Emma Cathcart, Head of Service at the Counter Fraud and Enforcement Unit (CFEU), and Mark Squibbs, Senior Investigation and Enforcement Officer, presented a detailed case study at Counter Fraud 2026 on one of the most significant polygamous working prosecutions the public sector has seen. Here is what they said.
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Cathcart was clear from the outset: polygamous working is not moonlighting, and it is not having multiple responsibilities across one organisation. It is the secret, concurrent holding of multiple full-time roles; working overlapping hours for different employers without declaration. The fraud lies in the failure to disclose, the conflict of interest, and the misrepresentation of availability and capacity to each employer. It is a breach of the implied duty of mutual trust and confidence that runs through every employment contract, whether or not there is an express clause.
It is a growing risk. FOI data and recent research show a rising number of public sector employees identified as holding multiple full-time jobs, and there has been an upturn in successful criminal prosecutions, disproving the argument that this is simply an HR matter. The majority of cases identified to date have come through the National Fraud Initiative.
Squibbs set out the facts. An NFI match identified that a Mr Howells held simultaneous employment across three organisations between February 2022 and June 2023: as a Strategic Housing and Enabling Officer at Tewkesbury Borough Council, as a Valuer and Estate Surveyor at Publica Group (a local authority-owned company), and as a Senior Development Surveyor at South Gloucestershire Council. A fourth role, held via an agency, ran between January and November 2023 but was not included in the prosecution.
When contracted to two employers simultaneously, Howells was committed to 74 hours a week. When employed by three, 111 hours. At the peak of four roles, 148 contracted hours per week. The total value of the fraud exceeded £236,500 - every penny of salary, pension contributions and national insurance paid out by the councils as a result of his false representations.
Throughout the period, Howells made dishonest representations and omissions across job applications, onboarding documentation, and annual declarations of interest. He submitted timesheets to each employer showing standard 9-to-5 working - a physical impossibility. On nine charges of fraud (six for false representation, three for failing to disclose), he was found guilty.
His defence at trial was notable. He argued he had not read the contracts closely, that the declarations were an administrative oversight, that timesheets were for lower-grade staff rather than professionals of his standing, and that his work was of such high quality that the councils had saved money rather than suffered a loss. The jury was not persuaded. He was sentenced to three years in custody. A proceeds of crime case is ongoing.
Squibbs was candid about the challenges. The Friday before trial, Howells agreed to plead guilty to six of twelve charges. Over the weekend, following advice from a friend rather than his barrister, he changed his mind. He wrote to the CPS asking them to take over and reconsider the prosecution, citing procedural fairness, proportionality, and what he described as a maliciously motivated and vindictive prosecution. His barrister, on the first day of trial, stated he was professionally embarrassed and withdrew. The judge rejected the application to involve the CPS, confirmed the council's authority to bring the prosecution, and refused an adjournment. On the second day, Howells raised concerns about his mental health, citing memory loss and early signs of dementia. The trial was paused for two hours for him to retrieve medical documentation. The documentation confirmed no evidence of dementia, attributing any short-term memory loss to the stress of the Crown Court proceedings. The trial continued. The conviction is now under appeal.
Cathcart drew out a number of practical lessons for counter fraud teams and organisations:
Cathcart acknowledged that colleagues at the councils felt guilt about not having spotted the fraud earlier. She pushed back: Howells was a fraudster who lied, misled, and submitted multiple false documents. He did just enough work to maintain the deception, and he was evasive when challenged. That said, there are behavioural indicators that can prompt earlier scrutiny, including inconsistent availability, vague responses about workload, unexplained gaps in output, reluctance to attend in-person, and unusual patterns in timesheet submission. These indicators are not proof of wrongdoing, but they warrant a conversation.
Cathcart closed by connecting the case to the wider legislative landscape. The new failure to prevent fraud offence under the Economic Crime and Corporate Transparency Act means organisations need to demonstrate they are taking active steps to prevent fraud — both internally and externally. How an organisation responds to and communicates about cases like this is now part of that evidence base. Polygamous working, she argued, is not a niche risk. It is a growing one, enabled by agile working arrangements that are not going away. The question is whether organisations have the controls in place to detect it.