Anti-Fraud Policy

In this document

1.0 Policy Statement

1.1 Beckfoot Trust expects all staff to adopt the highest standards of propriety and accountability. We are committed to operating fairly, openly, honestly and in accordance with the highest ethical and legal standards. 

1.2 Beckfoot Trust has a “zero tolerance” policy towards fraud, theft, bribery and corruption. This means that our Trust:

• does not accept any level of fraud, theft, bribery or corruption within the organisation; or by any other individual or organisation receiving Trust’s funds; or representing our Trust; and 
• will always seek to take disciplinary and/or legal action against those found to have perpetrated, be involved in, or assisted with fraudulent or other improper activities in any of its operations. 

1.3 Beckfoot Trust is committed to developing an anti-fraud culture and keeping the opportunities for fraud, theft, bribery and corruption to the absolute minimum. 

1.4 Beckfoot Trust requires all staff to always act honestly and with integrity, in accordance with our Trust’s Staff Code of Conduct and the Seven Principles of Public Life and to safeguard the resources for which they are responsible. 

1.5 This policy does not form part of any employee’s contract of employment.

2.0 Scope and Purpose

2.1 The purpose of this policy is to set out our Trust’s stance on fraud, bribery and corruption and approach to preventing, detecting, reporting and investigating fraud, bribery and corruption.

2.2 This policy applies to the whole of our Trust, its schools and central services functions. 

2.2.2 This policy is applicable to, and must be followed by, all staff including employees, consultants and agency staff. Failure to comply could result in disciplinary action, including dismissal. 

2.2.3 This policy is applicable to all Trustees and members of Local School Committees. 

2.2.4 We require all those receiving funds of our Trust or representing our Trust including its suppliers, contractors and agents, to act in accordance with this policy. 

2.2.5 It is the responsibility of all individuals to whom this policy is applicable to familiarise themselves with this policy and comply with its provisions.

2.3 Legal and Regulatory Framework

2.3.1 This policy takes its legal framework from the following legislation and statutory guidance: 

• Fraud Act 2006 
• Bribery Act 2010 
• The Academy Trust Handbook 2024 
• Managing Public Money.

2.3.2 The Trust’s Trustees are required under charity law to safeguard the assets of the Trust.

2.4 Related Trust policies

This policy is related to the following other Trust policies:

• Whistleblowing Policy 
• Finance Policy
• Staff Code of Conduct 
• Multi Card Policy
• Personal Relationships and Conflicts Policy
• Expenses Policy
• Charging and Remissions Policy
• Gifts and Hospitality Policy
• Recruitment and Selection Policy 
• Online Safety and IT Use Policy.

3.0 Overarching Principles

3.1 Terms and Definitions

3.1.1 Fraud means knowingly making an untrue or misleading representation with the intention of making a gain for oneself or another or causing a loss, or risk of loss, to another. 

3.1.2 Theft means dishonestly appropriating property belonging to another with the intention of permanently depriving the other of it. 

3.1.3 Bribery means giving, offering, promising, accepting or soliciting a financial or other advantage to encourage that person to perform their functions or activities improperly, or to do something that is illegal, or to reward someone for having already done so.

3.1.4 Corruption means the misuse of entrusted power for personal gain. This would include dishonest or fraudulent behaviour by those in positions of power, such as managers or government officials. It would include offering, giving and receiving bribes to influence the actions of someone in a position of power or influence, and the diversion of funds for private gain. 

3.1.5 A facilitation payment is a type of bribe, either an unofficial payment or other advantage given to a public official to undertake or speed up the performance of their normal duties. It is not a payment or gift given to obtain or retain business. 

3.1.6 A conflict of interest occurs where an individual has private interests that may or do influence the decisions that they make or contribute to as an employee or other representative of an organisation.

3.1.7 The Seven Principles of Public Life (the “Nolan Principles”) 

Underpinning the Trust’s anti-fraud culture are the Seven Principles of Standards in Public Life. The principles apply equally to trustees, staff, contractors and third parties working on our Trust’s behalf, and are: 

• Selflessness – holders of public office should take decisions solely in terms of the public interest. They should not do so to gain financial or other material benefits for themselves, their families 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 their official duties. 
• Objectivity – in carrying out public business, including making public appointments, awarding contracts, or recommending individuals for rewards or 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 public scrutiny is appropriate to their role. 
• Openness – holders of public office should be as open as possible about all the decisions and actions they take. They should give clear reasons for their decisions and restrict information only when the wider public interest (or legislation) 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.

4.0 Responsibilities and Arrangements

4.1 Roles and responsibilities

4.1.1 The Trustees, as charity trustees, are ultimately accountable for the Trust’s proper management, which includes ensuring appropriate management of the risk of fraud, bribery and corruption. 

4.1.2 The Audit and Risk Committee is responsible for reviewing and approving this policy and for holding the Chief Executive Officer to account for ensuring compliance with this policy. 

4.1.3 The Chief Executive Officer (CEO) is the Accounting Officer and, as such, “must have oversight of the Trust’s financial transactions by ensuring the Trust’s property and assets are under the Trustees’ control and measures exist to prevent losses or misuse”. 

4.1.4 The Chief Finance Officer is the owner of this policy, is responsible for creating the Trust’s anti-fraud, bribery and corruption strategy and is accountable for implementing its approach. They are also responsible for recording all instances of actual or suspected fraud, bribery or corruption and for facilitating training to staff on preventing, detecting and reporting fraud.

4.1.5 The Deputy CEO is responsible for ensuring proportionate and appropriate investigations are conducted, with the support of specialists if considered necessary. 

4.1.6 Headteachers and Central function leaders are responsible for ensuring that their staff are aware of and support this policy, and that all actual or suspected incidents of fraud, bribery or corruption in their school or function are reported in line with this policy, to the Chief Finance Officer. 

4.1.7 Leaders receiving reports of fraud, bribery or corruption are responsible for reporting them to the Chief Finance Officer and assisting in the investigation as required. 

4.1.8 All staff are responsible for complying with this policy. 

4.2 Risk and internal control systems

4.2.1 Beckfoot Trust will seek to assess the nature and extent of its exposure to the risks of internal and external fraud, theft, bribery and corruption. We will regularly review these risks, using information on actual or suspected instances of fraud, theft, bribery and corruption to inform our review. 

4.2.2 We will seek to put in place efficient and effective systems, procedures and internal controls to: encourage an anti-fraud culture; prevent and detect fraud, theft, bribery and corruption; and reduce the risks to an acceptable level. Such controls will include segregation of duties, employee screening checks and authority approval limits. 

4.2.3 Beckfoot Trust will seek to equip its staff with the skills, knowledge and expertise to manage its fraud risk effectively. It will provide adequate training to make staff aware of the risks of fraud, theft, bribery and corruption, and of their responsibilities in preventing, detecting and reporting it. 

4.2.4 Beckfoot Trust will make all those receiving Trust funds or representing our Trust, including its suppliers, contractors and agents aware of this policy. 

4.2.5 We will work in co-operation with relevant stakeholders, including comparable organisations, relevant regulators and government organisations to tackle fraud. 

4.2.6 We will regularly review and evaluate the effectiveness of our systems, procedures and internal controls for managing the risk of fraud, theft, bribery and corruption and will do this through risk management and assurance processes and audit arrangements.

4.3 Reporting of concerns – internal

4.3.1 All staff must immediately report any suspected or actual instances of fraud, theft, bribery or corruption to the Chief Finance Officer or if the concerns relate to the Chief Finance Officer, then the Deputy Chief Executive Officer or Chief Executive Officer. This includes offers to pay bribes, solicitation of bribes and demands to make facilitation payments. Failure to report could result in disciplinary action. Staff who wish to report anonymously can do so using the Whistleblowing Policy.

4.3.1.1 Staff should not attempt to carry out an investigation themselves as this could compromise any subsequent investigation. 

4.3.2 Beckfoot Trust also requires all those receiving Trust funds or representing Beckfoot Trust, including its suppliers, contractors and agents, to report any suspected or actual instances of fraud, bribery or corruption involving Trust assets or staff. Reports should be sent to the Chief Finance Officer. 

4.3.3 Beckfoot Trust will not penalise anyone for raising a concern in good faith, even if it turns out to be unfounded. Any member of staff who harasses or victimises someone for raising a concern in good faith will themselves be subject to disciplinary action. 

4.3.4 We will maintain a system for recording: 

1. all reports of actual or suspected fraud, bribery and corruption; 
2. the action taken; and 
3. the outcome of any investigation. This information will be used to inform the Trust’s review of the risks and effectiveness of its controls.

4.4 Reporting – external

4.4.1 Beckfoot Trust will fully meet its obligations to report fraud, bribery and corruption to third parties. The Accounting Officer will report any instances of fraud, theft and/or irregularity exceeding £5,000 individually, or £5,000 cumulatively in any financial year, to the DfE as soon as possible. Unusual or systematic fraud, regardless of value, will also be reported. When making a report to the DfE, the Accounting Officer will provide the following information:

1. Full details of the event(s) with dates 
2. The financial value of the loss 
3. Measures that have been taken to prevent recurrence 
4. Whether the matter was referred to the Police and, if not, the reasoning behind this 
5. Whether insurance cover or the risk protection arrangement (RPA) have offset any loss. 

4.4.2 Following a report, the DfE may conduct or commission its own investigation into actual or potential fraud, theft or irregularity in the Trust, either as a result of a notification from Beckfoot Trust or from other information the DfE has received. Other authorities, including the Police, may be involved in the investigation. 

4.5 Investigation

4.5.1 Beckfoot Trust will take all reports of actual or suspected fraud, bribery and corruption seriously and investigate proportionately and appropriately, as set out in this policy. 

4.5.2 We will always seek to take disciplinary and/or legal action against those found to have perpetrated or assisted with fraudulent or other improper activities in any of its operations. For staff, this may include dismissal. 

4.5.3 We will seek to recover any assets lost through fraud, unless it is considered to be non-advantageous from a cost of recovery point of view.

4.6 Specific controls to mitigate risks

4.6.1 To minimise Beckfoot Trust’s exposure to risk of bribery and corruption, all gifts and hospitality received by staff and given by our Trust must be approved and recorded on the Gifts and Hospitality Register in accordance with the rules set out in the Gifts and Hospitality Policy. 

4.6.2 Conflicts of interest increase the risk of fraud. There is an annual re-declaration of any interests, or a nil return, for all Trustees and Local School Committee members, the Finance Team, the HR Team, the IT Team, Site Team members, Executive leaders, Central Function leaders and school leaders.

4.6.3 External audit perform annual fraud checks.

4.6.4 An annual internal financial scrutiny programme is in place.

4.7 Reporting and consequences of non-compliance

4.7.1 Non-compliance with this policy by individuals may result in disciplinary action and could lead to removal of an individual from their role. In certain circumstances individuals may also be subject to external sanction, including criminal prosecution. 

4.7.2 Non-compliance with this policy by Beckfoot Trust could result in the DfE issuing a Notice to Improve (NtI) to the Trust if there is deemed to be inadequate financial governance and management. Failure to comply with an NtI could, in exceptional circumstances, also result in the termination of the Trust’s funding agreements.

4.7.3 The Deputy CEO is responsible for reporting any instances of non-compliance to the Audit and Risk Committee.

4.7.4 The CFO’s report to the business committee provides a statement of assurance in respect of fraud during that period.

5.0 Review of Policy

5.1 This policy is formally reviewed every two years.

Please download the PDF above to access the appendices.