LBWF has issued corporate credit cards to its senior managers, but broken the law for many years by failing to publish data tracking their use

For the past two decades or so, LBWF has issued its senior managers with corporate credit cards.

And, since 2015, following the introduction of the Local Government Transparency Code (LGTC), LBWF also has been legally required to publish data on how these cards are being used.

But with the exception of one year, 2016, the latter is something which LBWF has, without explanation, completely failed to do. 

Challenged about this in January 2025, LBWF’s Corporate Director – Internal Audit, Anti-Fraud, Revenues and Benefits, Gemma Young, states that ‘The corporate credit card data is being collated and will look to be published [sic] as soon as possible’, and then attempts some reassurance:

‘Although we have not yet been able to publish the corporate credit card information, all spend on credit cards is subject to review by individual services as part of the monthly budget monitoring process, so there are checks and balances in place to ensure that there is oversight. In addition to this, in 2021 the Internal Audit and Anti-Fraud teams undertook a proactive exercise to review credit card transactions made between 2019-21 [sic], and there were no fraudulent or inappropriate transactions identified. 

Internal Audit also undertook a review of the management of the credit cards in 2022 and were able to give reasonable assurance on the adequacy and effectiveness of the controls at the time’.

What to say? 

It is, of course, absolutely disgraceful that, despite employing several highly paid legal staff, including a Monitoring Officer, Mark Hynes, who is charged with ensuring compliance with the law, LBWF has for so long flouted the LGTC; and laughable that it is now seeking to publish data that the law dictates was due long ago.

Moreover, it hardly inspires confidence that no-one at LBWF seems to know exactly how many corporate credit cards have been in use, with Ms. Young falling back on the somewhat vague formulation ‘over 100’.

But what of Ms. Young’s more specific points about the Internal Audit findings?

It is of course significant that the material she cites only covers a relatively short period of time, 2019-22, and, so far, she has made no comment about the situation before and after.

Moreover, the one document that she has placed in the public domain, the October 2022 Internal Audit review, is less conclusive than might be imagined, amongst other things revealing that:

• the LBWF policy on payment cards was then only in draft, and had yet to be approved;
• supporting documents such as receipts were not stored centrally or shared with line managers; and
• there was no monitoring at a transaction line-item level, meaning, to quote, ‘Inappropriate spend may go unnoticed’.

Finally, as is apparent, Ms. Young’s comments focus exclusively on internal checks. 

But government advice is that those public sector organisations which use credit cards should build in some degree of outside supervision, for example, as the Crown Commercial Service strongly recommends, ‘Independent regular review of (a sample of) cardholder transactions’, and it is interesting that Ms. Young makes no mention of this safeguard.

In conclusion, it’s not difficult to find cases where local authorities which issue corporate credit cards have run into trouble.

For instance, in December 2023 TeesideLive reported that investigators evaluating just one Middlesborough Council department had uncovered ‘non-compliance with policy’, ‘thousands of unreviewed transactions’, ‘no regular challenge against excessive spending limits’, and ‘some officers… even reviewing and approving their own spend’.

There is no evidence at present that anything similar has occurred in Waltham Forest.

Nevertheless, what can be said is that by failing for so long in its legal duty to publish data on corporate credit card spending, LBWF has side-stepped one of the most effective ways of protecting against fraud, public scrutiny; and consequently made itself look, if not shifty, at least unwisely complacent about the expenditure of public money.