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Fraud Control and Anti-Corruption Policy


Family Planning NSW (FPNSW) works to achieve the highest standards of honesty and integrity and comply with all relevant legislation and regulations. FPNSW will foster an environment that makes active fraud and corruption control the responsibility of all staff.

FPNSW takes a zero-tolerance approach to all forms of fraud and is committed to preventing, detecting and responding to fraud in all aspects of organisational and program management. Fraud and corruption are serious criminal offences, and FPNSW will treat them accordingly.


All FPNSW staff, board of directors, contractors, students, project partners and volunteers.


Term Meaning
Conflicts of Interest exists when a person could be influenced or could be perceived to be influenced by a personal interest in carrying out their duties.

A conflict of interest that leads to partiality in decision-making may constitute corrupt conduct.
Corruption involves misuse of power for private gain e.g. blackmail, bribery, forgery, abuse of role, improper sharing of information, not declaring a conflict of interest.
DFAT Department of Foreign Affairs and Trade.
Fraud dishonestly obtaining a benefit, or causing a loss, by deception or other means. Fraud includes theft of funds or assets, misappropriation of funds, falsifying invoices or signatures, unlawful use of equipment, material or services, unauthorised disclosure of confidential information, or wrongfully using intellectual property.


Risk Assessment

FPNSW will undertake an organisational risk assessment to identify fraud risks and mitigating strategies to prevent and detect fraud. Fraud risk management is integrated with overall risk management procedures. Fraud risks are identified through an assessment process consistent with ISO 31000:2018 Risk management - Guidelines, addressing inherent risk and the likelihood and consequences of identified risks. The fraud risk assessment will be documented in the FPNSW risk register and forms the Fraud Control Strategy.

A project-specific fraud risk assessment and fraud control strategy will be conducted on all DFAT funded projects within one month of the commencement of the project. Each fraud risk assessment and strategy must contain project-specific fraud prevention, detection, investigation and reporting processes and procedures.

Preventative Controls

Preventing fraud is the responsibility of all FPNSW staff, Board of Directors, partners and volunteers. Preventative controls manage the sources of the risk to decrease the likelihood of the risk occurring. FPNSW will implement a range of preventative strategies as identified in the organisational and project fraud control strategies, including:

  1. Maintaining appropriate financial strategies such as ensuring
    • all financial transactions are recorded in financial systems, including detailed records of expenditure against relevant budget lines
    • separation of duties, such as separation of accounts payable and accounts receivable, and to ensure that staff approving expenditure must not be in a position to benefit from that expenditure
    • regular monitoring and investigating variances from budget
    • two cheque signatories for all payments (EFT, direct debit, cheque)
    • maintenance and regular review of asset registers
    • annual audit of systems and financial statements by qualified external auditors
    • expectations of staff, contractor and consultants are documented and implemented according to defined policies and procedures, including the Family Planning NSW Code of Conduct and Ethics policy (https://www.fpnsw.org.au/about-us/policies/code-conduct-and-ethics-policy) , Conflicts of interest policy, Delegations policy, Fixed asset management policy, Investment policy, Petty cash management cash handling and receipting policy, Purchasing policy, Revenue recognition & receipting procedure, Travel policy, International travel and security policy and IT and cloud systems usage policy and Whistleblower policy (https://www.fpnsw.org.au/about-us/policies/whistleblower-policy).
  2. Due diligence of prospective suppliers/contractors.
  3. Mandatory reporting of all conflicts of interest.
  4. Avoiding conflicts of interest in making purchases or sub-grant activities.
  5. System access controls.
  6. Physical security controls.
  7. IT cyber security controls to prevent external penetration into IT systems.
  8. Pre-appointment screening such as criminal record check for Board members, volunteers, contractors and consultants, where appropriate.
  9. Training of relevant staff to understand their obligations and responsibilities regarding prevention, detection and reporting of fraud.
  10. Appropriate checks of inventory to ensure inventory ordered matches the inventory being removed.
  11. Partnering with organisations and professionals who share FPNSW values.
  12. Complying with contractual and reporting obligations of funders, statutory bodies, regulatory bodies and law enforcement.
  13. Maintaining compliance with all funding bodies, including NSW Health and DFAT, regarding funding arrangements to ensure staff are clear on how funds can be used in terms of content and timing.
  14. Guaranteeing value for money and spending all contractee funding, including from NSW Health and DFAT, in a way that is economical, efficient, effective and ethical.
  15. Performing due diligence of overseas sub-partners, and other partners as appropriate - through:
    • performing partnership assessment prior to engaging with a partner, ensuring they are a reputable entity and they have the systems in place to manage funds
    • regularly performing appropriate checks to ensure that funds are not being directed to terrorist and/or money laundering activities.
    • internal audits, stocktakes, official visits to partner/project sites to meet with in-country partners and review projects
    • performing regular acquittal processes to ensure funds have been deployed and expended appropriately

FPNSW has appropriate and effective internal control systems for the prevention, detection, reporting and management of fraud and corruption. These internal systems include, but are not limited to, financial, administrative, human resourcing, information communication technology, fundraising and program management.

Detection and Reporting of Fraudulent Activities

  1. Should fraud be detected or suspected, it must be reported immediately to the CEO through the Family Planning NSW Incident Report procedure.
  2. Any detected, suspected, or attempted fraudulent activity must be reported in a confidential, prompt and professional manner.
  3. Investigations will be carried out by appropriately qualified and experienced personnel within FPNSW. If external investigators are engaged, FPNSW will ensure that they are appropriately qualified.
  4. FPNSW will consult with financial/legal advisors as appropriate to obtain advice and counsel regarding the fraud investigation.
  5. The CEO, on advice from financial/legal advisors, will refer instances of potential serious or complex fraud offences to the appropriate law enforcement agency, including the NSW Police or Australian Federal Police (AFP). Minor or routine instances of fraud, that is, fraud that would be unlikely to be investigated by the law enforcement agency /AFP, will be investigated internally or by an external investigator appointed by FPNSW.
  6. FPNSW will seek prosecution, as advised, of those who commit fraud against it, whether they are within or external to the organisation, and will cooperate with fraud and corruption investigations by law enforcement and other investigative authorities.
  7. FPNSW will seek to reclaim any money or other resources misappropriated through fraudulent or corrupt activity and will take appropriate disciplinary action against staff members found to have engaged in such activity.
  8. All documentation relating to an investigation of fraud or potential fraud will be stored securely and confidentially and used to improve preventative measures and mitigate future risks.
  9. Investigations will not be disclosed or discussed with anyone other than those who have a legitimate need to know the details of the case. Involvement will be limited to avoid damaging the reputations of persons suspected but found innocent of fraudulent conduct.

In the case of fraud related to funds provided by DFAT, the below measures will be actioned:

  1. In-country partners must report all cases directly to Family Planning NSW immediately. Within 5 business days Family Planning NSW will report to the Fraud Control Section at fraud@dfat.gov.au using the fraud referral form to enable full investigation and action. Family Planning NSW will follow the DFAT guidelines for handling such situations.
  2. Where suspected fraudulent activity is alleged to have occurred in a partner organisation, the CEO and Director Finance will consult with the CEO of the partner organisation (if appropriate) and agree on the person to investigate the activity.
  3. Family Planning NSW will consult with financial/legal advisors and DFAT as appropriate to obtain advice and counsel regarding the fraud investigation.
  4. Where a decision has been made to take formal action, including referring the investigation results to the appropriate law enforcement agency for independent investigation or taking other legal action, the final decision must be made by the FPNSW CEO.
  5. Commercial and NGO partners will repay funds or replace assets lost to fraud, including taking recovery action in accordance with recovery procedures.
  6. Family Planning NSW will ensure that DFAT is kept informed of the progress and resolution of any investigation and respond within 5 business days to any further requests for information by DFAT.


Policy Breaches

Failure to comply with this policy could lead to disciplinary action, including dismissal.


Party/Parties Responsibilities
  • sets the tone regarding FPNSW's attitude to fraud and internal control
  • monitors Management's implementation of FPNSW's Fraud Prevention and Detection Policy
  • demonstrate commitment to this policy
  • promote an ethical culture
  • effective and economical use of FPNSW resources
  • initiate fraud investigations
  • report fraud, as appropriate, to relevant funders and appropriate law enforcement agencies
Director Finance
  • demonstrate commitment to this policy
  • promote an ethical culture
  • determine appropriate controls in managing fraud and corruption risks
Executives, Managers
  • demonstrate commitment to this policy
  • promote an ethical culture
  • ensure all declared relationships, associations and conflicts of interests are severed if not manageable and otherwise are appropriately managed
  • assessing the risk of fraud and corruption in their business area, identify and report suspected fraud or corruption, and promote a culture of integrity in the workplace
  • report suspected fraud and corruption promptly to the CEO and maintain confidentiality, and ensure the protection of complainants who report fraudulent or corrupt activities
  • ensure all staff are aware of this policy and related policies
  • contribute to preventing fraud and corruption by acting with integrity and ethically
  • comply with all related policies and procedures, including the Code of conduct and ethics
  • report suspected incidences of fraudulent or corrupt behaviour through their line manager
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