Train staff to apply correct processes and decisions
Summary
Provide staff with adequate training to increase likelihood that correct and consistent processes and decisions will be applied.
Why this countermeasure matters
Lack of adequate training for staff in how to apply correct processes and decisions can lead to:
- frustrated staff, clients or third parties – this can motivate them to commit reckless fraud or allow them to rationalise fraudulent or corrupt behaviour
- staff acting in an inconsistent way or making errors resulting in higher levels of non-compliance and fraud
- staff not applying processes and controls correctly, such as identity authentication, which fraudsters can exploit
- staff not recognising inconsistencies or red flags, such as someone providing false or misleading information or evidence to support a request or claim
- poor management of fraud and corruption risks
- staff abusing their positions of trust to commit fraud or act corruptly.
How to put this countermeasure in place
Some ways to implement this countermeasure include:
- requiring all staff to complete induction training
- providing specific guidance, training, and support to staff undertaking specialist processes
- requiring all staff to undertake ethics and code of conduct training
- making sure staff have completed mandatory qualifications and training.
How to measure this countermeasure's effectiveness
Measure the effectiveness of this countermeasure by using the following methods:
- Review statistics of completed training.
- Analyse program error rates and complaints.
- Ask staff about processes or systems to make sure they have received training.
- Confirm training needs assessments and performance agreements are in place and they communicate minimum training requirements.
- Undertake a staff census and particularly ask questions relevant to learning and development.
- Review APSC Census Results if you are Commonwealth entity.
Related countermeasures
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.
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.
Make sure a manager, independent person or expert oversees actions and decisions. Involving multiple people in actions and decisions increases transparency and reduces the opportunity for fraud.
Clearly document decision-makers using delegations, authorisations and instructions. Clearly defined decision-making powers increase transparency and reduce the opportunity for fraud and corruption.
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.
Prepare summary reports on activities for clients, managers or responsible staff.
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.
Provide staff with the knowledge and skills required to analyse and investigate different types of fraud.
Related Fraudster Personas
This countermeasure helps prevent, detect or respond to the following Fraudster Personas:
