Ethics, conduct and integrity policies · 04
Fraud prevention and response plan
Moves the organisation from intention to machinery: what is done to prevent fraud, what happens when it is suspected, and who decides.
Moves the organisation from intention to machinery: what is done to prevent fraud, what happens when it is suspected, and who decides.
Set out the fraud risk assessment and its cycle; the preventive controls mapped to the risks; detection routes including the whistleblowing channel and data analytics; the response protocol: who is told, who secures evidence, who suspends, who investigates and who may not; the decision on criminal and civil recovery and who takes it; and the reporting to the audit and risk committee.
The response protocol is the part that is always thin and always needed at speed. Name the roles now, because deciding who leads an investigation while it is running is how evidence is lost and how a subsequent dismissal becomes procedurally unfair.
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