Anti-Fraud Bribery and
requires its managers, staff and trainees to act honestly, with integrity and
to safeguard any ACAPS resources for which they are responsible at all times.
The purpose of this policy is to set out the responsibilities of managers, staff and trainees regarding the
prevention of fraud, bribery and corruption and the procedures to be followed
where any of these are detected or suspected.
1.1 ACAPS management is responsible
for the prevention, detection and investigation of irregularities. To discharge
this responsibility, management must ensure that an adequate system of internal
control is operated. The work of internal audit in reviewing the adequacy and
effectiveness of the internal control system will help management to prevent
and detect fraud.
1.2 Prosecution is a particularly
effective deterrent because of the risk of a custodial sentence and a criminal
record. However, the threat of prosecution only deters if the threat is real.
Therefore each and every case arising will normally be referred to the police
irrespective of the status of the individual.
2.1 Fraud can be minimised through
carefully designed and consistently operated management procedures which deny
opportunities for fraud. Training in fraud awareness for appropriate members of
staff will be co-ordinated by the Management, with support from both internal
and external audit.
2.2 Potential misuse of information
technology must be prevented by managing the physical access to terminals, and
protecting systems with electronic access restrictions.
Role of Auditors
3.1 When new systems are being
designed or existing systems are to be modified, internal auditors can advise
management on building in ways of preventing or detecting fraud.
3.2 A continuous review of systems
by internal audit may deter attempted fraud and should result in continuous
improvements. The risk of fraud should be a factor in audit plans. External
audit can give advice about systems and their reviews of financial checks and
balances and validation testing will provide further deterrence. Auditors may
also wish to assess systems in place to deter corruption.
4.1 Potential new members of staff
must be screened before appointment in accordance with the Recruitment and
Selection Procedures prepared by the Administration Department
Internal Management Systems
5.1 This is the most important
measure because the risk of processing an irregular transaction is minimised
where every transaction is reviewed systematically. Detective checks and
balances must be designed into all systems and applied consistently.
5.2 Systems should identify
transactions which have not followed normal procedures. However, deception may
be used to make improper transactions appear legitimate. The detective elements
in each system must therefore be complemented by a general detective approach,
to capture suspicions identified through chance, exit interviews and tip-offs.
member of staff has a duty to ensure that ACAPS resources are safeguarded.
Staff must alert their manager if they believe an opportunity for fraud exists
because of poor procedures or lack of effective supervision.
6.2 It is
the responsibility of every member of staff to report details immediately to
their manager or appropriate senior person if they suspect fraud may have been
must also assist in any investigations by making available all relevant
information and by co-operating in interviews.
Whistleblowing/Public Interest Disclosure
7.1 ACAPS complies with the Public
Interest Disclosure Act 1998 which states that employees who disclose
information on certain matters will be legally protected from being
disciplined, dismissed or victimised by their employer as a result.
of Audit in Detection
defences against fraud must be robust preventative measures by management,
coupled with sound detective checks and balances. Audit should be regarded as a
'long stop'. Internal and external audit may be involved in identifying
irregularity occurs unpredictably, in any part and at any level in an
organisation. It frequently causes disruption which is out of proportion to the
sums involved. Once a fraud is suspected, prompt action is needed to safeguard
assets, recover losses and secure evidence for effective legal and disciplinary
Process of Investigation
10.1 Suspected fraud should be
reported to the Managing Director who will instigate action and investigation.
10.2 It is important to ensure that
initial investigation is carried out with care and sensitivity, confidential to
those who contribute to the investigation, recognising the possibility of
proper investigation, ACAPS will take legal and/or disciplinary action in
accordance with the ACAPS disciplinary procedures where it is considered
appropriate. ACAPS Managing Director will refer each case to the police as
early as possible. If the case is not reported to the police, the Managing
Director will advise the reason why not. A civil action against the perpetrator
may also be appropriate to recover losses resulting from the fraud. The
investigation will also consider whether there has been any failure of
supervision, and if so, appropriate disciplinary action will be taken against
circumstances of individual frauds will vary, but it is very important that
each case is vigorously and promptly investigated and that appropriate action
is taken. ACAPS views fraud very seriously and it will not be tolerated in any
form. Any member of staff found to have committed an act of fraud is liable to
Amended Sept 2017 DE.