Set up self-disclosure and reporting processes
Require and support staff and third parties to self-disclose gifts, benefits, incidents, mistakes and real or perceived conflicts of interest.
Why this countermeasure matters
Lack of self-disclosure and reporting processes may lead to:
- staff and third parties failing to self-disclose gifts, benefits, incidents, mistakes and real or perceived conflicts of interest
- fraudulent conduct, dishonest influences or coercion
- staff and contractors being coerced to commit fraud for the benefit of another person or entity.
How to put this countermeasure in place
Some ways to implement this countermeasure include:
- requiring staff to declare conflicts of interest
- creating a process for staff to self-report accidental unauthorised accesses or disclosures
- creating a register for staff to self-report gifts and benefits
- maintaining a conflict of interest register
- requiring staff or contractors to self-report when their circumstances change, such as to maintain a security clearance.
How to measure this countermeasure's effectiveness
Measure the effectiveness of this countermeasure by using the following methods:
- Confirm policy and guidance material exists for self-disclosure or self-reporting.
- Confirm guidance material is available and easy to access.
- Review guidance material to make sure it is clear and easy to understand.
- Confirm guidance material and processes align with policy and legislation such as the Public Governance, Performance and Accountability Act 2013.
- Ask staff about the forms, processes or systems to make sure they have a consistent understanding of how to use them.
- Analyse the use of registers such as conflict of interest registers or inadvertent access registers.
A positive workplace culture can encourage ethical and supportive behaviours while discouraging fraudulent or corrupt activities. Staff will be less able to rationalise fraudulent or corrupt activities where a positive workplace culture exists. A culture built on honesty, transparency and integrity is a key organisational strength that can serve to reduce the risk of fraud. If weak countermeasures are the fuel, a bad culture can be the spark that ignites fraud and corruption.
Establish governance, accountability and oversight of processes by using delegations and requiring committees and project boards to oversee critical decisions and risk. Good governance, accountability and oversight increases transparency and reduces the opportunity for fraud.
Legislation and policy can help prevent, detect and respond to fraud, such as by outlining clear rules, regulations and criteria, allowing entities to collect, use and disclose information and allowing entities to enforce penalties and recover fraud losses.
Develop clear instructions and guidance for activities and processes, such as instructions for collecting the right information to verify eligibility or entitlements, procedures to help staff apply consistent and correct processes and guidance to help staff make correct and ethical decisions.
Provide staff with adequate training to increase likelihood that correct and consistent processes and decisions will be applied.
Provide help and support to customers, staff and third parties to help them follow correct processes and encourage them to comply with rules and processes and meet expectations.
Use declarations or acknowledgments to both communicate and confirm that a person understands their obligations and the consequences for non-compliance. The declaration could be written or verbal, and should encourage compliance and deter fraud.
Make sure requests or claims use a specific form, process or system for consistency.
Train and support staff to identify red flags to detect fraud, know what to do if they suspect fraud and know how to report it. Fraudsters can take advantage if staff and contractors are not aware of what constitutes fraud and corruption.
Conduct quality assurance activities to confirm that processes are being followed correctly and to a high standard.
Internal or external audits or reviews evaluate the process, purpose and outcome of activities. Clients, public officials or contractors can take advantage of weaknesses in government programs and systems to commit fraud, act corruptly, and avoid exposure.
Put in place processes for staff or external parties to lodge tip-offs or Public Interest Disclosures.
Fraud detection software programs automatically analyse data to detect what is different from what is standard, normal or expected and may indicate fraud or corruption.