Fraud and corruption – not my problem (or 🤔)?
At the Policy Place, we’ve just finished reviewing and updating the Fraud and Corruption policy as part of our cyclical review of our online Financial and Property Management policy pages.
Sometimes, people think they don’t need a Fraud and Corruption policy. But they are mistaken.
Yes, we want to think the best of the people we work with. But that doesn’t mean we should bury our heads in the sand.
Policy and procedures that guide how your organisation prevents, detects and responds to fraud and corruption are a must! Policy and procedures to prevent and respond to fraud and corruption are also criteria for accreditation and auditing under the Ngā Paerewa Health and Disability Standard, the Social Sector Accreditation Standards and Community Housing Performance Standards and Guidelines.
Here’s some ideas about what to cover in your policy and procedures.
Prevention of fraud and corruption
Training and information for staff on how to report concern about fraud is a key requirement. Staff also need to know that they will not penalised for reporting and if applicable, that they have Whistleblower protection.
Risks and mitigations
Think through the risks – what parts and dynamics of your operation are vulnerable to fraud and corruption and what processes help to mitigate the risks. Here’s some examples of corruption risks and how these might be mitigated.
|CORRUPTION RISK||CONTROL EXAMPLES|
|Bribery by gifts and other inducements aimed at influencing decisions.||
|CONFLICT OF INTEREST|
|Conflicts of interest may lead to favouritism and preferential treatment in procurement and other areas.||
|DISHONEST OR CORRUPT DEALING WITH ASSETS|
|Assets, including intellectual property and confidential information, may be disposed of or improperly dealt with for personal gain.||
Identify and make sure everyone knows how to report concerns about fraud and corruption. It’s important in this regard that the process applies for everyone in the organisation, including the CE, managers and board/governance.
The process should include when allegations will be reported to Police, investigation of concerns, rights of those being investigated and protections for those who report.
Through training and information, people should be made aware they should provide detail when reporting, but that they must not undertake an investigation themselves.