Reporting Fraud to the Programme
If for any reason you have suspicions of fraudulent activity relating to the programme, you are strongly encouraged to report them as soon as possible. All reports to staff will be treated confidentially, in line with relevant legislation on whistleblowing.
If you wish to make a report to a confidential mailbox, please send your concerns to;
France (Channel) England Programme Policy on Fraud
The Managing Authority (MA) for the INTERREG VA France (Channel) England Programme is committed to maintain high legal, ethical and moral standards, to adhere to the principles of integrity, objectivity and honesty and wishes to be visibly opposed to fraud and corruption in the way that it conducts its business. All members of staff are expected to share this commitment. The objective of this policy is to promote a culture which deters fraudulent activity and to facilitate the prevention and detection of fraud and the development of procedures which will aid in the investigation of fraud and related offences and which will ensure that such cases are dealt with timely and appropriately.
A procedure is in place for the disclosure of situations of conflict of interests.
The term fraud is commonly used to describe a wide range of misconducts including theft, corruption, embezzlement, bribery, forgery, misrepresentation, collusion, money laundering and concealment of material facts. It often involves the use of deception to make a personal gain for oneself, a connected person or a third party, or a loss for another – intention is the key element that distinguishes fraud from irregularity. Fraud does not just have a potential financial impact, but it can cause damage to the reputation of an organisation responsible for managing funds effectively and efficiently. This is of particular importance for a public organisation responsible for the management of EU funds. Corruption is the abuse of power for private gain. Conflict of interests exists where the impartial and objective exercise of the official functions of a person are compromised for reasons involving family, emotional life, political or national affinity, economic interest or any other shared interest with e.g. an applicant for or a recipient of EU funds.
Within the MA, overall responsibility for managing the risk of fraud and corruption has been delegated to Vince Muspratt, Assistant Director – Growth and Development, who has the responsibility for:
- Undertaking a regular review, with the help of a risk assessment team, of the fraud risk;
- Establishing an effective anti-fraud policy and fraud response plan;
- Ensuring fraud awareness of staff and training;
- Ensuring that the MA refers promptly investigations to competent investigation bodies when they occur;
- Process owners/managers of the MA are responsible for the day-to-day management of fraud risks and action plans, as set out in the fraud risk assessment and particularly for
- Ensuring that an adequate system of internal control exists within their area of responsibility; o Preventing and detecting fraud;
- Ensuring due diligence and implementing precautionary actions in case of suspicion of fraud
- Taking corrective measures, including any administrative penalties, as relevant.
- The Certifying Authorities have a system which records and stores reliable information on each operation; they receive adequate information from the MA on the procedures and verifications carried out in relation to expenditure
- The Audit Authority has a responsibility to act in accordance within professional standards in assessing the risk of fraud and the adequacy of the control framework in place.
The MA has procedures in place for reporting fraud, both internally and to the European Anti-Fraud Office Reporting to the European Anti-Fraud Office will be done in collaboration with the Programmes National Authorities, the Ministry of Housing, Communites and Local Government (MHCLG) in the UK and the Prefecture de Normandie, Secrétariat Général pour les Affaires Régionales (SGAR) in France.
All reports will be dealt with in the strictest of confidence and in accordance with EU Data Protection Directive 2016/680 (Law Enforcement Directive). The Directive complements the General Data Protection Regulation (GDPR) 2018 in the UK and La loi sur les protection des données personnelles 23 June 2018. Also, the Loi Sapin 2 du 9 Décembre 2016 in France and the Public Interest Disclosure Act 1998 in the UK, (whichever is applicable to the report). Staff reporting irregularities or suspected frauds are protected from reprisals.
The MA has put in place proportionate anti-fraud measures based on a thorough fraud risk assessment. In particular, it uses IT tools to detect risky operations (such as ARACHNE) and ensures that staff is aware of fraud risks and receives anti-fraud training. The MA carries out a vigorous and prompt review into all cases of suspected and actual fraud which have occurred with a view to improve the internal management and control system where necessary.
Fraud can manifest itself in many different ways. The MA has a zero tolerance policy to fraud and corruption, and has in place a robust control system that is designed to prevent and detect, as far as is practicable, acts of fraud and correct their impact, should they occur.
This policy and all relevant procedures and strategies are supported by the Interreg VA France (Channel) England Programme Board at Norfolk County Council, who will proactively review and update them on a continual basis.