Create processes to receive and review complaints
Allow clients, staff and third parties to lodge complaints about actions or decisions they disagree with. This may identify fraud or corruption as a cause for complaints.
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.