Anti-fraud policy

The Conseil Régional Hauts de France is the Managing Authority of three European Territorial Cooperation (ETC) Programmes (Interreg Europe, Interreg North West Europe, Interreg 2 Seas) and one European Initiative (Urban Innovative Actions - UIA).

As each ETC Programme finances projects through EU and public funding, we are committed to protecting the EU and public funds that have been entrusted to us. Therefore, we wish to be clearly perceived as opposed to fraud and corruption.

The term fraud is commonly used to describe a wide range of misconduct including theft, corruption, embezzlement, bribery, forgery, misrepresentation, collusion, money laundering and concealment of material facts. It often involves the use of deception to make a personal gain for oneself, a connected person or a third party, or a loss for another.

The EU Treaty defines fraud, in respect of expenditure, as an intentional act or omission related to:

• The use or presentation of false, incorrect or incomplete statements or documents, which has as its effect the misappropriation or wrongful retention of funds from the EU;
• Non-disclosure of information in violation of a specific obligation, with the same effect;
• The misapplication of such funds for purposes other than those for which they were originally granted.

Intention is the key element that distinguishes fraud from irregularity. Intentional deceit is not easy to prove but there are some tell-tale signs such as:

• Motive – Pressure for results, financial hardship, revenge
• Opportunity – Controls not functioning, staff changes/losses, tolerance
• Repetition – If not detected it is repeated
• Concealment – Attempt to cover up the evidence

Fraud does not just have a potential financial impact, but it can cause damage to the reputation of an organisation responsible for effectively and efficiently managing funds. This is of particular importance for a public organisation responsible for the management of public funding in general and of EU funding in particular.

The Managing Authority has a zero tolerance policy towards fraud and corruption. We have identified the most likely areas for fraud in our Programmes and projects and have set up robust control systems, measures and procedures in order to follow up on all suspected cases that are highlighted to us.

We may carry out verifications of project partners or external contractors, notably through the use of specialised IT tools such as the ARACHNE risk scoring tool provided by the European Commission.

With our Member State representatives, we will furthermore seek action at the national level in line with a country's administrative and legal procedures, wherever the need arises.

The Managing Authority expects all employees and representatives of the three ETC Programmes and the European Initiative UIA to be an example in ensuring adherence to legal requirements, regulations, codes of conduct, procedures and practices.

The responsibility for an anti-fraud culture is the joint work of all those involved in the EU programmes/initiative and projects. We therefore also encourage all partners, contractors, employees, or the public to do their utmost to prevent fraud from happening, to put into place proportionate measures to detect it and to come forward with any suspicion of fraud in relation to our programmes.

If you wish to report suspicion of fraud, please send relevant information to the following email address: lanceur.alertes(at)hautsdefrance.fr, which is accessed by the Director of the legal affairs department of the Hauts-de-France Region.

Please note that sending an email to this email address does not replace national legal actions that may be introduced in parallel (for instance, a potential contractor may also consider taking legal action to request the cancellation of a public procurement procedure that is considered irregular or fraudulent). It also does not have any impact on the time limits for such legal actions.

Controllers wishing to report a suspicion of fraud should use the template below.