Fraud unit issues recommendations on tackling “polygamous working”

The CFEU conducted a review of the risks posed by undisclosed multiple employment and the challenges of oversight in hybrid working arrangements.

It also issued 16 recommendations, covering clearer contractual language, greater checks on current or prospective employees, and new disciplinary measures.

The review comes a month on from Bryn Howells being found guilty of committing fraud for working for three councils and a Teckal company providing services to another council at the same time.

He was sentenced on 28 August 2025 to three years imprisonment for three charges and a further two years imprisonment to run concurrently, for six other charges.

Tewkesbury Borough Council - which was one of the three councils affected in the case - detailed some of the review's findings in a full council meeting on Tuesday (30 September).

West Oxfordshire District Council's Audit and Governance Committee also considered a report on the CFEU's review last week (25 September).

The district council's report confirmed that the CFEU's work plan for 2024/25 "included a focus on fraud risk mitigation regarding grant schemes and polygamous working as high-risk areas".

Responding to a member's question, Lead Member for Staff and Culture at Tewkesbury, Cllr Deborah Harwood, said: "The [Howells] case has underscored the need for systemic improvements in recruitment, contract oversight, and remote working governance.

"While this individual exploited vulnerabilities for personal gain, the case and successful prosecution also serves as a catalyst for change, reinforcing the importance of managing hybrid working arrangements with care."

Tewkesbury has implemented the review's recommendations, including:

• Clearer contractual language and declarations of interest, explicitly requiring disclosure and approval of any secondary employment.
• Strengthened verification processes at recruitment and throughout employment, including cross-checks with external data sources to identify potential conflicts or risks.
• Updated guidance for managers, with a focus on effective oversight in remote and hybrid working environments.
• Revised disciplinary procedures, enabling more decisive action in cases of fraud, misrepresentation, or breach of trust.
• A new manager toolkit, designed to support performance management, visibility, and accountability in hybrid settings.

The Counter Fraud and Enforcement Unit also produced an updated Fraud Risk Strategy, Compliance Report and Response Plan, covering wider fraud risks.

Adam Carey