Fraud Policy

Kartoza Fraud Policy

MODEL FRAUD RESPONSE PLAN

Purpose

The purpose of this plan is to provide guidance on the action to be taken when fraud is suspected or discovered.  It covers among other things, to whom the fraud will be reported, responsibilities for actions, who will investigate the incident and how employees under suspicion will be dealt with.  The use of the plan may enable the governing body within Kartoza (hereafter called the Organisation) to:

Initiating Action

Detection

Suspicion of fraud or irregularity may be captured through a number of means, including the following:

Action to be taken

  1. All actual or suspected incidents of fraud will be reported without delay to the Fraud Liaison Officer or other nominated person responsible for managing the risk of fraud within the Organisation.  
  2. The Organisation will immediately take steps to identify if the actual or suspected fraud involves public or private funding or is restricted to the Organisation’s own funds.  
  3. Where the fraud may involve public funding the Organisation will immediately contact the relevant funding body for guidance on what action needs to be taken by the Organisation.  This may include advice on any preliminary enquiries which may be required and on who will conduct the investigation; for example in cases where the suspected fraud involves grant money disbursed by the Department for Social Development (DSD), then any investigation will be conducted by DSD Corporate Investigations Unit (CIU). 
  4. If the fraud involves the Organisation’s own private funding then the Police should be notified immediately.  In such instances the Police will be responsible for taking forward any investigation and providing advice in respect of any preliminary enquiry to be undertaken.  

Prevention of further loss

  1. Where initial enquiries provide reasonable grounds for suspecting a member or members of staff of fraud, the Organisation will decide how to prevent further loss. This may require the suspension, with or without pay of the suspect(s); it may be necessary to plan the timing of suspension to prevent the suspect(s) from destroying or removing evidence that may be needed to support disciplinary or criminal action.  Regard should be paid to guidance below in relation to disciplinary action.
  2. In these circumstances, the suspect(s) will be approached unannounced.  They will be supervised at all times before leaving the premises.  They will be allowed to collect personal property under supervision, but will not be able to remove any property belonging to the Organisation.  Any security passes and keys to premises, offices and furniture will be returned.
  3. The Organisation will consider the best means of denying access to its premises/property while the suspect(s) remain suspended (for example by changing locks and informing staff not to admit the individual(s) to any part of the premises). Similarly, access permissions to all computer systems will be withdrawn.

Establishing and securing evidence

Following an allegation or the report of a suspicion of fraud, information to determine whether fraud is a possibility will initially be obtained by the organisation: 

Discreet enquiries –

Review of documents/records–

Recovery of losses

Where the Organisation has suffered a loss, efforts will be made to recover that loss.  In some circumstances this may involve a civil action and it will probably be necessary to seek legal advice.  If the loss may be covered by insurance then the appointed brokers will be advised at the earliest opportunity. The funding body or the Police should be able to advise on options available.

Other Issues

Disciplinary action

The application of disciplinary procedures is solely a matter for the Organisation.  Advice shall however be obtained, either from the funding body or the Police, on whether or not such action could impede or interfere with a potential criminal investigation.  All disciplinary action will be conducted in line with relevant employment legislation and recognised codes of practice.

Review of Fraud Response Plan

The Fraud Response Plan will be reviewed annually or following an incident of fraud, to ensure that it reflects changes, which may be necessary to strengthen future responses to fraud.  Changes to the Fraud Response Plan will be the responsibility of the Organisation.

 

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