Corporate Governance Framework
9. The Chief Executive, as Accounting Officer will decide how the investigation of the suspected fraud will proceed. The Chief People Officer will normally be informed of any such investigation involving Commission employees.
The investigation process will include:
- clarifying and documenting the nature and circumstances surrounding the suspect activity
- securing the evidence in a legally admissible form
- ensuring the threat of further or continued fraud or corruption and any associated losses are removed
- deciding whether a formal investigation is appropriate
- advising Internal Audit, the Chair of the Audit and Risk Committee, and Department for Digital, Culture, Media and Sport (DCMS)
- advising the police where there is initial evidence of wrongdoing
- following the advice of the police and providing the necessary support and information if he/she accepts the allegation for investigation
- if the police decide not to take further action, the Commission will consider:
- suspending or dismissing the alleged perpetrator from the workplace (if the circumstances support this action), or arrange for appropriate surveillance if the employee under suspicion remains in the workplace. Any such action will only be taken after consideration of advice from the Chief People Officer and one of the Commission’s legal advisers
- appointing a person with suitable experience, who may be a member of management, or a third party investigator to: investigate; ensure that a fully documented record is kept setting out the key steps and details of the investigative process; and report
- taking the necessary actions based upon the report recommendations, for example disciplinary action in accordance with the Commission’s disciplinary policy.
Last updated: 27 February 2023
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