Make sure there is managerial, independent or expert oversight
Make sure a manager, independent person or expert oversees actions and decisions. Multiple people being involved in actions and decisions increases transparency and reduces the opportunity for fraud.
Why this countermeasure matters
Allowing certain actions or decisions without managerial, independent or expert oversight can lead to:
- actions and decision-making not being performed correctly
- less visibility of fraud and corruption risks
- less action and accountability to prevent, detect and respond to fraud and corruption
- staff or contractors taking advantage of positions of trust to act corruptly, commit fraud and avoid exposure
- staff or contractors being coerced to commit fraud for someone else.
How to put this countermeasure in place
Some ways to implement this countermeasure include requiring:
- a manager to oversee staff activities such as work output, timesheets and travel
- a probity advisor to review and sign-off procurement milestones
- a contract manager to oversee contract requirements, such as reporting on software development milestones
- a security advisor to oversee physical security arrangements.
How to measure this countermeasure's effectiveness
Measure the effectiveness of this countermeasure by using the following methods:
- Confirm the existence of processes to support transparent actions and decision-making.
- Confirm that managerial, independent or expert oversight exists for critical actions or decisions.
- Confirm clear reporting lines and separation of duties exist.
- Review a sample of decisions to confirm independent or expert advice was obtained.
- Review workflows to make sure the involvement/oversight of a manager, independent person or expert.
- Review the volume of actions and decisions to determine if sufficient oversight is possible.
- Assess the level of independence of independent persons or the expertise of experts.
- Review reporting and reconciliation processes.
- Undertake a staff census and include questions relevant to supervisor oversight.
- Review APSC Census Results if you are Commonwealth entity.