Anti-fraud, bribery and corruption policies

Please note: we use the terms 'fraud', 'bribery' and 'corruption' in this article to refer specifically to incidents of financial irregularity.

Having an anti-fraud policy is recommended but not required

However, you must have arrangements in place to protect public money, as outlined below. 

Maintained schools

All maintained schools must complete the Schools Financial Value Standard (SFVS).

You're required to submit your SFVS to your local authority by 31 March 2024. 

Section F requires schools to ask themselves:

• Are there adequate arrangements in place to manage related party transactions?
• Are there adequate arrangements in place to guard against fraud and theft by staff, contractors and suppliers?
• Are all staff aware of the school’s whistle-blowing arrangements and to whom they should report concerns?
• Do we have an adequate accounting system that delivers accurate reports, including the consistent financial reporting return?
• Do we have adequate arrangements to audit voluntary funds?

The checklist guidance (the second document on the page) sets out what schools' anti-fraud arrangements should include. This includes the governing board and headteacher informing all staff of:

• School policies and procedures related to fraud and theft
• The controls in place to prevent them
• The consequences of breaching these controls

Suitable arrangements are likely to include, among other things:

• Financial management checks
• Spot checks on systems and transactions
• Pre-employment checks
• Clear job descriptions that include financial responsibilities

Academies

Trusts are required to complete a resource management self-assessment checklist. It's for governing bodies and trust boards, and covers:

• Governance
• Trust strategy
• Setting the annual budget
• Staffing
• Value for money
• Protecting the public purse

The deadline for trusts to submit their checklist is 15 March 2024.

Academy trusts must also have an internal control framework, which reduces the risk of fraud and theft, as outlined in the Academy Trust Handbook (paragraphs 2.6 and 2.7).

The handbook includes guidance for academies on investigating fraud, theft and/or irregularity in their accounts (paragraphs 6.9 and 6.10). Requirements include:

• Academies must be aware of the risk of fraud
• The board of trustees must notify the Education and Skills Funding Agency (ESFA) of any instances of fraud

You can download a checklist for developing a fraud-management strategy. It's included in the ESFA's guidance on managing the risk of fraud in academy trusts.

See examples from schools

Goudhurst and Kilndown Church of England (CofE) Primary School in Kent has a school fraud policy with sections on:

• Policy statement
• Definition of fraud
• Key responsibilities
• Reporting suspicions

It also includes a fraud response plan. 

Bushey Heath Primary School in Hertfordshire has an anti-fraud and corruption policy for staff which includes: 

• Background information 
• Policy statement 
• Checklist for implementation of the policy 

St Thomas Rich's School, a secondary school in Gloucestershire, has an anti-fraud policy that outlines preventative measures for the following areas: 

• Leadership
• Management procedures
• Staff appointments 
• Handling of cash and cheques 
• Purchasing

Greenwood Academies Trust's anti-fraud policy includes sections on:

• Policy statement
• Deterrence
• Prevention
• Detection
• Response