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Corporate Governance Framework

Our corporate governance framework sets out the necessary responsibilities and procedures that guarantee we operate properly.

  1. Contents
  2. Appendix 3 – Anti-fraud and corruption policy
  3. The Accounting Officer and Chief Finance Officer

The Accounting Officer and Chief Finance Officer

10 The Chief Executive, as Accounting Officer, is responsible for establishing and maintaining a sound system of internal control that supports the achievement of Commission policies, aims and objectives. The system of internal control is designed to respond to and manage the whole range of risks that the Commission faces. The system of internal control is designed to identify the principal risks facing the Commission at organisational and departmental level, to evaluate the nature and extent of those risks and to manage them effectively. Managing fraud risk is seen in the context of the management of this wider range of risks.

11 Overall responsibility for managing the risk of fraud and corruption within the Commission has been delegated to the Chief Finance Officer.

The responsibilities of the Chief Finance Officer role include:

  • developing a fraud and corruption risk profile and undertaking a regular review of the fraud risks associated with each of the key organisation objectives in order to keep the profile current
  • establishing an effective anti-fraud and corruption policy and response plan, commensurate with the level of risk identified in the risk profile
  • developing appropriate targets, as appropriate
  • designing an effective control environment to deter and prevent fraud and corruption commensurate with the risk profile
  • establishing appropriate mechanisms for:
  • liaising with the Commission’s Executive Group and/or Audit and Risk Committee
  • making sure that all employees are aware of the Commission’s Anti-fraud and Corruption Policy and know what their responsibilities are in relation to combating fraud and corruption
  • ensuring that appropriate training and development opportunities are available to employees in order to meet their defined competency levels
  • ensuring that vigorous and prompt investigations are carried out if fraud or corruption occurs or is suspected
  • ensuring that the police are notified of identified fraud and/or corruption and taking appropriate legal and/or disciplinary action against perpetrators of fraud
  • ensuring that appropriate disciplinary action is taken against supervisors where supervisory failures have contributed to the commission of fraud and corruption
  • ensuring that appropriate disciplinary action is taken against employees who fail to report fraud and corruption
  • taking appropriate action to recover assets
  • ensuring that appropriate action is taken to minimise the risk of similar frauds occurring in future.

12 Managers are responsible for:

  • ensuring that an adequate system of internal controls exist within their areas of responsibility and that controls operate effectively
  • preventing and detecting fraud
  • assessing the types of risk involved in the operations for which he/she is responsible
  • regularly reviewing and testing the control systems for which he/she is responsible
  • ensuring that controls are being complied with and their systems continue to operate effectively
  • implementing new controls to reduce the risk of similar fraud occurring where frauds have taken place.

13 Internal Audit is responsible for:

  • delivering an opinion to the Accounting Officer on the adequacy of arrangements for managing the risk of fraud and ensuring that the Commission promotes an anti-fraud culture
  • assisting in the deterrence and prevention of fraud by examining and evaluating the effectiveness of control, commensurate with the extent of the potential exposure/risk in the Commission’s operations
  • ensuring that the Executive Group has reviewed its risk exposures and identified the possibility of fraud as a business risk
  • assisting with fraud investigations.

14 Every employee is responsible for:

  • acting with propriety in the use of official resources and the handling and use of public funds whether they are involved with cash or payments systems, receipts or dealing with suppliers
  • complying with the Commission’s Employee Code of Conduct
  • conducting themselves in accordance with the ‘Seven Principles of Public Life’, set out by the Committee on Standards in Public Life (the Nolan Committee) (opens in new tab). They are: selflessness, integrity, objectivity, accountability, openness, honesty and leadership
  • being alert to the possibility that unusual events or transactions could be indicators of fraud and corruption
  • reporting immediately through the appropriate channel if they suspect that a fraud or corruption has been committed or see any suspicious acts or events
  • cooperating fully with whoever is conducting internal checks, reviews or investigations.
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Fraud and corruption response plan
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