Fraud Control and Anti-Corruption Policy

1. POLICY STATEMENT

Family Planning NSW works to achieve the highest standards of honesty and integrity and comply with all relevant legislation and regulations.

Family Planning NSW is member of the Australian Council for International Development (ACFID) and adheres to the ACFID Code of Conduct.

Family Planning NSW recognises the negative impact of fraud as it:

  • diverts funds away from organisational strategic goals and target groups
  • disrupts service delivery
  • undermines the confidence and support of donors and the general public, potentially damaging the organisation’s reputation

Family Planning NSW is committed to establish and maintain systems to:

  • prevent fraud
  • enable fraud to be detected at an early stage
  • report any suspicions of fraud or corruption to the relevant authorities as outlined below.

2. DEFINITIONS AND ACRONYMS

Term Meaning
Conflicts of Interest A conflict between an individual's public duties and their private interests which may mean that a decision is made on the basis of the benefit to the individual, not the benefit to the organisation.
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."

Commonwealth Fraud Control Guidelines 2011

Fraud includes misuse or misappropriation of money or assets, dishonestly obtaining benefits of any kind, or causing a loss or deception.

Examples of fraud as defined by DFAT include:

  • Misappropriation of funds
  • Altering documents
  • Falsifying signatures
  • Misuse of Commonwealth assets
  • Providing false information to the Commonwealth
  • Unauthorised disclosure of confidential information
  • Theft of aid program funds or assets

http://dfat.gov.au/about-us/publications/Pages/fraud-policy-statement.aspx

3. SCOPE

Family Planning NSW International Programme

4. POLICY DETAILS

4.1 Prevention:
 
  • Policies and procedures which establish expectations of the behaviour of staff, contractors and consultants:

    • Family Planning NSW Code of Conduct and Ethics
    • Purchasing Policy
    • Delegations Procedure
    • Travel Policy
    • International Travel Policy
    • Purchasing Procedure
    • Petty Cash Management / Cash handling Procedures
  • Fraud prevention clauses included in memorandums of understanding (MOU) established between Family Planning NSW and in-country partners which include the right to terminate the MOU in the event of fraud, misconduct or gross negligence in the provision of services
  • Segregation of duties such as accounts payable and accounts receivable roles
  • Acquittal process to ensure that funds have been deployed appropriately
  • Maintenance and review of asset registers
  • IT system security monitoring by IT Department
  • Computer Usage Policy and Procedures
  • Internal audits, stocktakes, official visits to partner/project sites to meet with in-country partners and review projects
  • Fraud awareness training for relevant staff
  • External audit of systems and financial statements by qualified auditors
  • Monitoring of investigating major variances from budget
  • 2 cheque signatories required for all payments (EFT, cheque)
4.2 Reporting of fraud
 

Should fraud be detected or suspected, it must be reported immediately to the CEO through the Family Planning NSW Incident Report procedure.

Family Planning NSW adheres to the Australian Government policy of zero tolerance of fraudulent activity or behaviour including:

  • misappropriation of funds
  • altering documents
  • falsifying signatures
  • misuse of Commonwealth assets
  • providing false information to the Commonwealth
  • unauthorised disclosure of confidential information
  • theft of aid program funds or assets

In the case of fraud related to funds provided by DFAT, any detected, suspected, or attempted fraudulent activity must be reported in a confidential, prompt and professional manner.

In the case of DFAT funding, in-country partners must report all cases directly to Family Planning NSW immediately. Within 5 days Family Planning NSW will report to the Fraud Control Section at fraud@dfat.gov.au or phone +61 2 6178 4897 to enable full investigation and action. Family Planning NSW will follow the DFAT guidelines for handling such situations.

5. ASSOCIATED DOCUMENTS

  1. 7.1 Family Planning NSW Code of Conduct And Ethics
  2. 7.2 Family Planning NSW Social & Ethical Responsibility Policy
  3. 7.3 Family Planning NSW Incident Management Procedure
  4. 7.4 Family Planning NSW Computer Usage Policy and Procedures
  5. 7.5 Family Planning NSW Petty Cash Management / Cash handling Procedures

6. REFERENCES

Family Planning NSW International Programme

Fraud Control and Anti-Corruption Plan

(The timing of the following activities is set out in the Family Planning NSW International Programme Project Management Guidelines)

  1. An initial financial risk assessment undertaken as part of the Partner Capacity Checklist
  2. The Memorandum of Understanding established between Family Planning NSW and the in-country partner highlights the following:
    1. 2.1. Termination of the contract in the event of fraud (Clause 10)
    2. 2.2. Financial Reporting Requirements (Schedule1) which require :
      • The partner to hold sufficient source documents (receipts/invoices/ statements/vouchers) to support all project transactions and shall make these available for review on monitoring visits and/or forward copies upon request by Family Planning NSW.
      • The partner to provide to Family Planning NSW ad-hoc source documents that may be requested on a quarterly basis. The request for documents will be based on a random selection from the quarterly bank statement from the Partner.
  3. Financial monitoring through the life of the project including:
    • review of the acquittals submitted by the partner in line with agreed tranche schedule, utilising internal audit and fraud control principles by Family Planning NSW Finance Team
    • analysis of the partner's audit statements and financial reports by Family Planning NSW Finance Team
    • review of foreign exchange rate in line with Family Planning NSW Foreign Currency Exchange policy
    • on-going review of the partner's financial performance as a standing agenda item at International Programme team meetings attended by Management Accountant, Manager International Projects and Senior Project Coordinators
    • Review of financial issues during in-country visits and through regular phone and email communication between partner and Family Planning NSW staff.
  4. Financial management of Family Planning NSW monitored through:
    • Family Planning NSW quarterly financial reporting and reconciliation
    • Family Planning NSW annual financial audit
    • ACFID Code of Conduct annual financial report
  5. Any fraud, detected or suspected, reported immediately to the CEO through the Family Planning NSW Incident Report procedure.
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