Counter fraud and anti-corruption policy

What to do if you suspect fraud

Immediately report your suspicions to:

Do:

  • record your suspicions – write down what you have found, seen and heard
  • keep any evidence you have in a safe place until you can pass it to CFIT unless you risk alerting the suspect
  • tell us who you are – we will want to talk to you as you may know more than you realise
  • keep calm

Do not:

  • delay - report the matter quickly
  • approach or accuse individuals directly. You may alert them and evidence may be destroyed
  • tell anybody else – you don’t know who may be involved
  • investigate yourself – you may spoil the evidence and prevent a criminal prosecution

Safeguards

Harassment, bullying or victimisation

If you have raised your concerns in good faith we will take action to prevent you from reprisal.

Confidentiality

If you feel it is necessary we will try to protect your identity. This will not be possible if the investigation leads to criminal action.

Anonymous referrals

We do not encourage these as it affects our ability to investigate. However we will always look into any case of suspected fraud. 

Malicious referrals

If we find that your referral is malicious or has been made for personal gain, we will take action against you under our disciplinary policy or relevant agreement if you work for one of our partners.

Investigation

All suspected fraud must be referred to CFIT.

CFIT will assess the initial information and decide how to proceed.  This will include a strategy meeting with the relevant manager.

Following best practice defined in the counter fraud and investigations manual, CFIT will investigate most cases of suspected fraud.  Management may investigate low level fraud involving an employee after consultation with CFIT.

Potential outcomes

Criminal prosecution

The head of corporate audit and risk management on advice from CFIT will authorise the referral to the police for investigation.

Disciplinary action

At the end of the investigation CFIT will produce an outcome report.  If this involves an employee and fraud is proven, the likely outcome will be dismissal.  If fraud is not proven there may still be matters which need to be considered under our disciplinary procedures.

Recovery through civil or criminal proceedings

We will seek to recover all losses subject to legal advice and where it is cost effective to do so.  We will recover any loss caused by an employee through salary, pension or insurance.

Weaknesses in the system of controls

We will produce an action plan to:

  • address any system or management weaknesses 
  • reduce the risk of fraud and error in the future