National Assembly for Wales Governance and Audit. Fraud Response Plan

Similar documents
National Assembly for Wales Governance and Audit. Whistleblowing Policy

Anti-Fraud and Corruption Policy

ANTI-FRAUD, BRIBERY AND CORRUPTION POLICY

Fraud Prevention Policy

FRAUD & THEFT POLICY & RESPONSE PLAN

Finance Committee. Scrutiny of the Assembly Commission Draft Budget October National Assembly for Wales.

ANTI-BRIBERY POLICY AND ANTI-FRAUD POLICY AND RESPONSE PLAN

APPENDIX 2 CORPORATE ANTI-FRAUD AND CORRUPTION STRATEGY

Anti-fraud and Corruption Policy

Finance Committee. Report on the financial implications of the Proposed Safety on Learner Transport (Wales) Measure. December 2010

June 2017 Whistleblower Policy

CARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY PILLARS I, II AND III WHISTLEBLOWER POLICY

Policies, Procedures, Guidelines and Protocols

Anti-Fraud Policy. Version: 8.0 Approval Status: Approved. Document Owner: Graham Feek. Review Date: 07/12/2018

CORPORATE AFFAIRS POLICY

MyState Limited. Whistleblower Protection Policy

Financial implications of the Renting Homes (Fees etc.) (Wales) Bill

Research Briefing Budget Series 1: Funding Welsh devolution

To find out more about our accessible services please visit

FRAUD POLICY. Fraud is a serious matter and the Trust is committed to investigating all cases of suspected fraud.

THOMAS MILLS HIGH SCHOOL Whistleblowing Procedure Policy

Anti - Fraud and Corruption Policy

THOMAS MILLS HIGH SCHOOL. FINANCIAL PROBITY The School s Code of Standards and Practice

Special Compliance Office investigations

We, Our, the Institute means The Hong Kong Institute of Chartered Secretaries. means The Council of The Hong Kong Institute of Chartered Secretaries

Whistleblowing Policy

Agreement terms M&S CREDIT CARD. Key terms

ANTI BRIBERY FRAUD AND CORRUPTION. RES-CG-003-V02 Anti Bribary, Fraud and Corruption If printed this document is uncontrolled

ANTI-FRAUD, BRIBERY AND CORRUPTION POLICY AND STRATEGY THE VIEW TRUST

Local authority accounts: A guide to your rights

WHISTLE BLOWING POLICY AND PROCEDURE

OMAN ARAB BANK Whistle Blowing Guidelines WHISTLE BLOWING GUIDLINE. Version : 1.0

REGULATORY Code of practice

ANTI FRAUD POLICY AND FRAUD RESPONSE PLAN

ANTI-FACILITATION OF TAX EVASION POLICY

Archwilydd Cyffredinol Cymru Auditor General for Wales. Councils Accounts: Your Rights

Scrutiny of Welsh Government Second Supplementary Budget

The Co-operative Academies Trust Anti-Fraud and Anti-Bribery Policy. Approved by the Trust Board on 21 April 2016 Implementation from 22 April 2016

Your new Terms and Conditions

WHISTLEBLOWING POLICY

Policy 42 Anti-Fraud, Anti-Theft & Anti-Corruption

Labour Market Briefing

Sunway Construction Group Berhad

YourLife Plan Term Assurance

Risk Oversight Committee

Counter Theft, Fraud and Corruption Policy

Whistle-Blowing Policy

Welsh Government Housing Policy Regulation

Audit of financial statements: issues for the attention of the Audit Committee Cardiff and Vale NHS Trust

Report on the Environment (Wales) Bill

DIOCESAN EDUCATION SERVICE MODEL PUBLIC INTEREST DISCLOSURE (WHISTLEBLOWING) POLICY FOR VOLUNTARY AIDED CATHOLIC SCHOOLS

Whistleblowing Policy

first direct Credit Card Terms

Balance transfer made within 90 days of account opening. Balance transfer made within 90 days of account opening

Revenue Scotland Counter-Fraud Policy

WHISTLE BLOWER POLICY

POLICY. Tiger Brands Anti-Bribery and Anti-Corruption Policy

Governance. Board of Directors. Ion Spor, President Steven Reeve, Director Will Spence, Secretary Terry Good Greg Meeker. Conflict of Interest Policy

Policies, Procedures, Guidelines and Protocols

Personal Lending Products

ANNUAL CORRUPTION CASE REPORT 2016

Whistleblowing Policy & Procedures. GFH Financial Group

Whistleblowers Protection Act 2001 Policy and Procedures ABN

HSBC Premier World Elite Mastercard. Terms and conditions

first direct Credit Card Terms & first direct credit card Give me a break offer Terms and Conditions

CICM Professional Qualifications. Debt Collection Syllabus

Cases where Contract Disclosure Facilities (COP 9) are not used COP8

CANADA GOOSE HOLDINGS INC.

Unemployment Briefing

ANTI- FRAUD & WHISTLE-BLOWING POLICY November 2017

HSBC Premier Credit Card. Terms and conditions

MODEL CONTRACT FOR SPECIAL ADVISERS

Current Account Switch Service:

National Assembly for Wales Research paper. Final Budget November Research Service

Unemployment Briefing

first direct Single Trip and Annual Multi-trip Travel Insurance Important Information

WHISTLEBLOWING POLICY & PROCEDURE

GUIDANCE NOTE. Public Interest Disclosure (Whistleblowing)

THE KEMNAL ACADEMIES TRUST. Gifts and Hospitality Policy (including fraud, bribery and corruption)

Anti-facilitation of Tax Evasion Policy

POLICY (OPERATIONAL) FRAUD CONTROL

COLOUR JOB LOCATION: PRINERGY

Welsh Triathlon. Whistle Blowing Policy

Anti-Money Laundering Policy and Procedure


Research Briefing Carrier bag charges: frequently asked questions

Insurance Fraud Enforcement Department. Referral guide

Insurance 4 That Privacy Policy

WHISTLEBLOWER PROTECTION POLICY

Welsh Government Housing Policy Regulation

CBOE GLOBAL MARKETS, INC. AND SUBSIDIARIES CODE OF BUSINESS CONDUCT AND ETHICS. Adopted October 27, 2017

NN Group. Whistleblower. Policy. Version 2.3 Date September 2015 Department. Corporate Compliance

Sainsbury s Bank Online Saver Account Conditions

first direct Credit Card Terms & first direct Credit Card and Gold Card offer Terms and Conditions

METRO PERFORMANCE GLASS LIMITED (Metroglass) Share Trading Policy

Regulatory Notice 4: Regulation of newly registered providers up to 31 July 2019

Approval version. G l o b a l P o l i c y : F r a u d R e s p o n s e a n d W h i s t l e b l o w i n g P o l i c y. Board of Directors.

UNDERCOVER POLICING INQUIRY MANAGEMENT STATEMENT

SH FP 4. Version 2. Summary:

Annual Scrutiny of the Wales Audit Office and Auditor General for Wales

Transcription:

National Assembly for Wales Governance and Audit Fraud Response Plan

The National Assembly for Wales is the democratically elected body that represents the interests of Wales and its people, makes laws for Wales and holds the Welsh Government to account. A summary of this document can also be obtained in an accessible format such as braille, easy read, large print, audio or hard copy from: Assembly Communications National Assembly for Wales Cardiff Bay Cardiff CF99 1NA Online: www.assembly.wales Email: contact@assembly.wales Telephone: 0300 200 6565 We welcome calls via the Text Relay Service. National Assembly for Wales Commission Copyright 2015 The text of this document may be reproduced free of charge in any format or medium providing that it is reproduced accurately and not used in a misleading or derogatory context. The material must be acknowledged as copyright of the National Assembly for Wales Commission and the title of the document specified.

National Assembly for Wales Governance and Audit Fraud Response Plan

Contents Fraud Response plan... 1 Reporting a Fraud or Suspected Fraud:... 1 Responsibility for Investigation:... 1 Investigating a Fraud:... 1 Reporting to External Agencies:... 2 Post Investigation:... 2 ANNEX A Fraud Response Plan Dos and Don ts... 3 Do... 3 Don t... 3

Fraud Response plan Reporting a Fraud or Suspected Fraud: involving an employee or outside individual or organisation: If someone suspects that a fraud has occurred, he/she must report it immediately. They can do this either by the mechanisms set out in the Whistleblowing Policy or directly to one of the following people: Line Manager Head of Service; Director of Finance and Finance Team; and Chief Executive and Clerk. Additionally, staff must report all concerns to the Head of Internal Audit. However the fraud is reported the person reporting the fraud receives the same protections that apply to anyone making a disclosure under the Whistleblowing Policy. Involving an Assembly Member In these cases, the Chief Executive and Clerk must be informed and will initiate any investigation. Responsibility for Investigation: Once a fraud has been reported, the overall responsibility for investigation lies with the Head of Internal Audit. The Head of Internal Audit may then utilise the skills and expertise of suitably qualified staff in order to undertake detailed investigations and this may include the Director of Finance and the Finance Team. In the event that the fraud involves the Head of Internal Audit, the overall responsibility lies with the Chief Executive and Clerk. The Chief Executive and Clerk will retain overall responsibility for any investigation involving an Assembly Member. Investigating a Fraud: Reports of fraud or suspected fraud will always be investigated. The details of an investigation will vary depending on the scale and nature of the fraud and on the person(s) implicated. However, the following principles will apply to cases involving employees or outside persons and organisations. The Head necessary to suspend a member of staff while an investigation is conducted, this will be done via normal HR procedures. 1

Reporting to External Agencies: Sometimes it may be necessary to involve outside agencies in the investigation. Card Provider any fraud involving a credit card must be reported to the card provider. The Police - where there is evidence that a fraud has been committed against the National Assembly, the matter will normally be reported to the Police except when the fraud involves a credit card and the card provider decides to investigate the matter. External Audit (WAO) all staff must co-operate fully with any external audit enquiries, which may have to take precedence over any internal investigation or disciplinary process. However, where possible, investigation teams will co-ordinate their enquiries to maximise the effective and efficient use of resources and information. Post Investigation: On conclusion of an investigation, and once evidence of a fraud is established, the following steps will normally follow: Disciplinary action against member of staff in line with HR procedures, or other appropriate action against any external third party; Management Review* of the circumstances surrounding the fraud to identify if changes need to be made to procedures to strengthen the system of control and prevent a recurrence; Management Review* of the extent to which the individual(s) involved in the fraud may have been involved in any other fraudulent activity; Report to the Audit and Risk Assurance Committee at their next meeting. *The Chief Executive and Clerk will discuss with the Head of Internal Audit and the Chair of the Audit and Risk Assurance Committee the extent to which Internal Audit should be involved in the Management Review. 2

ANNEX A Fraud Response Plan Dos and Don ts Do Make a note of your concerns: record all relevant details, such as the nature of your concern, the names of parties you believe to be involved, details of any telephone or other conversations with names, dates and times and any witnesses; notes do not need to be overly formal, but should be timed, signed and dated; timeliness is most important. The longer you delay writing up, the greater the chances of recollections becoming distorted and the case being weakened. Retain any evidence you may have: the quality of evidence is crucial and the more direct and tangible the evidence, the better the chances of an effective investigation. Report your suspicions promptly: in the first instance, report your suspicions to your line manager. If this action would be inappropriate, further guidance on disclosure can be found in the Fraud and Bribery Response Plan (above) and the Assembly Commission Whistleblowing Policy (on intranet); additionally, all concerns must be reported to the Head of Internal Audit. Don t Be afraid of raising your concerns: the Public Interest Disclosure Act provides protection for employees who raise reasonably held concerns through the appropriate channels (Whistleblowing); you will not suffer discrimination or victimisation as a result of following these procedures and the matter will be treated sensitively and confidentially. Convey your concerns to anyone other than authorised persons: there may be a perfectly reasonable explanation for the events that give rise to your suspicion. Spreading unsubstantiated concerns may harm innocent persons. Approach the person you suspect or try to investigate the matter yourself: there are special rules relating to the gathering of evidence for use in criminal cases. Any attempt to gather evidence by persons who are unfamiliar with these rules may destroy the case. 3