D2M is entrusted with client's money, and we must look after it in the exactly same way that we look after our own. Fraud is not a victimless crime. So we must all be aware of what constitutes fraud, steps to prevent fraud in the first instance and what to do in the event of fraud or if we suspect fraud has occurred. D2M takes a zero tolerance approach to fraud, reporting instances of fraud to the police as necessary, and taking all appropriate steps to recover monies lost as a result of fraud perpetrated against the Firm.
D2M requires all staff, at all times, to act honestly and with integrity, and to safeguard the resources for which they are responsible. The Chief Executive Officer is responsible for establishing and maintaining a sound system of internal control that supports the achievement of our policies, aims and objectives. The system of internal control is designed to respond to and manage the whole range of risks that we face. The system of internal control is based on an on-going process designed to identify the principal risks, to evaluate the nature and extent of those risks and to manage them effectively. And overall responsibility for managing the risk of fraud has been delegated to the Compliance Officer. His responsibilities include:
Undertaking a regular review of the fraud risks;
Designing an effective control environment to prevent fraud commensurate with the fraud risk profile;
Operating appropriate pre-employment screening measures;
Making sure that all staff are aware of the Firm's anti-fraud policy and know what their responsibilities are in relation to combating fraud;
Ensuring that vigorous and prompt investigations are carried out if fraud occurs, is attempted or is suspected;
Ensuring, where appropriate, legal and/or disciplinary action against perpetrators of fraud;
Taking appropriate action to recover assets and losses; and
Ensuring that appropriate action is taken to minimise the risk of similar frauds occurring in future.
Our Staff's Responsibilities
Every member of staff has a duty to ensure that public funds are safeguarded and therefore, everyone is responsible for:
Acting with propriety in the use of official resources and the handling and use of funds in all instances;
Conducting themselves in accordance with the principles of selflessness, integrity, objectivity, accountability, openness, honesty and leadership; and
Being vigilant to the possibility that unusual events or transactions could be indicators of fraud and alerting their line manager where they believe the opportunity for fraud exists.
In addition, it is the responsibility of every member of staff to report details immediately to their line manager or Compliance Officer if they suspect that a fraud has been attempted or committed, or see any suspicious acts or events.
Staff must also assist any investigations by making available all relevant information, by co-operating in interviews and if appropriate provide a witness statement.
As members of a regulated financial services firm, you must have, and be seen to have, high standards of personal integrity. Staff including temporary staff or contractors should not accept gifts, hospitality or benefits from a third party, which might be seen to compromise their integrity.
It is also essential that staff understand and adhere to systems and procedures including those of a personnel/management nature such as submission of expenses claims and records of absence, and annual leave.
Line managers should be alert to the possibility that unusual events or transactions can be symptoms of fraud or attempted fraud. After suspicion has been roused, prompt action is essential, and all cases of suspected or actual fraud should be reported immediately to the Compliance Officer who can provide advice on next steps.
If an initial examination confirms the suspicion that a fraud has been perpetrated or attempted, management should follow the procedures provided in the Fraud Response Plan.
Fraud Risk Assessments
A major element of good corporate governance is a sound assessment of the firm's business risks. The key to managing the risk of fraud is the same in principle as managing any other business risk and should be approached systematically at both the Firm and the operational level. The assessment of risk should be part of a continuous cycle rather than a one-off event.
After full investigation the Firm will take legal and/or disciplinary action in all cases where it is considered appropriate. Any member of staff found guilty of a criminal act will be considered to have committed a serious disciplinary offence and will be dismissed from the Firm on the grounds of gross misconduct.
Where supervisory negligence is found to be a contributory factor, disciplinary action may also be initiated against those managers/supervisors responsible.
It is our policy that in all cases of fraud, whether perpetrated or attempted by a member of staff or by external firms or persons, the case will be referred to the police at the earliest possible juncture.
Appropriate steps will be taken to recover all losses resulting from fraud, if necessary through civil action.
It is appreciated that the circumstances of individual frauds will vary. The Firm takes fraud very seriously, taking a zero tolerance approach, and will ensure that all cases of actual or suspected fraud, including attempted fraud, are vigorously and promptly investigated and that appropriate remedial action is taken, including recovery of losses. Senior managers should be fully aware of their responsibility to protect all resources and as such, should always be alert to the potential for fraud.
Further information on this Anti-Fraud Policy is available from your usual contact or our Compliance Department at: email@example.com