantage, avoiding an obligation or causing loss to another party.

Corruption is an act done with intent to give some advantage which is inconsistent with official duty and rights of others. This includes bribery but also covers bias (e.g. in selection or award). The wider interpretation of force corruption is dealt with under Police Regulations, Staff Codes of Conduct and Criminal Law.

Theft is typically defined as the taking of almost anything of value without the consent of the owner, with the intent to permanently deprive him or her of the property taken.

The Fraud Act 2006

The UK Fraud Act states that a person is guilty of Fraud if they:

• Dishonestly make a false representation, and intend, by making the representation to make a gain for themselves or another, or cause loss to another or to expose another to a risk of loss.
• Dishonestly fail to disclose to another person information which they are under a legal duty to disclose, and intend, by failing to disclose the information to make a gain for themselves or another, or to cause loss to another or to expose another to risk or loss.
• Occupy a position in which they are expected to safeguard, or not to act against the financial interests of another person, dishonestly abuse that position, and intend, by means of the abuse of the position to make gain for themselves or another, or to cause loss to another or to expose another to risk or loss.

The UK Bribery Act 2010

This Act defines two types of bribery:

• Offences of bribing another person – where a person offers, promises or gives a financial or other advantage to another person and, intends the advantage to induce a person to perform improperly a relevant function or activity, or to reward a person for the improper performance of such a function or activity. Or where a person offers, promises or gives a financial or other advantage to another person, and knows or believes that the acceptance of the advantage would itself constitute the improper performance of a relevant function or activity.
• Offences relating to being bribed – where a person requests, agrees to receive or accepts a financial or other advantage intending that, in consequences, a relevant function or activity should be performed improperly. Or where a person requests, agrees to receive or accepts a financial or other advantage, and the request, agreement or acceptance itself constitutes the improper performance by a person of a relevant function or activity.

The Police Act 1996 Section 93 (1) provides that:

‘A Police and Crime Commissioner (PCC) or Chief Constable (CC) may, in connection with the discharge of any of its functions, accept gifts of money and gifts or loans of other property provided the terms of their donations appear to be appropriate.

The terms on which gifts or loans are accepted under subsection (1) may include terms for the commercial sponsorship of any activity of the PCC or of the functions of the Chief Constable maintained by it.’

The Home Office Financial Management Code of Practice for the Police Forces of England and Wales (‘The Code’) provide that:

‘A PCC may decide to accept gifts of money, gifts or loans of other property if they will enable the police either to enhance or extend the service which they would normally be expected to provide. The terms on which gifts, loans and sponsorship are accepted may allow commercial sponsorship of some police force activities.

Donations and sponsorship can be accepted from any source which has genuine and well-intentioned reasons for wishing to support specific projects. In return, the provider may expect some publicity or other acknowledgement. It is acceptable to allow the provider to display the organisations name or logo on publicity material, provided this does not dominate or, detract from the purpose of the supported project.’

The College of Policing (CoP) offers an online service that provides access to a consolidated body of guidance for policing called APP (authorised professional practice) | College of Policing

The Code of Ethics underpins every policy, procedure, decision and action in policing today and all staff are reminded of the need to comply with the Standards of Professional Behaviour and principles of the Code of Ethics.

The Joint Corporate Governance Framework (CGF) sets out the principles, structures and processes by which the Office of the Police and Crime Commissioner (OPCC) and Dyfed-Powys Police (DPP) will be governed, both jointly and separately. The CGF outlines the Force and OPCC approach to the prevention of fraud and corruption.

The Joint Audit Committee (JAC) is responsible for conducting, at least annually, an independent review of the effectiveness of governance arrangements, risk management and control frameworks, including financial reporting, annual governance processes and internal and external audit findings.

This policy is compliant with the NPCC Counter-Corruption Strategy 2021-22 and is under-pinned by the NCA 2022 Strategic Intelligence assessment.

The Independent Office for Police Conduct (IOPC) require referrals of Theft / Fraud / Corruption to be referred under the mandatory referral criteria. The IOPC determine if an investigation is required and if so who should investigate. This process does therefore provide further governance and oversight.

Donations and Sponsorship

Public confidence in the police is crucial. Dyfed-Powys Police will ensure complete openness and transparency and will not accept any donations or sponsorship that will impact on its integrity or ethics or which could be misconstrued as potential preferential treatment by competitors.

Donations or offers of sponsorship must not compromise or impose or imply conditions that will limit or appear to limit the forces ability to carry out its functions fully and impartially.

Definitions

Donation

A donation is the act or action of transferring ownership of cash or other tangible asset as a free gift. It can also be extended to include services (i.e. free performance of an act or acts) but must not be regarded as a contract or sponsorship or have any commercial intent, obligation or reciprocal commitment.

Sponsorship

For the purpose of this policy, ‘sponsorship’ is defined as ‘the voluntary provision to the police service of non-public funds, services, equipment or other resources.’

Governance

When a donation or offer of sponsorship is received, the respective Force BCU Commander, Head of Department or Chief Finance Officer for the Chief Constable is responsible for deciding if it is acceptable in consultation with Corporate Finance, Procurement and the Professional Standards Department.

The Professional Standards Department will hold and maintain a register of all donations and sponsorship received by Dyfed-Powys Police.

Delegated Budget Holders are able to accept sponsorship and donations of up to £1,000 on behalf of the Chief Constable in line with the Scheme of Delegation.

The Chief Constable can accept sponsorship and donations of up to £50,000.

The Chief Finance Officer for the PCC may accept a donation or sponsorship up to the value of £50,000 on behalf of the PCC for Dyfed-Powys Police.

Where the actual or assessed value of a donation or sponsorship exceeds £50,000, the decision to accept must be referred to the PCC for ratification.

The total value that can be accepted in any one financial year, when considered together with the value of donations or sponsorship, shall not be allowed to exceed a maximum equivalent of 1% (one percent) of the total police fund budget annually.

Full details on how the Donations and Sponsorship process should be carried out can be found with the Donations and Sponsorship Procedure.

 

4. Options and Contingencies

Approval Process: Approval decisions regarding the implementation of this policy will be made by the Head of the Professional Standards Department in conjunction with the Director of Finance and the Chief Finance Officer with oversight from the Joint Audit Committee.

 

The ACU Anti-Corruption Strategy: the strategy identifies the procedures and processes for DPP’s response to corruption. It establishes an ambitious and long-term framework for tackling corruption in support of the NPCC Counter-Corruption Strategy 2017-22 and is under-pinned by the NCA 2019 Strategic Intelligence Assessment. It identifies counter corruption priorities that will be the focus of the ACUs effort.

To ensure understanding of the processes contained within the Anti-Corruption Strategy, Police personnel (including volunteers), affected by the policy are provided with training and regular reminders are given.

Significant failures within the procedures contained within the Force’s Anti-Corruption Strategy would be referred for consideration to the Force ‘Learning the Lessons Committee’.

Each of the Code of Ethics ethical policing principles are relevant to this policy, specifically:

Courage

• Taking responsibility
• Challenging unprofessional behaviour and practice
• Being honest, open and accountable

We will report, challenge or take action against the conduct of colleagues which has fallen below the standards of professional behaviour.

Challenging and / or reporting will be done in line with the highlighted options available within the accompanying protocol.

We will apply this policy and protocol in line with the need to preserve the honesty and integrity of the individual and the organisation as whole and in order to ensure that public confidence is maintained.

We will be answerable for the decisions, actions and omissions made in relation to the application of the processes and procedures contained within the Anti-Corruption Unit Strategy.

Respect and Empathy

• Acting with respect
• listening to and understanding different perspectives
• being fair and impartial

We will treat everyone with respect.

The application of this policy and accompanying protocol will be based upon evidence and best professional judgement. For example, it may not always be necessary to report conduct that managers and supervisors are able to ascertain at an early stage is an honest mistake, in contrast to conduct that is dishonest and may amount to an offence of fraud. Due regard will be given to individual circumstances and consideration should be given to a reporting person’s status as a ‘Whistleblower’ where necessary.

Public Service

• delivering a service to be proud of
• acting lawfully
• reflecting on and applying knowledge and experience
• improving our self, our peers and our profession

We will act selflessly and in the public interest. We will be open and transparent in our actions and decisions and will treat corruption related intelligence and information with respect and access or disclose it only in the proper course of our work.

 

5.  Take action and review

Dyfed-Powys Police Professional Standards department and the OPCC will monitor the application of this policy and will exercise discretion to review it at any time through the appropriate consultation mechanisms and considering any developments in legislative changes and best practice.

The Head of the Professional Standards Department and the OPCC who will be responsible for regularly monitoring the policy for:

• Its effectiveness;
• Any changes to relevant guidance;
• Challenges to the Policy; and
• Any identified inefficiencies in relation to implementation

Any amendments to this policy and the accompanying protocol will be implemented through the Joint Audit Committee in conjunction with the Director of Finance and the OPCC Chief Finance Officer.  

Consultation with and feedback from the Joint Audit Committee with governance as detailed within the Corporate Governance Framework will form an ongoing part of the monitoring and review of this policy and protocol.

Reviews of the effectiveness of this policy and protocol will include regular reporting to the Joint Audit Committee and to our external auditors. Professional Standards department staff will continue to monitor and review reports made and reporting methods used in relation to all suspected fraudulent activity. Monitoring and review will include the identification of missed opportunities and learning opportunities that may lead to a change of processes in order to prevent repeated conduct.

 

CODE OF ETHICS CERTIFICATE OF COMPLIANCE

This policy has been drafted in accordance with the Code of Ethics and has been reviewed on the basis of its content and the supporting evidence and it is deemed compliant with that Code and the principles underpinning it.

HUMAN RIGHTS ACT CERTIFICATE OF COMPLIANCE

This policy has been drafted in accordance with the Human Rights Act and has been reviewed on the basis of its content and the supporting evidence and it is deemed compliant with that Act and the principles underpinning it.

EQUALITY IMPACT ASSESSMENT

Section 4 of the Equality Act 2010 sets out the protected characteristics that qualify for protection under the Act as follows: Age; Disability; Gender Reassignment; Marriage and Civil Partnership; Pregnancy and Maternity; Race; Religion or Belief; Sex; Sexual Orientation.

The public sector equality duty places a proactive legal requirement on public bodies to have regard, in the exercise of their functions, to the need to:

• eliminate discrimination, harassment, victimisation, and any other conduct that is unlawful under the Act;
• advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;
• foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

The equality duty applies to all protected characteristics with the exception of Marriage and Civil Partnership, to which only the duty to have regard to the need to eliminate discrimination applies.

Carrying out an equality impact assessment involves systematically assessing the likely or actual effects of policies on people in respect of all the protected characteristics set out above. An equality impact assessment should be carried out on any policy that is relevant to the public sector equality duty. 

EQUALITY IMPACT ASSESSMENT COMPLETED: June 2025