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?
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?
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?
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?
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.