Scope

• Leading by example, Wisdom House will:
• Introduce appropriate measures to minimise the risk of fraud;
• Adopt formal procedures to investigate fraud when it is suspected;
• Provide appropriate mechanisms for employees to voice their genuine concerns and protect those who do so;
• Deter employees from making malicious or unfounded accusations;
• Have no hesitation referring cases of suspected financial irregularity to the attention of the police;
• Work closely with the police and other appropriate external agencies to combat fraud;
• Support national and local initiatives against fraud.

Introduction

• Measures to Minimise the Risk of Fraud
• In order to maintain Wisdom House’s high standards, procedures and controls have been established to provide an environment which will minimise the opportunity for fraud. These procedures and controls help Wisdom House conduct its business in a manner beyond reproach. They establish the rules to which directors and employees must adhere and are supported, as necessary, by detailed procedure manuals which have been prepared for the key functions of Wisdom House.

The Policy

• It is the responsibility of Directors and Managers to operate internal systems to ensure that high standards are applied and brought to the attention of their employees. Procedures are operated throughout Wisdom House to ensure:
• An adequate separation of duties (more than one employee is involved in key tasks); Proper authorisation procedures (transactions must be approved);
• Independent monitoring and checking of data and documentation (checks and balances).
• Wisdom House has a rigorous audit process which monitors compliance with regulations and undertakes a rolling programme of checks to detect, deter and prevent fraud and corruption. They work closely with Managers, monitoring their systems and procedures, to ensure that they are fully operated.
• Procedures when a Fraud is suspected
• Wisdom House requires suspected irregularities to be referred to the senior manager. All reported irregularities will be thoroughly investigated. The normal sequence of events, should an irregularity be suspected, will be as follows:
• If employees suspect an irregularity has occurred, or is likely to occur, they should normally report this to their line Manager who will in turn inform the appropriate business manager (unless the concerns relate to that officer, in which case employees should have regard to the alternative mechanisms outlined below).
• Should preliminary investigations suggest the suspicion is reasonable, the Manager should be informed, without delay.
• If the suspicions stem from an audit, the Manager will inform the appropriate business manager. Members of the public are encouraged to report any concerns to the Manager.
• Where further investigations indicate an offence may have occurred, the Manager will consult with the business manager. This will normally result in a decision to handle the matter according to Wisdom House Disciplinary Procedures and to involve the Police.
• Where financial impropriety is suspected, the Police will normally be informed.

• Mechanisms for Employees to Voice Concerns
• Employees are vital to the successful implementation of measures against fraud. Wisdom House, therefore, encourages employees to report any concerns they have, without fear of being penalised. Normally, employees should raise such concerns with their line Managers, who have a responsibility to investigate and keep their Directors fully informed. However, other routes are available, and employees are free to discuss the matter with business manager
• All concerns reported will be treated in confidence and fully investigated. If anonymity is requested, every effort will be made to ensure such confidentiality.
• The Manager to whom the concerns are expressed will take prompt action and the employee will be notified quickly of any action taken. Where action is not considered appropriate, the employee will also be given a prompt and thorough explanation of the reasons for this. In the event of a disagreement, the employee will be advised how to pursue the matter formally.
• Employees should be aware that, if a suspicion is reported and results in a prosecution or disciplinary hearing, their involvement as a witness in those processes may be necessary, unless other substantial reliable evidence is available.
• There is also a need to ensure that the investigative process is not misused. Therefore, any abuse, such as raising unfounded or malicious allegations, may be dealt with as a disciplinary matter in itself. This should not deter employees from raising genuine concerns (even if subsequently unfounded but made with good intent), as, in so doing, they will be supported in every possible way.
• This policy will be reviewed annually or when there is a change in circumstances, in work practices or the introduction of new legislation.