{"id":596,"date":"2022-04-16T11:40:29","date_gmt":"2022-04-16T07:40:29","guid":{"rendered":"http:\/\/iepf-ngo.org\/en\/iepf-anti-fraud-bribery-and-corruption-policy\/"},"modified":"2022-04-16T11:40:29","modified_gmt":"2022-04-16T07:40:29","slug":"iepf-anti-fraud-bribery-and-corruption-policy","status":"publish","type":"post","link":"https:\/\/iepf-ngo.org\/en\/iepf-anti-fraud-bribery-and-corruption-policy\/","title":{"rendered":"IEPF: Anti-Fraud, Bribery and Corruption Policy"},"content":{"rendered":"

\n\t <\/span><\/p>\n

\n\t <\/span>Introduction<\/p>\n

\n\tInternational Eurasia Press Fund Anti-Fraud, Bribery and Corruption Policy is designed to promote an anti-fraud culture and consistent organisational behaviour across the company when dealing with cases of suspected fraud, bribery or corruption. It sets out responsibilities for fraud prevention and detection and provides clear guidelines and procedures for reporting cases of suspected fraud and corruption and for the conduct of investigations.<\/p>\n

\n\tDefinitions<\/span><\/h1>\n

\n\tFraud<\/h2>\n

\n\tThe Fraud Act 2006 established three main offences of fraud, all of which carry a maximum sentence of 10 years and\/or an unlimited fine. The offences are:<\/p>\n

    \n
  • \n

    \n\t\t\tfraud by false representation<\/p>\n<\/li>\n

  • \n

    \n\t\t\tfraud by failing to disclose information or<\/p>\n<\/li>\n

  • \n

    \n\t\t\tfraud by abuse of position.<\/p>\n<\/li>\n<\/ul>\n

    \n\tThe following actions are among those which fall within the definition of fraud:<\/p>\n

      \n
    • \n

      \n\t\t\ttheft of company property, including information<\/p>\n<\/li>\n

    • \n

      \n\t\t\tmisappropriation or use of company assets for personal gain<\/p>\n<\/li>\n

    • \n

      \n\t\t\tfalse accounting \u2013 dishonestly destroying, defacing, concealing or falsifying any account, record or document required for any accounting purpose<\/p>\n<\/li>\n

    • \n

      \n\t\t\tforgery or alteration of company documents<\/p>\n<\/li>\n

    • \n

      \n\t\t\twilful destruction or removal of company records<\/p>\n<\/li>\n

    • \n

      \n\t\t\tany computer- related activity involving the alteration, destruction, forgery or manipulation of data for fraudulent purposes or misappropriation of International Eurasia Press Fund- owned software<\/p>\n<\/li>\n

    • \n

      \n\t\t\tfalsification of travel and subsistence claims<\/p>\n<\/li>\n

    • \n

      \n\t\t\tknowingly generating or paying false claims or invoices<\/p>\n<\/li>\n

    • \n

      \n\t\t\tunauthorised disclosure of confidential information to third parties e.g. confidential details of current business activities or of bids or activities that the company is contemplating.<\/p>\n<\/li>\n<\/ul>\n

      \n\tBribery<\/h2>\n

      \n\tBribery is the offer, promise, giving, demanding or acceptance of an advantage as an inducement for action which is illegal, unethical or a breach of trust.<\/p>\n

      \n\tBribes can take many different forms, but typically they involve corrupt intent. A bribe could be:<\/p>\n

        \n
      • \n

        \n\t\t\tthe direct or indirect promise of anything of value<\/p>\n<\/li>\n

      • \n

        \n\t\t\tthe offer of a fee, reward or other advantage<\/p>\n<\/li>\n

      • \n

        \n\t\t\tthe giving of a donation.<\/p>\n<\/li>\n<\/ul>\n

        \n\tCorruption<\/h2>\n

        \n\tCorruption is the misuse of power for private gain.<\/p>\n

        \n\tThe Bribery Act makes bribery and corruption a criminal offence and holds companies liable for failing to prevent acts of bribery or corruption by those working for or on its behalf, no matter where the act takes place. <\/p>\n

        \n\tPolicy Scope<\/span><\/h1>\n

        \n\tThis policy applies to all International Eurasia Press Fund directors and staff, whether permanent, fixed term, or temporary and to any consultants and sub-contractors working on IEPF behalf.<\/p>\n

        \n\tPolicy Statement<\/span><\/h1>\n

        \n\tIEPF expects high standards of conduct and probity from all of its directors and staff and requires them at all times to act honestly, with integrity and to safeguard the resources for which they are responsible. The company also expects its suppliers, delivery partners and sub-contractors to maintain the same high standards of conduct and probity.<\/p>\n

        \n\tInternational Eurasia Press Fund is committed to developing an anti-fraud culture and actively seeks to deter and prevent fraud and corruption by ensuring that risks are identified and managed effectively. The company will not accept any level of fraud, bribery or corruption and will investigate thoroughly all suspected cases. Staff involved in an impropriety of any kind will be subject to the company\u2019s disciplinary procedures and legal action will be taken where appropriate.<\/p>\n

        \n\tTo ensure that this policy is implemented effectively, IEPF will:<\/p>\n

          \n
        • \n

          \n\t\t\tidentify and include fraud and corruption risks within its risk management processes<\/p>\n<\/li>\n

        • \n

          \n\t\t\tdevelop and maintain appropriate control systems to reduce the risk of fraud and corruption<\/p>\n<\/li>\n

        • \n

          \n\t\t\tencourage a culture of prevention and deterrence<\/p>\n<\/li>\n

        • \n

          \n\t\t\tensure that responsibilities are clearly defined and communicated at all levels<\/p>\n<\/li>\n

        • \n

          \n\t\t\tencourage staff and others to be vigilant and report any genuine suspicions of fraudulent activity (see International Eurasia Press Fund Confidential Disclosure (\u2018Whistleblowing\u2019) Policy)<\/p>\n<\/li>\n

        • \n

          \n\t\t\tensure that if a fraud occurs, a prompt and thorough investigation takes place, without regard to position held or length of service of employees concerned<\/p>\n<\/li>\n

        • \n

          \n\t\t\ttake appropriate disciplinary and legal action in all cases, where justified<\/p>\n<\/li>\n

        • \n

          \n\t\t\treview systems and procedures to prevent similar fraud should a fraud occur<\/p>\n<\/li>\n

        • \n

          \n\t\t\tensure that anti-fraud considerations are built into tendering and sub-contracting processes.<\/p>\n<\/li>\n<\/ul>\n

          \n\tRoles and Responsibilities<\/h1>\n

          \n\tThe Risk Management officers hold overall responsibility for International Eurasia Press Fund corporate anti-fraud policy and procedures. They are responsible for establishing and maintaining a sound system of internal control to manage the whole range of risks that the organization might faces. An Audit Committee, made up of at least 3 non-executive directors appointed by the Board, is responsible for reviewing the effectiveness of the company\u2019s internal controls and risk management systems, the Confidential Disclosure (\u2018Whistleblowing\u2019) Policy and company procedures for detecting fraud.<\/p>\n

          \n\tChief Executive Officer Responsibilities<\/p>\n

          \n\tIn addition to the roles and responsibilities defined within Annex 1, the Chief Executive Officer is responsible for:<\/p>\n

            \n
          • \n

            \n\t\t\tidentification and evaluation of risks and risk management<\/p>\n<\/li>\n

          • \n

            \n\t\t\tnotifying supply\u2013chain partners\/sub-contractors of the nature of any investigation relating to a case of suspected fraud involving one or more of their employees.<\/p>\n<\/li>\n

          • \n

            \n\t\t\treporting significant incidents of fraud to the International Eurasia Press Fund Board (for example, where a significant sum of money is involved or if there is likely to be public interest because of the nature of fraud).<\/p>\n<\/li>\n<\/ul>\n

            \n\tGroup Finance Director Responsibilities<\/h2>\n

            \n\tIn addition to the roles and responsibilities defined within Annex 1, the Group Finance Director is responsible for:<\/p>\n

              \n
            • \n

              \n\t\t\tidentification and evaluation of risks and risk management<\/p>\n<\/li>\n

            • \n

              \n\t\t\tdeveloping and implementing fraud prevention and detection measures<\/p>\n<\/li>\n

            • \n

              \n\t\t\tthe regular review of the company\u2019s financial regulations and accounting procedures<\/p>\n<\/li>\n

            • \n

              \n\t\t\tarranging for the internal audit of the company\u2019s financial regulations and accounting procedures to ensure compliance<\/p>\n<\/li>\n

            • \n

              \n\t\t\tproviding advice and assistance to managers on control issues.<\/p>\n<\/li>\n<\/ul>\n

              \n\tCompany Risk Officer Responsibilities<\/h2>\n

              \n\tIn addition to the roles and responsibilities defined within Annex 1, the Company Risk Officer is responsible for:<\/p>\n

                \n
              • \n

                \n\t\t\tdevelopment and regular review of the Anti-fraud, Bribery and Corruption policy<\/p>\n<\/li>\n

              • \n

                \n\t\t\tensuring that all managers and staff are aware of IEPF Anti-fraud, Bribery and Corruption Policy through the dissemination of information and provision of relevant training<\/p>\n<\/li>\n

              • \n

                \n\t\t\tproviding advice and assistance to managers in the application of the policy should a case of suspected fraud occur<\/p>\n<\/li>\n

              • \n

                \n\t\t\theading up an investigation team in response to a report of suspected fraud, when required to do so by the Risk Management Incident Group.<\/p>\n<\/li>\n

              • \n

                \n\t\t\treporting to the Risk Management Incident Group on the progress of any investigation.<\/p>\n<\/li>\n<\/ul>\n

                \n\tOperations Directors\/Managers & Other Contract Manager Responsibilities<\/span><\/strong><\/h2>\n
                  \n
                • \n

                  \n\t\t\tensuring that all staff are familiar with the Anti-fraud, Bribery and Corruption Policy<\/p>\n<\/li>\n

                • \n

                  \n\t\t\tidentifying the risks involved in the contracts for which they are responsible<\/p>\n<\/li>\n

                • \n

                  \n\t\t\tdeveloping the local control systems necessary to prevent and detect fraud<\/p>\n<\/li>\n

                • \n

                  \n\t\t\treviewing and testing regularly the control systems for which they are responsible to ensure they are operating effectively<\/p>\n<\/li>\n

                • \n

                  \n\t\t\tensuring that staff have received appropriate training on control systems and that controls are complied with<\/p>\n<\/li>\n

                • \n

                  \n\t\t\tnotifying the Company Risk Officer when any case of suspected fraud is reported to them<\/p>\n<\/li>\n

                • \n

                  \n\t\t\tensuring that delivery partners and sub-contractors have an anti-fraud policy and procedures in place and meet the contractual requirements relating to the prevention of fraud and dealing with suspected incidents of fraud<\/p>\n<\/li>\n

                • \n

                  \n\t\t\tassist sub-contractors in developing appropriate controls systems to prevent and detect fraud if appropriate<\/p>\n<\/li>\n

                • \n

                  \n\t\t\tensuring that the staff of any sub-contractors involved in the delivery of a contract, are aware of anti-fraud policies and procedures<\/p>\n<\/li>\n

                • \n

                  \n\t\t\tensuring that audits of contracts with sub-contractors include compliance with anti-fraud policies and procedures.<\/p>\n<\/li>\n<\/ul>\n

                  \n\tDirector of Marketing and Communications Responsibilities<\/span><\/strong><\/h2>\n

                  \n\tIn addition to the roles and responsibilities defined within Annex 1, the Director of Marketing & Communications is responsible for:<\/p>\n

                    \n
                  • \n

                    \n\t\t\tresponding to media enquiries which may arise from a case of fraud or corruption.<\/p>\n<\/li>\n<\/ul>\n

                    \n\tCompany Solicitor Responsibilities<\/span><\/strong><\/h2>\n

                    \n\tIn addition to the roles and responsibilities defined within Annex 1, the Company Solicitor is responsible for:<\/p>\n

                      \n
                    • \n

                      \n\t\t\ttaking appropriate legal action against perpetrators of fraud<\/p>\n<\/li>\n

                    • \n

                      \n\t\t\tseeking the repayment of losses to the company and the recovery of any costs.<\/p>\n<\/li>\n<\/ul>\n

                      \n\tGroup HR Business Partner Responsibilities<\/span><\/strong><\/h2>\n
                        \n
                      • \n

                        \n\t\t\tensuring that disciplinary action is taken against perpetrators of fraud<\/p>\n<\/li>\n

                      • \n

                        \n\t\t\tpreparing the response to requests for references for any member (or former member) of staff who has been disciplined or prosecuted for fraud.<\/p>\n<\/li>\n<\/ul>\n

                        \n\tAll Staff Members are responsible for:<\/span><\/strong><\/h2>\n
                          \n
                        • \n

                          \n\t\t\tbeing alert to the possibility of fraud and taking special care if unusual events or transactions occur<\/p>\n<\/li>\n

                        • \n

                          \n\t\t\treporting details immediately if they suspect that fraud is taking\/has taken place or if they see any suspicious acts or events (see procedure below)<\/p>\n<\/li>\n

                        • \n

                          \n\t\t\tco-operating fully with any internal checks, reviews or investigations<\/p>\n<\/li>\n

                        • \n

                          \n\t\t\tco-operating fully with audit or investigation by external bodies such as HM Revenue and Customs and contracting bodies who may invoke their right to conduct audits as set out in the contract between the contracting body and IEPF<\/p>\n<\/li>\n<\/ul>\n

                          \n\t <\/p>\n

                          \n\tConflicts of Interest<\/span><\/strong><\/h1>\n

                          \n\tEmployees are required to fully disclose any situation in which his or her personal interests may conflict with those of the company.<\/p>\n

                          \n\tAny employee who is, or might be influenced by personal considerations which may hinder objective decision-making must seek advice from an appropriate senior manager. The Procurement of Supplies & Services Policy & Framework refers.<\/p>\n

                          \n\tGifts and Hospitality<\/span><\/strong><\/h1>\n

                          \n\tEmployees and their families must not accept, directly or indirectly, any money, gifts or hospitality which could influence or appear to influence decisions they make on behalf of the company. Staff responsible for the purchase of supplies, equipment or services must take particular care to ensure that there can be no criticism that unequal treatment has been given to suppliers involved in tendering processes, through the acceptance of gifts or other benefits. Employees who are offered a gift as an inducement for preferential treatment must decline or return it as appropriate, with a suitably courteous letter explaining company policy.<\/p>\n

                          \n\tEmployees should not give any gift or hospitality with the expectation that they and\/or the company will benefit from it, since this may constitute a bribe.The acceptance and\/or offer of small gifts and\/or casual hospitality such as business lunches, dinners or invitations to events, is acceptable within reasonable grounds, as long as it is a normal and appropriate expression of business courtesy and that the recipient is not placed under any obligation. If a member of staff is in any doubt as to the propriety of giving or receiving any gift or hospitality then he\/she must consult his\/her line manager. The Procurement of Supplies & Services Policy & Framework refers.<\/p>\n

                          \n\tCorruption and National or Local Government Officials<\/span><\/strong><\/h1>\n

                          \n\tContacts with and\/or gifts to or from national or local government officials can be particularly sensitive. Employees must not offer or provide, either directly or indirectly, any pecuniary or other advantage to or for a public or corporate official in order to obtain or retain business or secure any improper business advantage. Any employee who is asked by a government or corporate official to circumvent these rules must immediately report the matter to the Managing Director.<\/p>\n

                          \n\tPolitical Contributions<\/span><\/strong><\/h1>\n

                          \n\tEmployees should not make any contributions to either individual politicians or political parties in order to secure political or commercial influence on behalf of the company. (This does not preclude private donations to political parties made by individual employees which otherwise would be lawful).<\/p>\n

                          \n\tAnti – Fraud Arrangements with Sub-Contractors\/ Delivery Partners<\/span><\/strong><\/h1>\n

                          \n\tIEPF expects its sub-contractors and delivery partners to maintain high standards of conduct and probity and to have in place anti-fraud processes similar to those of the organization. All of the IEPF sub-contractors should therefore be required to:<\/p>\n

                            \n
                          • \n

                            \n\t\t\thave in place anti-fraud and confidential disclosure (\u2018whistleblowing\u2019) policies and procedures<\/p>\n<\/li>\n

                          • \n

                            \n\t\t\timmediately report any case of suspected fraudulent activity by its employees to the IEPF Operations Director responsible for the contract, who will then initiate an investigation following the procedures outlined in this policy<\/p>\n<\/li>\n

                          • \n

                            \n\t\t\timmediately suspend any member of staff who is suspected of fraud<\/p>\n<\/li>\n

                          • \n

                            \n\t\t\tensure that all its employees are informed about and have access to its anti-fraud and confidential disclosure (\u2018whistleblowing\u2019) policies.<\/p>\n<\/li>\n<\/ul>\n

                            \n\tWhere necessary, The International Eurasia Press Fund will assist providers in developing appropriate control systems to prevent and detect fraud when appropriate. Where a potential sub-contractor is judged to have inadequate processes and is unwilling to commit to the IEPF standards, IEPF will not proceed to contract with that provider.<\/p>\n

                            \n\tReporting a Suspicion of Fraud<\/span><\/strong><\/h1>\n

                            \n\tFraud may be discovered in a number of ways, including the following:<\/p>\n

                              \n
                            • \n

                              \n\t\t\tThrough planned audit work<\/p>\n<\/li>\n

                            • \n

                              \n\t\t\tThrough the operation of management and control procedures<\/p>\n<\/li>\n

                            • \n

                              \n\t\t\tA concern may be raised by a member of the public<\/p>\n<\/li>\n

                            • \n

                              \n\t\t\tA concern may be raised by an employee.<\/p>\n<\/li>\n<\/ul>\n

                              \n\tStaff are encouraged to report any suspicion of fraud, bribery or corruption or any other form of malpractice. The Confidential Disclosure (\u2018Whistleblowing\u2019) Policy makes clear that staff can report suspicions confidentially and without fear of victimisation or subsequent discrimination or disadvantage, whatever the outcome of an investigation.<\/p>\n

                              \n\tProcedure \u2013 Reporting a Suspicion of Fraud<\/span><\/strong><\/h1>\n

                              \n\tPlease see Annex 1<\/p>\n

                              \n\tCommunication and Training<\/span><\/strong><\/h1>\n

                              \n\tThis policy is communicated to all staff via the normal company channels, including Prospectus and the company intranet and is introduced to all new staff at induction.<\/p>\n

                              \n\t <\/p>\n

                              \n\tInternal Controls and Audit<\/span><\/strong><\/h1>\n

                              \n\tInternal control systems are subject to regular audits to provide assurance that they are effective in countering fraud, bribery and corruption.  The company\u2019s external auditors review the internal financial control systems on an annual basis as part of their statutory audit. Any control issues arising or recommendations for improvement are set out in the Key Issues Memorandum which is presented by the external auditors to the Audit Committee. Internal audits of the company\u2019s financial controls are carried out periodically by senior members of the finance team and the Company Risk Officer who are not directly involved in the area being reviewed.<\/p>\n

                              \n\tReview<\/h1>\n

                              \n\tThis policy is reviewed every year or in the event of any change in related government policy.<\/p>\n

                              \n\t <\/p>\n

                              \n\tAnnex 1<\/span><\/p>\n

                              \n\tRisk Management Response Plan<\/span><\/strong><\/h1>\n

                              \n\tInitial Response<\/p>\n

                              \n\tAny suspicion of fraud, bribery and corruption (whether perpetrated by a member of the International Eurasia Press Fund staff or by a third party) must be reported without delay to a manager who without delay should escalate to the Company Risk Officer. No investigations should be undertaken at a local level by managers or other staff. Internal investigations could be counterproductive to the investigative process and hamper efforts to promote an independent and transparent process.  The Company Risk Officer in discussion with  senior managers will make an initial assessment as to the level of seriousness and apply a RAG status.  The RAG status will dictate immediate actions. The Company Risk Officer may seek advice prior to applying a RAG status from the Chief Executive Officer.<\/p>\n

                              \n\t <\/p>\n\n\n\n\n\n\n
                              \n

                              \n\t\t\t\t\tRAG STATUS<\/span><\/p>\n<\/td>\n

                              		\n

                              \n\t\t\t\t\tDESCRIPTION<\/span><\/p>\n<\/td>\n<\/tr>\n

                              \n

                              \n\t\t\t\t\t <\/p>\n

                              \n\t\t\t\t\tRED<\/p>\n

                              \n\t\t\t\t\t <\/p>\n<\/td>\n

                              		\n

                              \n\t\t\t\t\t <\/p>\n

                              \n\t\t\t\t\tSerious incident that requires escalation to the Risk Management Incident Group.<\/p>\n<\/td>\n<\/tr>\n

                              \n

                              \n\t\t\t\t\t <\/p>\n

                              \n\t\t\t\t\tAMBER<\/p>\n

                              \n\t\t\t\t\t <\/p>\n<\/td>\n

                              		\n

                              \n\t\t\t\t\t <\/p>\n

                              \n\t\t\t\t\tHas the potential to be serious incident but requires further investigation prior to possible escalation and notification to the Risk Management Incident Group.<\/p>\n

                              \n\t\t\t\t\t <\/p>\n<\/td>\n<\/tr>\n

                              \n

                              \n\t\t\t\t\t <\/p>\n

                              \n\t\t\t\t\tGREEN<\/p>\n<\/td>\n

                              		\n

                              \n\t\t\t\t\t <\/p>\n

                              \n\t\t\t\t\tIs not deemed serious or time sensitive.  Expected outcome poses no risk to staff, property or company reputation. Does not require notification to the Risk Management Incident Group.<\/p>\n

                              \n\t\t\t\t\t <\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                              \n\t <\/p>\n

                              \n\tRisk Escalation<\/h2>\n

                              \n\tAt any time during an investigation the initial risk status may escalate (or deescalate) at which time the Company Risk Officer will notify, in liaison with Risk Management team senior managers, the Chief Executive Officer.<\/p>\n

                              \n\t <\/p>\n

                              \n\tRisk Management Incident Group<\/span><\/strong><\/h2>\n

                              \n\tAll amber and red incidents will be reported to the Chief Executive Officer. The Chief Executive Officer will convene the group and lead meetings as appropriate.<\/p>\n

                              \n\tThe Risk Management Incident Group comprises key company stakeholders best placed to advise, direct and manage serious incidents.  All members or a combination of representatives may be called upon.<\/p>\n

                              \n\tThe Risk Management Incident Group will determine what immediate action should be taken, for example, whether the matter should be immediately reported to the police and how the investigation will proceed.<\/p>\n

                              \n\t <\/p>\n

                              \n\tThe Investigation Process<\/strong><\/span><\/h2>\n

                              \n\tThe investigation process will vary according to the circumstances of the case. In cases judged to be fairly minor (RAG status Green), the Company Risk Officer or a member of the crusial department, who has undergone investigation training, will undertake an investigation and present a report along with recommendations, to a nominated senior manager. In more serious cases (RAG status Amber or Red), the Risk Management Incident group will appoint a team, led by the Company Risk Officer, which may include external specialists as deemed appropriate. Any member of staff who is asked to join an investigation team will be required to do so with immediate effect. All staff are expected to cooperate with any investigation, where required.<\/p>\n

                              \n\tDuties of the Company Risk Officer<\/span><\/strong><\/h2>\n
                                \n
                              • \n

                                \n\t\t\tWith the senior managers undertake an initial risk assessment to establish the RAG status of the incident<\/p>\n<\/li>\n

                              • \n

                                \n\t\t\tUndertake an initial report to the Chief Executive Officer and incident group as appropriate<\/p>\n<\/li>\n

                              • \n

                                \n\t\t\tGather relevant evidence and maintain detailed records, including a chronological record detailing all telephone conversations, discussions, meetings and interviews<\/p>\n<\/li>\n

                              • \n

                                \n\t\t\tIn collaboration with the Risk Management Incident Group, report the incident to the police where appropriate and maintain contact with the police as necessary.<\/p>\n<\/li>\n

                              • \n

                                \n\t\t\tLiaise with the Company Solicitor to obtain legal advice where necessary on the recovery of losses.<\/p>\n<\/li>\n

                              • \n

                                \n\t\t\tReport regularly to the Risk Management Incident Group on the progress of the investigation (at least monthly for ongoing investigations) The reports should include the following:<\/p>\n<\/li>\n

                              • \n

                                \n\t\t\tValue of the company\u2019s losses<\/p>\n<\/li>\n

                              • \n

                                \n\t\t\tEstimated resources required and timescale to conclude the investigation<\/p>\n<\/li>\n

                              • \n

                                \n\t\t\tRecommended actions to be taken to prevent and detect similar incidents.<\/p>\n<\/li>\n

                              • \n

                                \n\t\t\ton completion of an investigation, submit an Incident Investigation Report to the Risk Management Incident group, including a full description of the incident (including the value of any loss, the people involved and the means of perpetrating the fraud) and the measures taken to prevent a recurrence<\/p>\n<\/li>\n

                              • \n

                                \n\t\t\tProvide recommendations for any further action needed to strengthen future responses to incidents of a similar nature.<\/p>\n<\/li>\n

                              • \n

                                \n\t\t\tReport to the company audit committee<\/p>\n<\/li>\n<\/ul>\n

                                \n\tDuties of the Risk Management Incident Group<\/p>\n

                                  \n
                                • \n

                                  \n\t\t\tLiaise with the relevant Operations Director in respect of notifying the funder as required by the contract (see \u2018Notifying the funder\u2019 below).<\/p>\n<\/li>\n

                                • \n

                                  \n\t\t\tIdentify any disciplinary action required<\/p>\n<\/li>\n

                                • \n

                                  \n\t\t\tIdentify any criminal proceedings to be taken<\/p>\n<\/li>\n<\/ul>\n

                                  \n\tGathering and Securing Evidence<\/h2>\n

                                  \n\tThe Company Risk Officer should maintain a chronological record of events, giving a full explanation of each action and event during the course of the investigation. As considerable time may elapse between the start and conclusion of the investigation, it is important that a detailed record is maintained to aid recall to all relevant events. A successful criminal prosecution may also depend on these details. The following should be logged:<\/p>\n

                                    \n
                                  • \n

                                    \n\t\t\tDetails of all telephone calls, faxes, e-mail and any other forms of communication<\/p>\n<\/li>\n

                                  • \n

                                    \n\t\t\tA formal record of all interviews and meetings<\/p>\n<\/li>\n

                                  • \n

                                    \n\t\t\tA clear record of where and how documents and other evidence were obtained.<\/p>\n<\/li>\n

                                  • \n

                                    \n\t\t\tAll evidence should be stored with consideration to Home Office Guidance, Data Protection Act.<\/p>\n<\/li>\n<\/ul>\n

                                    \n\tWhere there is a possibility of subsequent criminal proceedings, the Risk Management Incident Group will nominate the Company Risk Officer to refer the matter to the police and seek advice from them on the conduct of internal enquiries, to ensure that any potential criminal case is not prejudiced.<\/span><\/span><\/p>\n

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                                    \n\tGuidelines for Conducting Investigation Interviews<\/h2>\n

                                    \n\tAs part of an Amber or Red Status risk investigation, the Company Risk Officer will need to interview member(s) of staff under investigation and other members of staff who may be witnesses to or able to help establish the facts. During interviews the investigating officer should adopt the following best practice:<\/p>\n

                                      \n
                                    • \n

                                      \n\t\t\tHave an interview plan before the meeting to ensure the key issues are covered.<\/p>\n<\/li>\n

                                    • \n

                                      \n\t\t\tArrange for an appropriately trained member of investigation team to attend the interview and ask them to take detailed notes.<\/p>\n<\/li>\n

                                    • \n

                                      \n\t\t\tConduct interviews in an independent and professional manner.<\/p>\n<\/li>\n

                                    • \n

                                      \n\t\t\tAsk only questions relevant to the investigation.<\/p>\n<\/li>\n

                                    • \n

                                      \n\t\t\tDo not ask leading questions or subject the interviewee to harassment or intimidation.<\/p>\n<\/li>\n

                                    • \n

                                      \n\t\t\tPrepare a type written statement of the interview, recording all salient points and wherever possible record direct speech by the investigator and the person making the statement.<\/p>\n<\/li>\n

                                    • \n

                                      \n\t\t\tAsk the interviewee to read the statement, to make any corrections or additions to the statement and to sign the statement at the end to say it is a true and correct record of the interview.<\/p>\n<\/li>\n

                                    • \n

                                      \n\t\t\tTreat reports and statements as \u2018Restricted\u2019 documents and share them only with members of the Risk Management Incident Group and the police, where appropriate and where directed. The Chief Executive Officer and\/or the Risk Management Incident Group may decide the appropriateness of sharing these documents with other company employees i.e. HR managers.<\/p>\n<\/li>\n<\/ul>\n

                                      \n\tSuspending Staff under Investigation<\/span><\/strong><\/h2>\n

                                      \n\tWhere initial investigation provides reasonable grounds for suspecting a member of staff of fraud, theft, bribery or corruption, the Risk Management Incident Group will take steps to prevent any further loss. It may be appropriate to suspend the suspect(s) pending the outcome of the investigation.<\/p>\n

                                      \n\tIn these circumstances, the suspect(s) should be:<\/p>\n

                                        \n
                                      • \n

                                        \n\t\t\tApproached sensitively (unannounced) in a confidential space<\/p>\n<\/li>\n

                                      • \n

                                        \n\t\t\tSupervised at all times by a member of the Senior Management Team before leaving company or sub-contractor premises, to prevent them from destroying or removing any evidence.<\/p>\n<\/li>\n

                                      • \n

                                        \n\t\t\tAllowed to collect personal property under supervision, but should not be able to remove any property or records belonging to the company, sub-contractor or programme.<\/p>\n<\/li>\n

                                      • \n

                                        \n\t\t\tRequired to immediately return any keys to premises, security passes, laptop computers, memory sticks, mobile devices and files including diaries and address books in their possession.<\/p>\n<\/li>\n

                                      • \n

                                        \n\t\t\tDenied any unsupervised access to the company\u2019s premises whilst they remain suspended.<\/p>\n<\/li>\n

                                      • \n

                                        \n\t\t\tDenied access to the company\u2019s ICT systems whilst they remain suspended.<\/p>\n<\/li>\n

                                      • \n

                                        \n\t\t\tRequired not to make contact with other staff in relation to the investigation.<\/p>\n<\/li>\n<\/ul>\n

                                        \n\tNotifying the Funder<\/h2>\n

                                        \n\tPost consultation with the Risk Management Incident Group, notification to the funding organisation about actual or suspected fraud should commence where necessary. International Eurasia Press Fund\u2019 contractual obligations with regards to reporting are detailed within the various contracts and guidelines. The relevant Operations Directors hold copies of these and must follow the required protocol, liaising with contract managers throughout the process. If there are any doubts, the Operations Director should seek advice from the Company Solicitor and the Managing Director. The Executive Board and\/or Chief Executive Officer may wish to seek external legal advice.<\/p>\n

                                        \n\tMedia Enquiries<\/span><\/strong><\/h2>\n

                                        \n\tAny media response plan should be agreed by the Risk Management Incident Group.<\/p>\n

                                        \n\tEnquiries from the media in respect of any case of fraud, theft, bribery or corruption should be referred to the Director of Marketing and Communications (and in their absence the Chief Executive Officer or somebody nominated by the Executive Board who has undertaken company media training) who will make any statement to the media.<\/p>\n

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                                        \n\t <\/span> <\/span><\/p>\n","protected":false},"excerpt":{"rendered":"

                                           Introduction International Eurasia Press Fund Anti-Fraud, Bribery and Corruption Policy is designed to promote an anti-fraud culture and consistent organisational behaviour across the company when dealing with cases of suspected fraud, bribery or corruption. It sets out responsibilities for fraud prevention and detection and provides clear guidelines and procedures for reporting cases of suspected […]<\/p>\n","protected":false},"author":1,"featured_media":1016,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[11],"tags":[],"class_list":["post-596","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-regulations"],"_links":{"self":[{"href":"https:\/\/iepf-ngo.org\/en\/wp-json\/wp\/v2\/posts\/596","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/iepf-ngo.org\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/iepf-ngo.org\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/iepf-ngo.org\/en\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/iepf-ngo.org\/en\/wp-json\/wp\/v2\/comments?post=596"}],"version-history":[{"count":0,"href":"https:\/\/iepf-ngo.org\/en\/wp-json\/wp\/v2\/posts\/596\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/iepf-ngo.org\/en\/wp-json\/wp\/v2\/media\/1016"}],"wp:attachment":[{"href":"https:\/\/iepf-ngo.org\/en\/wp-json\/wp\/v2\/media?parent=596"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/iepf-ngo.org\/en\/wp-json\/wp\/v2\/categories?post=596"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/iepf-ngo.org\/en\/wp-json\/wp\/v2\/tags?post=596"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}