This standard will provide confidence that you have adequate procedures to undertake proactive work to create an anti fraud culture, re-design systems and processes to remove fraud risks and deter fraudsters through the communication of a robust anti fraud stance.
A vital element of deterring fraud is developing a culture where the people you employ and do business with share your values of honesty and integrity.
Area for Action
Does the organisation have a clear workplan in place to create a strong deterrent effect?
Risk
Failure to have a workplan in place to promote a strong deterrent effect may result in:
- no/little resource allocated to deterrence allowing fraud to take place;
- the organisation may be perceived by the public and other stakeholders as not having an effective counter fraud culture;
- staff will not be aware of the consequences of fraud, examples of fraud, or likelihood of being caught; and
- staff are not aware of local or national frauds or actual cases within their speciality/discipline.
Area for Action
Does the organisation seek to design fraud and corruption out of new policies and systems and to revise existing ones to remove apparent weaknesses?
Risk
Failure to adopt a system of fraud proofing policies and procedures may result in:
- the organisation being at risk to the same fraud being perpetrated time and time again;
- the organisation being criticised by the Crown Prosecution Service for having inadequate procedures, and in the case of bribery will be at risk of prosecution itself;
- criminal sanctions against fraudsters may fail due to inadequate policies;
- staff will not see that the organisation is serious about deterring fraud;
- the organisation fails to demonstrate a commitment to countering fraud;
- the organisation fails to comply with legislation;
- the organisation may create the impression that fraud will go unnoticed or that systems may not provide adequate evidence of fraud if it is uncovered; and
- an organisation's entrenched procedures could lead to fraud if policies/systems drive staff to behave in a particular way.
Areas for Action
Are all applicants (including contractors, temporary staff, promotions) for jobs vetted by trained staff?
Risk
If an effective process is not in place there is a risk that:
- the organisation will not have an up to date system to promote consistency in the hiring process;
- the employer may be liable to a fine if they were found to be employing illegal workers;
- if found to be employing illegal workers the organisation may be exposed to bad publicity; and
- the organisation might employ people who are not suited to the role, who do not hold the appropriate qualifications, and/or who possess attributes that do not meet the organisation's expectations/standards for employees. In extreme cases the organisation's reputation and quality of services could be harmed.
Areas for Action
Does the organisation have a clear workplan attempting to create a real zero tolerance anti-fraud and corruption culture?
Risk
If there is no workplan in place there is a risk that:
- activities will not be co-ordinated;
- activities will not target the areas of highest risk;
- targeted activities will not flow throughout the organisation;
- relevant activities will not be suitably linked;
- activities will devalue over time if not clearly documented and followed up;
- the counter fraud specialist may be seen as unprofessional;
- the organisation's arrangements will not reflect policy; and
- the organisation will have no basis upon which to monitor its investment in counter fraud services.
