Issue - meetings

Fraud Policy

Meeting: 29/03/2023 - Clwyd Pension Fund Committee (Item 50)

50 Anti-Fraud and Corruption Strategy pdf icon PDF 93 KB

To provide Committee Members with the Clwyd Pension Fund Fraud Policy, for approval.

Additional documents:

Decision:

The Committee approved the Anti-Fraud and Corruption Strategy.

Minutes:

            The Chair handed over to Ms Murray of Aon to present this item. She explained that the proposed Pension Fund Fraud Strategy had been developed as part of the Fund’s risk management framework. As the Fund’s Governance Advisers, Aon felt that putting a strategy in place would be best practice from a good governance perspective, and this was also included in the Fund’s Business Plan for 2022/23.

            The purpose of the proposed Strategy was to safeguard the Fund’s data and assets. Page 104 identified the types of fraud addressed by the Strategy, with a wide scope including bribery, collusion, bank account access, anti-money laundering and pension scams. Pages 104-105 highlighted general definitions and relevant regulations and legislation.

            The Strategy would apply to all persons involved in the management of the Fund including Committee Members, Officers, Advisers and the Board, as well as Scheme Employers, Fund Members, and suppliers. The Head of the Fund would be responsible for the requirements of the Strategy being met.

            Ms Murray explained that Flintshire County Council has an existing Anti-Fraud and Corruption Strategy in place, so the principles of the proposed Fund’s Strategy are aligned with the Council’s. These three principles are identified on Page 106, and focus on:

-       Deterrence, including:

o   Publicising counter-fraud measures to raise awareness, for example publishing this policy on the website,

o   Reporting fraudulent activity to the Committee and Board as part of business as usual;

-       Prevention, by having internal controls in place including:

o   Participation in the National Fraud Initiative,

o   Regular review of tier-3 ill-health pensions,

o   Appropriate authorisation and verification procedures for changes to data affecting member benefits, and additional security for bank account details,

o   Verification process for verbal telephone requests,

o   Adoption of TPR guidance for pension scams,

-       Detection of fraud and corruption including:

o   The Fund will always seek to recover lost funds in line with Council policy including involvement of internal audit,

o   Regular bank reconciliation.

 

            Ms Murray also noted that pension scams were becoming a bigger threat. Part of the proposed Strategy aimed to protect members from this threat by encouraging them to protect their own personal information.

RESOLVED:

The Committee approved the Anti-Fraud and Corruption Strategy.