Scottish Public Finance Manual

The Scottish Public Finance Manual (SPFM) is issued by the Scottish Ministers to provide guidance on the proper handling and reporting of public funds.

Annex 1: counter fraud strategy


1. Tackling public sector fraud in Scotland is a big challenge. We have to be vigilant to protect public sector resources due to the significant challenges presented by the downturn in the global economy, the context of the reduction in public spending and the ambitious programme of public service reform. 

2. The Scottish Government (SG) Counter Fraud Strategy, along with the SG Counter Fraud Policy and Response Plan, outlines the approach for the prevention, detection, reporting and handling of fraud. The documentation is designed to be accessible to all SG staff – and to other public sector organisations to which the Scottish Public Finance Manual (SPFM) is directly applicable.

3. We have 5 strategic objectives in our approach to countering fraud: 

  • Awareness: we will prevent fraud by raising awareness of fraud and its safeguards among public organisations in Scotland, our partner organisations in the private and voluntary sectors and our stakeholders. 
  • Prevention: we will prevent fraud through improving our systems and controls to support our business and public services. 
  • Teamwork: we will prevent fraud by removing silos and working together across organisations and the public sector to share information and develop combined approaches to countering fraud. 
  • Investigation: we will handle fraud by being proactive in analysing data to identify areas at risk of fraud, by being effective and professional in our investigations of specific cases and by maintaining a robust whistle blowing procedure. 
  • Enforcement: we will handle fraud by continuing to be tough on fraudsters by punishing them more efficiently and effectively.

Counter fraud culture 

4. The Scottish Government has a zero tolerance approach to fraud: there is no acceptable level of fraud. There is a role for all members of staff in establishing an effective counter fraud culture by engaging and being alert to the risk of external and internal fraud; identifying suspicious activities and control weaknesses; and reporting any suspicions quickly and appropriately.

5. Our approach to counter fraud aims to ensure that a zero tolerance culture to fraud is maintained and that fraud is effectively managed at all levels of public service delivery as follows: 

  • Committing to clear ethical standards through a formal counter fraud policy
  • Communicating our attitude to fraud by raising awareness of our counter fraud policy to all staff
  • Supporting all staff in their responsibilities in preventing and detecting fraud through guidance and training
  • Providing managers with specialist support in designing, operating and reviewing internal controls
  • Maintaining comprehensive procedures for preventing and detecting fraud that must be carefully followed and monitored
  • Protecting members of staff through a robust process for reporting suspicions of fraud
  • Responding to fraud effectively through a comprehensive fraud response plan
  • Using data and technology efficiently in the systems in place to combat fraud
  • Sharing knowledge of vulnerabilities and lessons learned through strong communication channels


Page Updated: Septemebr 2019

Back to top