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Agenda item

Procurement Investigation - Counter Fraud and Enforcement Unit

Purpose

To present the Committee with a report on findings from an investigation into concerns related to three specific procurement activities of Cotswold District Council.

 

To provide assurance to the Committee that the risks of fraud committed against the Council or within the Council are recognised, managed, and mitigated appropriately.

 

Recommendations

That the Committee resolves to:

1.    Note the report.

2.    Request an update on the action plan being brought back to the committee in April 2026.

Minutes:

The Chair handed introduction of the report to the Deputy Chief Executive Officer, who explained that the report consisted of two parts; what had already occurred, and what the Council’s officers had done or were currently doing in response to it:

  • Section 2, supported by details provided in Annex A, outlined the ‘key governance issues’ identified during the investigation. Paragraph 2.2 of that section was highlighted by the officer as a key part of why the Committee had received the report, that this section highlighted the responsibility of the Committee and himself as Chief Finance Officer to maintain internal controls, operational risk awareness, and efforts made to combat fraud and corruption.
  • Section 6 summarised the findings from the previous sections and highlighted commonalities between them, including weaknesses in controls, impacts on the Council especially regarding reputational damage, and legal and financial risks.
  • The officer directed the Committee’s attention to section 7 and specifically Annex B, noting that of the points listed on the action plan:
    • the constitution had been updated following the new procurement process having been introduced in February 2025.
    • the online form for purchases over £5000 to ensure the register was as up to date as possible was completed in August 2025.
    • the mandatory procurement training for officers was in place and was expected to be complete by the end of 2025 with different levels of detail depending on staff member seniority.
    • Point four, the procurement toolkit, was still under development at the time of the meeting and would provide a set of standardised templates for future procurement requests.
    • Point five related to system improvements to the procurement section on the online Business World software in use by the Council, which was currently in development with testing to commence in November, to be launched by the end of 2025.
    • Point six involved reviewing the terms of reference for the officer commissioning and procurement board, which for a number of years had been under the purview of Publica but was now managed directly by the Council.
    • Point seven was the ‘long overdue’ improvements to financial reporting that the officer noted had been a point of discussion in previous committees. As suggested by previous audit findings, the Council made an effort to improve its ABW financial reporting through reducing the quantity of individual reports and ensuring that relevant directors and responsible staff members had straightforward access to them. This also included a spend analysis to support the commissioning and procurement board in ensuring that all spending was being captured, not just those the team was actively notified about.
    • The officer also noted the implementation of the team’s “No Purchase Order, No Payment” rule, a change that had also been discussed previously, which the team was hoping to implement around 30 June 2026 due to the turn of the financial year making earlier opportunities more complicated - but if an earlier launch did become possible they would do so.
    • The final point as listed was the Council Awareness Resource, requiring the addition of the Chartered Institute of Public Finance and Accountancy (CIPFA) guide to the member’s portal and to arrange an introductory briefing – the officer stated that this item remained in progress in the paperwork but as of the time of the meeting the item had now been completed.

 

The Deputy Chief Executive Officer stated that the overall aim for this report was to emphasise the importance the Council places on good governance, and to assure members that their Corporate Leadership Team had been actively working on and monitoring the findings in the report and that any issues had robust action plans in place to remedy them.

The Committee offered its support to the individuals who had initially reported their concerns as described on page 155, hoping that this indicated that the process was effective in protecting the Council from these kinds of fraudulent actions.

The Committee asked whether any funds were returned during the course of the reported investigations. The officer advised that while there were concerns about value for money during the bidding processes involved in these cases, it would be difficult to recoup specific figures due to the nature of the circumstances, and that any amounts listed in the report only pertained to resources expended investigating the allegations.

RESOLVED: The Committee noted the report and requested an update on the action plan in April 2026.

 

Supporting documents:

 

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