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Your 10-point plan on how to combat fraud and corruption in your organisation

Effective management of fraud and corruption risks should focus on the key areas of prevention, detection and response. The unfortunate reality is that perpetrators of fraud are constantly adapting their approach and managing the risk of fraud within organisations requires constant monitoring and assessment.”

There are specific requirements that all organisations should take note of in their formulation of a sound foundation for managing fraud and corruption risks and this foundation requires augmentation in respect of organisation specific environments.

As a minimum, organisations should have all of the measures below in place (this list is not exhaustive and serves as a foundation for managing fraud and corruption risks):

  1. Embed an effective fraud prevention strategy: Ensure that there is an approved Fraud Prevention Strategy, Protected Disclosures Policy, Conflict of Interest Policy, Anti- Bribery and Corruption Policy and Fraud Response Plan (including cyber-incident response), which are clearly articulated, implemented and communicated throughout  the  organisation.
  2. Implement a tiered approach: Implement a three-tier approach to reducing fraud and corruption, which should include essential elements of prevention, response and detection.
  3. Effective fraud risk assessments: Initiate on-going Fraud Risk Assessments (including assessment of cyber-related risks), which are a non-negotiable element of mitigating the risks of fraud; these should be conducted at an Enterprise and Business Unit level.
  4. Optimise the use of technology in detecting fraud: Leverage technology in order to implement Continuous Control Monitoring measures through Forensic Data Analytics aimed at the early detection of fraud and corruption risk indicators.
  5. Assessing employee awareness: Conduct an annual online Fraud Health Check survey amongst employees, which should ideally be anonymous in nature.
  6. Eliminating conflicts of interests: Manage the risk of Conflicts of interest through implementation of an auditable declaration process where all declarations are assessed and verified.
  7. Managing relationships with external stakeholders: Discourage/prohibit the receipt of gifts from suppliers as this alleviates the risk of potential irregularities and furthermore reduces the administration of any gift register.
  8. Know your business partners: Supplier vetting should entail stringent verification and approval measures, including a Conflict of Interest Declaration.
  9. Creating awareness: Fraud Awareness and Anti- Fraud Education should be consistently applied throughout the organisation and a continuous basis.
  10. Inform employees how to raise concerns: Organisations should ensure all employees know the policy for making protected disclosures under the Protected Disclosure Act 2014. 

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