The North Lincolnshire Council Audit Committee met to discuss treasury management, audit progress, and policies related to anti-money laundering, bribery, and fraud prevention. The committee approved the Anti Money Laundering Policy 2025 and the revised Anti-Bribery Policy, and were assured that the preventative measures in place met the threshold for a reasonable defence against fraud. The committee also requested an update at their next meeting on the Strategic Risk Register.

Preventing Fraud – The Council's Responsibilities Under the Economic Crime and Corporate Transparency Act

The committee reviewed a report regarding the council's responsibilities under the Economic Crime and Corporate Transparency Act 2023¹, which creates an offence for large organisations that fail to prevent fraud. The Director: Transformation and Outcomes explained that while the Act was not specifically designed for local authorities, North Lincolnshire Council meets the criteria of a large organisation due to its staff size and annual turnover.

To avoid prosecution, the council must demonstrate it has reasonable preventative measures in place. The report outlined six guiding principles for assessing these measures:

• Top Level Commitment: Senior leadership actively promotes an anti-fraud culture.
• Proportionate Procedures: Controls match the level of risk.
• Risk Assessment: Authorities assess fraud risks across operations.
• Communication and Training: Staff are trained to recognise and report fraud, and whistleblowing[^3] mechanisms are robust. [^3]: Whistleblowing is when a worker reports suspected wrongdoing at work.
• Due Diligence: Vetting of employees, contractors, and suppliers is essential.
• Monitoring and Review: Procedures are regularly reviewed and updated.

The report detailed the council's current position regarding each principle and proposed further actions. Mandatory e-learning for staff has been approved, and training will be revised and referenced in the Reporting a Concern policy. The committee were assured that the preventative measures in place met the threshold for a reasonable defence, and that these measures would be reviewed regularly.

Anti Money Laundering Policy 2025

The committee approved the Anti Money Laundering Policy 2025, which takes into account the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017². The Director: Transformation and Outcomes noted that while the regulations are not aimed at local authority activities, some activities may fall within the definition of 'regulated' activity. The policy provides guidance on reporting suspicious financial activity to protect the council and its employees. Changes to the policy include lowering the recommended maximum limit on cash acceptance from 15,000 Euros to 10,000 Euros (or GBP equivalent) and updating the link to the National Crime Agency's Suspicious Activity Report portal.

Anti-Bribery Policy 2025

The committee approved the revised Anti-Bribery Policy. The Director: Transformation and Outcomes stated that the council has a zero-tolerance policy regarding bribery, and all staff, officers, and members are expected to prevent and detect bribery offences, as required under Section 7 of the Bribery Act 2010³. There were no significant changes to the policy, which was due for renewal, and relevant links were refreshed in respect of the Reporting a Concern policy.

Treasury Management Quarter 1 2025-26

The Director: Transformation and Outcomes presented a report on the council's treasury performance during the first quarter of 2025-26, outlining national factors affecting treasury activity. The report fulfilled the council's legal obligation under the Local Government Act to adhere to the Chartered Institute of Public Finance and Accountancy (CIPFA) Code and Ministry of Housing, Communities and Local Government (MHCLG) guidance. The Treasury Management Code of Practice 2021 requires quarterly updates on treasury management to ensure the effectiveness of the council's arrangements.

The CIPFA Code prioritises security, liquidity, and yield in treasury management policies. Full Council agreed to the Treasury Management Strategy Statement (TMSS) for 2025-26 in February 2025. The council's quarter one treasury management activity and performance was attached to the report as an appendix. The committee were assured on the effectiveness of the council's arrangements for treasury management and noted the treasury management activity during the first quarter of 2025-26.

Audit Progress Report - September 2025 - Report of Forvis Mazars

A representative of Forvis Mazars, the council's external auditors, presented the Audit Progress Report for September 2025. The report noted that the audit certificate for the 2023-24 audit was issued on 3 September 2025, marking the completion of the external audit. The Audit Strategy Memorandum, presented to the committee in July 2025, outlined the auditors' plan. Fieldwork for the 2024-25 audit had commenced following the submission of draft financial statements on 3 June 2025, with no changes to the risk assessment or audit approach. Significant risks identified included management override of controls, valuation of land and buildings and surplus assets, valuation of the net defined benefit asset/liability, and accounting for leases under IFRS 16⁴. The auditors had reviewed regulatory reports and committee minutes as part of the Value for Money arrangements and requested that management complete a self-assessment questionnaire. The committee noted and received the Audit Progress Report.