Anti bribery & corruption policy
WHY IT MATTERS TO RHEA
Rhea does all it can to act with integrity in all its business dealings and commercial relationships. We are committed to the highest standards of ethics and honesty, and we operate a zero -tolerance approach to bribery and corruption. The giving or receiving of bribes, and any other form of corrupt payment, in any course of conduct involving Rhea, is unacceptable.
BACKGROUND
At Rhea, giving or receiving bribes is never acceptable and we take a zero -tolerance approach to those involved in bribery and corrupt practices. We are committed to complying with all applicable legislation relating to bribery, corruption and financial crime and we expect everyone who works for us to adopt the same approach. If you engage in bribery, you will lose your job at Rhea, could be convicted of a criminal offence, and fined or imprisoned.
UK bribery laws apply to all matters related to bribery and corruption and Rhea can be liable for the actions of employees and service providers; wherever they are located. If such persons engage in bribery, they could cause Rhea to incur unlimited fines. This policy sets out our minimum expectations for complying with UK bribery laws and is in place to keep you safe at work.
YOUR RESPONSIBILITIES - KEY RULES
1. What is bribery?
Bribery means offering, promising, giving, accepting or requesting anything of value to inappropriately influence a decision or action. Examples of something of value include cash, services, offers of employment, charitable donations, political contributions, travel and / or entertainment expenses, meals and gifts. Bribery is also a risk outside of work and can happen when family members are influenced, for example, if a supplier sends extravagant gifts to your family at the same time the supplier is tendering or pricing for business with Rhea. If this occurs, report it!
2. Public officials
Under the UK bribery laws, bribery of public officials (e.g. government officials) is a specific crime, and the rules are very strict. Colleagues and those acting on our behalf must be particularly careful when dealing with public officials. These would include Management within Local Authorities through to Chief Executives. Councillors or community leaders. Any activity that constitutes an attempt to bribe a public official, or which may give that impression, is prohibited at Rhea. Equally any attempt by any public official to bribe a member of Rhea to give favour for a service or contractor can be viewed in the same manner.
3. Third parties and associated persons
An associated person is a third party that performs services for or on behalf of Rhea. The definition of an associated person is broad and could include joint venture partners, subsidiaries and agents of Rhea along with contractors, consultants. Rhea may be liable if an associated person commits an act of bribery on behalf of Rhea, even if Rhea was not aware that the associated party has paid the bribe.
4. Facilitation payments
Facilitation payments (‘back -hander’ or ‘grease payments’) are small bribes that are paid to low level officials to speed up an administrative process such as the issuing of a permit or licence or permission by a local authority. Such payments are prohibited under this Rhea policy, irrespective of where they are given. Rhea's books are open for scrutiny by the Local Authority therefore any such payments are transparent and against the intent of this policy.
5. Political and charitable contributions
Although we work with local governments and other parties on issues that promote the well -being of our customers and communities, as a business we have no political affiliations and we do not make political donations.
6. Gifts, hospitality and entertainment In certain situations,
Gifts, hospitality and entertainment can be an appropriate and effective way to build and maintain business relationships. However, you must never give or receive gifts with the aim of influencing a business outcome. This may constitute a bribe, cause a conflict of interest or damage the reputation of Rhea. Any invitations for hospitality or entertainment, whether given or received, should be proportionate and not excessive in value. If in doubt, you should consider if it would cause you, or the company, any embarrassment if the invitations were to be published in the press. All employees must obtain line manager approval and record any gifts, hospitality and entertainment over £50 using the Submission Form. In the unlikely event that the value of hospitality and entertainment exceeds £500 per person, you must also obtain prior approval from the relevant Director. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
COMPLIANCE
It is important that you comply with this policy and related guidance. A breach of UK bribery laws can result in a formal investigation by the Serious Fraud Office who have the power to impose unlimited fines and / or 10 years imprisonment. Failure to comply with this policy may result in disciplinary action being taken against any colleagues concerned.
REPORTING AND QUERIES
It is important that any colleague who suspects a breach of any Rhea anti -bribery or corruption policy speaks up straight away. Breaches, whether confirmed or suspected, raised internally or by suppliers, must be reported as soon as possible to your line manager. If you feel unable to raise the issue with your line manager, then report directly to the Director
Anti-fraud bribery and corruption statement and strategy
Foreword
The estimated cost of fraud to the UK is in 2026 massive, with the total economic and social cost ranging from £14.4 billion to well over £190 billion annually, depending on what is measured and which sector is targeted.
By Economic Sector
Private Sector: Estimated losses range between £157 billion and £158 billion.
Public Sector: The National Audit Office (NAO) estimates fraud and error cost the taxpayer between £55 billion and £81 billion.
Individuals & Charities: Scams and frauds committed directly against individuals cost around £8 billion to £11.4 billion, with an additional £1.3 billion lost in the charity sector.
Rhea operates in a Local Authority environment therefore the way fraud is tackled needs to align with Local Authority priorities. The impact of fraud should never be underestimated. Fraud leaves councils and businesses with less to spend on services for residents and costs taxpayers' money. Fraud against a local council is not a victimless crime. The "tone from the top" is crucial in this respect and members, senior leaders and the Corporate Governance and Audit Committee (CGAC) are all committed to this in terms of their ethics, values, behaviours and compliance with policies and procedures.
Rhea can have confidence that we operate in a fair and honest way. It is essential that we each remain vigilant to the risk of fraud and corruption so that fraudsters are not able to take away valuable resources from the delivery of public funding or stop us being able to provide additional support to our most vulnerable residents.
Anti-Fraud, Bribery and Corruption Policy Statement
Rhea is committed to adopting a zero-tolerance approach to fraud and corruption from both internal and external sources.
It is committed to acting professionally, fairly and with integrity and to implementing and enforcing effective systems to counter fraud, bribery and corruption.
Rhea will promote an environment that actively encourages the highest principles of honesty and integrity.
The overall objective is to limit Rhea's exposure to fraud and corruption, and to minimise financial loss and the potential adverse effects on its reputation in the event of this occurrence by:
Creating a counter fraud culture;
Understanding the fraud risks facing Rhea;
Implementing measures to deter, prevent and detect fraud;
Promptly and professionally investigating alleged or detected fraud; and
Imposing appropriate sanctions and redress where fraud or corruption is proven.
All employees of Rhea should ensure the highest standards of stewardship of funds including public funds.
The detection, prevention and reporting of fraud, bribery and corruption is the responsibility of all employees (including casuals, temporary and agency staff), partners, and contractors of Rhea.
Rhea aims to combat fraud and corruption by encouraging prevention whilst also promoting detection.
It is important to note that fraud may be committed both from within Rhea and externally. Fraud may be complex or simple; opportunistic, pre-planned or continuous. Unlike fraud, bribery and corruption usually require the involvement of an employee.
Anti-Fraud, Bribery and Corruption Strategy
1 - Introduction and Approach to Countering Fraud
1.1 - Rhea is committed to promoting a strong ethical and counter-fraud culture. This anti-fraud and corruption strategy is the mechanism for achieving this commitment and, in particular, aims to reduce losses to fraud and corruption in all areas of Rhea to an absolute minimum.
1.2 - Rhea has a wide range of policies and procedures which aim to prevent fraud, bribery and corruption, and these include:
Codes of Conduct for Employees
Disciplinary Policy
Whistleblowing Policy
Anti-Money Laundering Policy
1.3 - This strategy adheres to the CIPFA Code of Practice - Managing the Risk of Fraud and Corruption (2014) and as we are working for Local Authorities, the four key themes of the Local Government Fraud Strategy - Fighting Fraud and Corruption Locally (2020).
CIPFA - MANAGING THE RISK OF FRAUD AND CORRUPTION
FIGHTING FRAUD AND CORRUPTION LOCALLY
Acknowledge the responsibility of the governing body for countering fraud and corruption
Govern - Having robust arrangements and support to ensure anti-fraud, bribery and corruption measures are embedded throughout Rhea.
Having a holistic approach to tackling fraud is part of good management.
Identify the fraud and corruption risks
Acknowledge - acknowledging and understanding fraud risks and committing support and resources to tackling fraud to maintain a robust anti-fraud response.
Develop an appropriate counter-fraud and corruption strategy
Prevent - Preventing and detecting more fraud by making better use of information and technology, enhancing fraud controls and processes and developing a more effective anti-fraud culture.
Provide resources to implement the strategy
Take action in response to fraud and corruption
Pursue - punishing fraudsters and recovering losses by prioritising the use of civil sanctions, developing capability and capacity to investigate fraudsters and developing a more collaborative and supportive local enforcement response.
2 - Definitions of Fraud, Bribery and Corruption
2.1 - The Chartered Institute of Public Finance and Accountancy (CIPFA) defines fraud as:
"The intentional distortion of financial statements or other records by persons internal or external to the organisation which is carried out to conceal the misappropriation of assets or otherwise for gain."
Put simply, fraud is an act of deception intended for personal gain or to cause a loss to another party.
The Fraud Act 2006 defines fraud in three classes:
False representation
Failure to disclose information where there is a legal duty to do so
Abuse of position
2.2 - CIPFA defines corruption as the:
"The offering, giving, soliciting or acceptance of an inducement or reward, which may influence the action of any person".
2.3 - The Theft Act 1968 defines theft as:
"A person shall be guilty of theft if he dishonestly appropriates property belonging to another with the intention of permanently depriving the other of it."
2.4 - CIPFA defines bribery as:
"An inducement or reward offered, promised or provided to gain personal, commercial, regulatory or contractual advantage".
The Bribery Act 2010 contains the following four categories of offence, and whilst it was updated in May 2013, these categories of offence remained unchanged:
offering, promising or giving a bribe to another person;
requesting, agreeing to receive or accepting a bribe from another person;
bribing a foreign public official; and
a corporate offence of failing to prevent bribery.
3 - Scope
3.1 - Rhea aims to foster honesty and integrity, and to uphold the Seven Principles of Public Life developed by the Nolan Committee on Standards in Public Life.
High ethical standards are an integral part of good management. In promoting good management, Rhea aims to create a counter-fraud culture to help deter people from committing fraud and to encourage those who suspect fraudulent activity to report it.
3.2 - The Policy Statement / Strategy applies to all staff (full-time, part-time, temporary, casual and volunteers) who work for Rhea.
3.3 - Rhea also expects that individuals and organisations (e.g. partners, suppliers, contractors, service providers and voluntary organisations) that it deals with will act with integrity and without thought or actions involving fraud, bribery and corruption.
Where relevant, Rhea will include appropriate clauses in its contracts regarding the consequences of fraud, bribery and corruption, and evidence of such acts is likely to lead to termination of the particular agreement and may lead to prosecution.
3.4 - The Anti-Fraud, Bribery and Corruption Policy Statement and Strategy are commended to Rhea's partner organisations with the expectation that they will be applied either wholly or as the basis for their own local version.
4 - Creating and maintaining a strong culture
4.1 - Responsibility for an anti-fraud culture is the joint duty of all those involved in giving political direction, determining policy and management. The strategy should be directed against fraud and corruption, whether it is attempted against Rhea from outside or from within its own workforce.
4.2 – Rhea expects staff at all levels will lead by example in ensuring adherence to legal requirements, Contract Procedure Rules, Financial Procedure Rules, Codes of Conduct and best (professional) practice.
4.3 - As part of this culture, Rhea will provide clear routes by which concerns can be raised by staff, and those outside who are providing, using or paying for services.
4.4 - Senior Management is expected to deal swiftly and firmly with those who defraud Rhea or who are corrupt.
5 - Deterrence
5.1 - Rhea can deter potential fraudsters from committing or attempting fraudulent or corrupt acts, both internal and external, through a range of measures, including:
Publicising the fact that Rhea is firmly set against fraud and corruption and states this at every appropriate opportunity - e.g., publicising the Whistleblowing arrangements, clauses in contracts, statements on benefits claim forms and publications, etc.
Acting robustly and decisively when fraud and corruption are suspected and proven - e.g., the termination of contracts, dismissal and prosecution, etc.
Taking action to affect the maximum recoveries for Rhea - e.g. through agreement, Court action, penalties and insurance, etc.
Rhea will optimise the publicity opportunities associated with anti-fraud and corruption activity within the authority. Where appropriate, the results of any action taken, including prosecutions, will be reported in the media.
Having sound internal control systems that still allow for innovation, but at the same time do not provide the opportunity for fraud and corruption.
A fraud reporting mechanism on the website.
6 - Prevention / Managing the Risk of Fraud and Corruption
6.1 - An offence of Failure to Prevent Fraud has recently been established through the Economic Crime and Corporate Transparency Act 2023, which came into force on 1 September 2025.
This offence applies to large organisations, but Rhea endeavours to adhere to the principles.
The offence created means that an organisation can be held accountable for fraud committed by employees, or an associated person, which may benefit the organisation, or, in certain circumstances, their clients.
As such, it is essential to maintain an anti-fraud culture.
6.2 - The following internal measures are in place to assist with the prevention of fraud:
The managers have a duty to report to the Director where it appears that any proposal, decision or omission by Rhea is likely to give rise to a breach of legislation
Senior managers ensure that internal controls, including those in a computerised environment, are adequately designed and effectively operated.
The Director reviews the adequacy of the internal controls, including those to prevent fraud.
Managers within Rhea have an important role to play in the prevention of fraud and corruption. Managers need to understand the importance of soundly designed systems which meet key control objectives and minimise the opportunities for fraud and corruption. They are responsible for assessing the potential for fraud and corruption within their own Service's activities and for implementing appropriate strategies to reduce this risk.
7 - Combining with Others to Prevent and Fight Fraud
7.1 - Rhea is committed to exchanging information with other local and national agencies to identify and prevent fraud using data matching techniques.
Such activity is carried out in full compliance with the General Data Protection Regulation and the Code of Practice for National Fraud Initiative Data Matching Exercises and includes providing information to other agencies for data matching purposes.
Any employee found to be perpetrating fraud on another local or national agency is liable to face disciplinary action where this has implications for Rhea's trust and confidence in the employee.
In certain cases, disciplinary action may result in dismissal.
7.2 - With the increase in recent years of frauds perpetrated against a variety of public bodies, which usually involve fraudsters having multiple identities and addresses, the necessity for liaison with other organisations has become paramount related to scheme eligibility.
Some of these include:
Police Forces and Fraud Squads
Other Local Authorities
External Auditor
Universities and Colleges
Department for Work and Pensions
National Anti-Fraud Network.
8 - Detection and Reporting Concerns
8.1 - It is the responsibility of the Director and managers to prevent and detect fraud and corruption.
8.2 - However, despite the best efforts of managers, many frauds are discovered by chance or "tip-off". It is often the alertness of employees and the public that enables detection to occur.
8.3 - Reporting suspected irregularities is essential to the Anti-Fraud, Bribery and Corruption Strategy and ensures:
Consistent treatment of information regarding fraud and corruption;
Proper investigation by an independent and experienced audit team;
The proper implementation of a fraud response investigation plan;
The optimum protection of the Council's interests.
8.4 - The Fraud Response Plan provides a clear path for raising concerns and facilitating "tip-offs", and the fraud response arrangements to enable such information or allegations to be properly dealt with.
Rhea's Whistleblowing Policy also gives advice on how to raise a concern and the safeguards and support that are available to those who raise concerns.
8.5 Red flags that may assist in identifying fraud
Unwillingness to share duties.
Refusal to take leave.
Refusal to implement internal controls (for example, skipping approvals).
Replacing existing suppliers with suppliers that have an unusually close connection.
Living a lifestyle above apparent means.
Lavishing gifts on colleagues.
Failure to keep records or receipts.
Bullying colleagues (especially if the colleagues question the person’s activities).
Seeking access to areas which the person should not be able to access.
Chronic shortage of cash - consistently seeking loans or advances.
Past legal/compliance problems.
Addiction problems (for example, gambling or drugs).
Under financial stress.
Significant personal stress (for example, divorce, business failing).
Disgruntled with Rhea as an employer.
Strong sense of entitlement.
Red flags in contracting/accounting
Financial information reporting is inconsistent with KPIs.
Abnormally high costs in a specific cost centre function.
Dubious record keeping.
High overheads.
Bank reconciliations not up to date.
Inadequate segregation of duties.
Reconciliations not performed on a regular basis.
Payments continuously just below reporting thresholds.
Duplicate invoices.
Sequential numbers on invoices.
Pricing does not adjust with changes in the value of goods or services in the market.
Owners of company not identifiable.
Owners of company with unusually close links to officials .
A history of fraud in the type of contract or with the contracting organisation.
9 - Investigations
9.1 - Managers are responsible for following up on any allegation of fraud or corruption that they receive and are required to inform the Director of all suspected irregularities.
This is to ensure that the matter is dealt with promptly and confidentially and that:
All evidence that has been received is recorded.
The evidence is sound and adequately supported.
All the evidence that has been collected is secure, including electronic evidence.
where appropriate, other agencies are contacted, e.g. Police;
when appropriate, to arrange for the notification of Rhea's insurers;
9.3 - Depending on the nature and anticipated extent of the allegations, managers will normally work closely with the Director and other agencies, such as the Police. This is to ensure that all allegations and evidence are properly investigated and reported upon, and where appropriate, maximum recoveries are made for Rhea.
9.4 - Rhea's disciplinary procedures will be used where the outcome of the audit investigation indicates improper behaviour. "Reasonable belief" is sufficient ground for dismissal, rather than absolute proof as in a court of law.
9.5 - The Council's Auditors and Fraud Prevention Officers may become involved related to irregularities related to scheme eligibility.
9.6 - Where a fraud has occurred, management will need to take action to ensure that any control weaknesses which provided the opportunity for this to occur are addressed.
Where appropriate, control weaknesses will be identified by the investigation. Any lessons learnt will be disseminated to all relevant staff.
10 - Sanctions and Redress
10.1 - Where financial impropriety is discovered, whether perpetrated by staff, customers or suppliers (e.g. suppliers, contractors, and service providers), Rhea deals with the presumption that the Police will be called in.
The Crown Prosecution Service decides whether a case will proceed to prosecution. Referral to the Police is determined by the Director.
10.2 - Referral to the Police will not inhibit action under the Rhea's Disciplinary Procedures. Serious cases of fraud or corruption would represent gross misconduct and consequently, the member of staff may be liable to dismissal.
10.3 - The Director will advise on the course of action to be taken in relation to Members or Contractors.
10.4 - Suspected financial impropriety by any organisation Rhea deals with will be the subject of an investigation. If proven, this could result, for example, in the termination of an individual contract and may result in prosecution.
10.5 - In proven cases of financial loss, Rhea will seek to recover all such losses through whatever means it considers appropriate. If the fraudster is an employee, the loss may be recovered from any monies due to the individual on the termination of employment. In the event of the fraudster being a member of the Council the redress may be through the contractual arrangement with Blackpool Council.
10.6 - In the event of Rhea receiving a request for a reference in respect of an employee who has been dismissed as a result of a fraud/irregularity investigation, the Director should be contacted for guidance regarding the wording of any reference provided.
11 - Councils and Members Code of Conduct
Each Local Authority and the Unitary Authority will have their own individual Fraud as well as Code of Conduct policies for staff and Councillors which may impact on this policy. The scope and range of all these cannot be covered within this document but there may be instances where the actions of Local Authority staff and members impact on the work of Rhea.
These policies are intended to promote high standards of behaviour amongst staff and elected and co-opted members of Councils.
These are usually underpinned by the Seven Principles of Public Life (the Nolan Principles),
a) Selflessness – You must act solely in the public interest and should never improperly confer an advantage or disadvantage on any person or act to gain financial or other material benefits for yourself, your family, a friend or close associate.
b) Integrity – You must not place yourself under a financial or other obligation to outside individuals or organisations that might seek to influence you in the performance of your official duties.
c) Objectivity – When carrying out your public duties you must make all choices, such as making public appointments, awarding contracts or recommending individuals for rewards or benefits, on merit.
d) Accountability –You are accountable for your decisions to the public, and you must co-operate fully with whatever scrutiny is appropriate to your office.
e) Openness – You must be as open as possible about your decisions and actions and the decisions and actions of your authority and should be prepared to give reasons for those decisions and actions.
f) Honesty – You must declare any private interests that relate to your public duties and take steps to resolve any conflicts arising in a way that protects the public interest, including registering and declaring interests in a manner conforming with the procedures set out below.
g) Leadership – You must promote and support high standards of conduct when serving in your public post, in particular as characterised by the above requirements, by leadership and example
If Rhea staff have any concerns related to the manner in which Local Authority staff or members are acting in relation to the work Rhea carries out your concerns should be raised with your line manager and Director as appropriate.
It is unavoidable at times that a member of the Council or Councillors are linked, associated or directly involved with the CHiL contract. Extra care needs to be taken to ensure the appropriateness of all dealings and openness to ensure any scrutiny can be subject to any test, vetting or anti-corruption investigation.
Procedural checks are in place to protect you and to ensure that there are no inappropriate dealings that may be considered as bribery and corruption
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