Create processes to receive and review complaints

Type of countermeasure

This is a detection countermeasure. Detection countermeasures can help to identify when fraud has occurred. They can help disrupt additional fraud and reduce the consequences.

Summary

Allow clients, staff and third parties to lodge complaints about actions or decisions they disagree with. This may help identify fraud or corruption, such as failure to receive an expected payment.

Why this countermeasure matters

Having no clear process for making complaints may lead to:

disgruntled staff, clients or third parties – this can motivate them to commit reckless fraud or allow them to rationalise fraudulent or corrupt behaviour
fraud or corrupt activity going unnoticed or unchallenged
delays in investigations and responses
unknown systemic fraud or corruption.

How to put this countermeasure in place

Some ways to implement this countermeasure include:

allowing clients, staff and external parties to make complaints or raise concerns about:
- issues with payments, such as unexpected delays
- issues they experience with services
- the conduct or operations of service providers or other third parties
- a procurement outcome
- a recruitment outcome
- the conduct of others in the workplace.
training staff to look for fraud and corruption, such as cartel behaviour, when reviewing complaints
creating a complaints management strategy that outlines how to resolve a complaint and provide feedback to the person who made the complaint.

How to measure this countermeasure's effectiveness

Measure the effectiveness of this countermeasure using the following methods:

Confirm that clients, staff or third parties would be able to notice changes that are different from what is standard, normal, or expected.
Measure how long it would take to receive a complaint and respond to potential fraud.
Confirm that consistent processes exists for making/handling complaints.
Confirm that information about the process for making complaints is easy to locate and the process is easy to use (increasing the likelihood complaints are received and acted upon).
Confirm the options for lodging complaints are clearly communicated like providing a dedicated phone number.
Confirm that complaints are adequately investigated and the outcomes are clearly communicated.
Confirm that clear processes exist for referring cases of potential fraud for investigation.

Related countermeasures

Conduct quality assurance checks

Conduct quality assurance activities to confirm that processes are being followed correctly and to a high standard.

Set up automatic notifications of high-risk events and transactions

Automatically notify clients or staff about high-risk events or transactions. This can alert them to potential fraud and avoid delays in investigating and responding to fraud.

Support staff to lodge tip-offs and Public Interest Disclosures

Put in place processes for staff or external parties to lodge tip-offs or Public Interest Disclosures.

Reconcile records

Reconcile records to make sure that 2 sets of records (usually the balances of 2 accounts) match. Reconciling records and accounts can detect if something is different from what is standard, normal, or expected, which may indicate fraud.

Report on activities

Prepare summary reports on activities for clients, managers or responsible staff.

Establish exception reporting

Establish exception reports to identify activities that are different from the standard, normal, or expected process and should be further investigated.

Report incidents or breaches for further investigation

Report on incidents or breaches to help identify if further investigation is required. Clients, public officials or contractors can take advantage of a lack of reporting and transparency to commit fraud, act corruptly and avoid exposure.