Attachment A - Frequently Asked Questions

Action Consideration Roles
Who    Who reviews and evaluates the fraud and corruption control plan?

The Fraud and Corruption Control Plan is owned by the Secretary. The Secretary has overall accountability and responsibility for fraud control, ensuring there are sound Fraud Control Frameworks and governance mechanisms in place that comply with the CFCF to effectively support fraud control activities.

The department’s Assurance and Audit Committee provides independent assurance and advice to the Secretary on the operation of key controls and the Fraud Control Plan to the extent that it is within the charter.

The Fraud and Corruption Control Plan is managed by the FCO and referenced by all levels of management.

The FCO collects, collates and reviews the fraud risk management strategies and controls implemented by the department A key responsibility of the FCO is ensuring the department meets and or exceeds the CFCF and the ANAO’s Better Practice Guide titled ‘Fraud Control in Australian Government Entities 2011.’

Who has to undertake fraud awareness training?

Fraud awareness training is encouraged by the Secretary. All staff are encouraged to attend fraud awareness training and/or information sessions.

The FCO designs and develops an ongoing fraud awareness training programme to raise awareness of fraud and fraud risks amongst all staff and contractors. Specialised training is available to high risk areas.

Fraud awareness training is conducted alongside other related training such as the APS Values and Code of Conduct, the ethical culture of the department.

Who analyses the fraud risks in the organisation?

The Corporate Division is responsible for implementing and managing the department’s Risk Management Framework and relevant support functions on a day-to-day basis. Further information relating to Risk Management is available on the intranet.

The FCO works with business areas to ensure internal and external fraud related risks are identified and adequate controls are in place to mitigate the risk to an acceptable level. It is a requirement of the ANAO that all key controls in place to address high levels of fraud related risk are articulated in the Fraud and Corruption Control Plan.

The Assurance and Audit Committee acts as an agent of and an advisory body to the Secretary in relation to risk management and fraud control.

Further information relating to the Assurance and Audit Committee responsibilities is located in the department’s Audit Committee Charter, available on the intranet.

Who analyses the fraud risks in my work area?

Managers and General Managers must assist the Secretary by demonstrating a high level commitment to fraud control and management and ensure business processes are planned and implemented after due consideration to fraud risk exposure.

Business areas responsible for managing a particular fraud risk should be identified and the timeframes for implementing remedial action should be clearly documented in the risk management plans.

What   What are the drivers of fraud risk at the organisation/ programme level?

The demand for timelines and flexibility in service delivery can create challenges in maintaining the integrity of the department’s programmes.

The risk of fraud can come from inside the department or from external parties such as clients, consultants, service providers, corporate entities or members of the public.

The risk of programmes being susceptible to fraud should be considered during the development, implementation and or delivery of Departmental programmes.

What is my role in fraud control?

The identification and reporting of fraud is the responsibility of all staff and contractors.

All staff and contractors play a part in managing the department’s potential exposure to fraudulent activity in a number of ways.

Firstly, by ensuring they themselves behave in an ethical way consistent with the APS Code of Conduct and values.

Secondly, by being alert to behaviour in the workplace that they suspect may be fraudulent and be prepared to report it expediently to the relevant point of contact.

Thirdly, by being alert to indicators of potential external fraud being perpetrated on the department and being prepared to report it expediently to the relevant point of contact.

What is a proportionate response to fraud risks in my organisation/work area?

Under the CFCF, the department is required to investigate minor and routine instances of fraud, irrespective of whether the outcome of the investigation results an administrative remedy or is referred for criminal prosecution consideration.

Matters involving serious and complex fraud must be referred to the AFP.

When   When do I get involved in fraud prevention and detection strategies?

Whenever programmes are developed, new opportunities to perpetrate fraud may arise from internal and external parties.

The risk of fraud should be considered at each critical stage of the programme lifecycle including, policy development, programme design, procurement, deliver/implementation/ management and closure.

All staff, in conjunction with their compliance teams, have prime responsibility for identifying potential fraud.

The FCO will liaise with business areas and provide fraud awareness training to assist in ensuring staff of their responsibilities in relation to fraud control.

When do we report fraud in the organisation?

Staff, contractors and external parties are encouraged to report all suspicions of fraud. This could include reporting concerns involving other staff, contractors or service providers.

Where the business area suspects fraud, they may initiate discussions with the FCO to assist them in determining whether the issues should be referred.

When do we analyse potential fraud activity? The risk analysis of programmes being susceptible to internal and external fraud should be considered during the development, implementation and/or delivery of departmental programmes.
Where   Where can I find my organisation’s Fraud Policy? The department’s Fraud Policy Statement is provided in DP 1.2. It is also provided in fraud awareness training.
Where is the guidance on how to report fraud in my organisation? Information on how to report fraud is in DP1.2. This document and further information is located on the intranet under ‘Fraud’.
Where can I refer matters of serious and complex fraud?

All allegations of fraud on the department, whether internal or external, are assessed, and where appropriate, investigated with the aim of proving or disproving the allegations.

Referrals of fraud should be delivered to the FCO following guidance provided in AAI 1.2. These allegations may in turn be referred to the AFP.

The People and Planning Branch reviews alleged APS Code of Conduct breaches, and works with the FCO to review internal allegations of fraud.

Why   Why is our organisation at risk of fraud? The number and scope of programmes administered by the department will attract a diverse range, and potentially large number, of participants that will include individuals or businesses prepared to offend. That is, people who will enter a programme, not necessarily with the intent of offending, but may offend if the opportunity presents itself. Others may enter a programme with intent to defraud the Commonwealth.
Why is governance so important to effective fraud control?

Fraud control and its operation within the department forms part of the overall governance framework.

The implementation of a variety of strategies and controls to prevent, detect, investigate and report on fraud all form part of the broader governance controls.

The department can then demonstrate we are managing affairs efficiently, effectively and ethically, and in accordance with the policies of the Commonwealth.

Why do we need to review our fraud risks when our organisation structure changes?

In accordance with the CFCF, fraud risk assessments must be conducted every two years. In addition, fraud risk assessments should be conducted when a new programme is introduced or the department undergoes changes to its structure.

The pre-existing fraud controls already in place may not be adequate for a new programme or structure put in place.

The department regularly reviews fraud risks to ensure controls are adequate and effective.

How   How do I get assurance that fraud risks are addressed in programme design?

Fraud risk assessments should be conducted throughout each stage of the programme lifecycle from policy development to business as usual, feeding back into programme re-design and education.

The FCCP will collect, collate and articulate controls that are in place. If not, recommendations will be immediately made by FCO.

How do I know our fraud strategies are working in my organisation?

The department’s FCCP is subject to regular monitoring and revision to ensure fraud controls are implemented effectively and activities achieve their intended outcomes.

The FCO is responsible for establishing processes to systematically manage the monitoring, reporting and evaluation of fraud prevention, detection and response activities within the department.

How does my organisation decide if a suspected fraud will be investigated?

All allegations of fraud on the department, whether internal or external, are assessed, and where appropriate, investigated with the aim of proving or disproving the allegations.

The department has in place an assessment process for the receipt of instances fraud. This process has been developed directly from the standards set out in the AGIS and takes into consideration the CDPP Prosecution Policy of the Commonwealth.

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