FRAUD RESPONSE PLAN

This fraud response plan includes information on:

  • Arrangements for establishing facts and securing evidence
  • Ensuring that further breaches are not made
  • Making appropriate notifications
  • Arrangements for managing or conducting the investigation
  • Decisions on follow up action, including liaising with the Police
  • Identifying and disseminating lessons for the future.

Updated on 24th June 2024

  • If a fraud has occurred or is suspected the following action must be taken:

The person who discovers the fraud must report the occurrence to their line manager in the first instance. If it is not appropriate for the individual to speak to their line manager because of fear of harassment or victimisation resulting from making the report or because the suspicion involves their line manager they may contact the Director of Finance and Performance (on extension 5287) or contact the Chair of the Audit Committee (contact details available from Head of Corporate Planning on extension 2391). Alternatively anyone wishing to report a fraud or suspected fraud anonymously may do so to the following email address: …….gsi.gov.uk using private and non-identifiable email accounts.
 
All matters will be dealt with in confidence and in strict accordance with the terms of the Public Interest Disclosure Act 1998 and EmergX’s Forensic Readiness Policy.
 
The contacted person will speak to Internal Audit or ensure a senior manager (normally at head of department level or above) is directed to instigate an investigation and will brief the Director of Finance and Performance and the Chair of the Audit Committee as appropriate. The investigation will cover the degree to which the alleged fraud was intentional. The Head of Internal Audit will be informed of all suspected frauds and irregularities from the outset of any investigation which might be undertaken.
 
In the first instance Internal Audit or a senior manager will normally investigate the alleged fraud and will lead the investigation. The facts should be quickly established by the operational managers; any threat to further frauds or losses should be removed immediately, for example by changing procedures or suspending payments.

  • Minor Fraud

A suspected minor fraud is one that is unlikely to result in police action, for example travel claim fraud, excess overtime, flexi fraud. In cases of minor fraud:

  • The Internal Audit or the investigating person should liaise with the Departmental Security Officer (DSO) to secure any evidence at the outset of the investigation. This should be done in a manner that does not alert the person alleged to have committed the fraud or impair future investigation or prosecution.
  • A decision to interview the alleged person must be made in conjunction with senior management which will be the Director of Human Resources and Organisational Development and the Director of Finance and Performance. Notes taken must be written up, agreed and signed as a fair representation of the interview by all parties. The alleged person will normally be dealt with through the disciplinary procedures detailed in the EmergX Staff Handbook and may be accompanied by a friend or trade union representative.
  • Disciplinary action may also be taken against any member of staff whose actions (or inaction) are found to have materially contributed to the fraud.
  • Major Fraud

If the nature of the alleged fraud is classed as serious (this decision will be taken by the Director of Finance and Performance, Internal Audit and the Chair of the Audit Committee) then a case meeting will be called with the Director of Finance and Performance, the Chief Executive, Internal Audit and Human Resources where the decision on whether to involve the police will be made. The police will then lead all investigations and Security, Human Resources, Internal Audit etc. will follow their directions.

  • If the fraud is classed as serious evidence must be secured in a legally admissible form e.g. evidence must be carefully preserved; it should not be handled and no marks made on original documents; a record should be kept of anyone handling evidence. It is important that this is undertaken by the police if the evidence will later be relied on in criminal proceedings.
  • Prompt action may have to be taken against an individual who is under suspicion.
  • Disciplinary Policy. Employees under suspicion who are allowed to stay on the premises must be kept under constant surveillance. An immediate search of the employee’s work area including computer files and filing cabinets must be made by the investigating officer, accompanied by either line manager, Director of Finance and Performance or similar and results noted and agreed between parties.
  • All interviews in pursuance of a potential criminal prosecution must be conducted under properly controlled conditions in order to ensure that any statement taken and subsequently used as evidence in a court case will not be rejected as inadmissible. These interviews must be carried out by the police under their evidence rules.
  • Recovering Assets

EmergX may ask the courts to pursue an action to recover all assets that have been taken illegally from EmergX.

  • Liason with press

If there is likely to be media interest then Press Office must be contacted by senior management with what information can be released and the Press Office is to keep a log of who requests or is given the information and what information has been provided

  • Learning Lessons and Improving Risk Mitigation Measures

At the conclusion of the investigation the person investigating the alleged fraud should identify any lessons learned. The Director of Finance and Performance is responsible for disseminating them across the organisation where appropriate. Where there has been a failure of control a full risk assessment and a revised procedure should be immediately put in place after taking advice from the Director of Finance and Performance, who will take action with managers to ensure that control changes are implemented quickly.

Facebook X-twitter Linkedin

Transforming Challenges into Opportunities in Underserved Markets

Transforming
Challenges into
Opportunities in
Underserved Markets

  • 2024

Join our newsletter

Subscribe to EmergX’s newsletter for exclusive updates, expert insights, and success stories. Be the first to know about new opportunities, events, and impact investing trends. Join us and be a catalyst for change.

  • 2024
  • 2024