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POLICY
RESPONSE TO ALLEGATIONS OF FRAUD, THEFT & CORRUPTION
POLICY
Applicable to:
All Wairarapa DHB Employees
Issued by:
Board
Contact
Chief Financial Officer & GM
person:
Corporate Services
.
POLICY STATEMENT
Wairarapa DHB has a zero tolerance towards fraud, corruption or theft and all allegations will be
appropriately investigated.
1.0
PURPOSE
The purpose of this policy is to protect public money an
d property by putting in place measures
to:
prevent and det
er theft and fraudulent or corrupt conduct
facilitate the detection and reporting of irregularities and improprieties
ensure that prompt, effective action is taken in response to allegations of theft, fraud or
corruption, including prosecution and recovery of losses, where appropriate.
This policy provide
s procedures for reporting suspected fraud, theft, and corruption, and raising
similar concerns.
Where the matter to be reported involv
es serious wrongdoing by or within the WDHB, it may be
appropriate to make a protected disclosure. Special procedures that must be followed by
under the Official Information Act
employees seeking protection under the Protected Disclosures Act 2000 are contained in the
WDHB’
s Disclosure of a Serious Wrongdoing Policy
Note that this policy is not intended to cover complaints by employees associated with a
Personal Grievance.
Released
2.0
SCOPE
The policy is to apply to all WDHB Board Members, employees, contractors and consultants.
3.0
ROLES & RESPONSIBILITIES
Individuals
All WDHB employees have an obligation at all times to act according to the law, in responsible
ways (that is, in the public interest), and to exercise good judgement and trustworthiness.
WDHB employees should always distinguish between public and private affairs and must not
use their duties or positions for undue private gain for themselves or third parties.
Individuals are responsible for:
Document No: 00917
Page 1 of 15
Version: 5
Prepared by: Eric Sinclair
Issue Date: 20/10/2013
Authorised by: Chief Executive
Class Code: OPO-C
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Wairarapa DHB.
CONTROLLED DOCUMENT. The electronic version is the most up-to-date version. WDHB will NOT take any responsibility in case of any
outdated paper copy being used and leading to any undesirable consequence.
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Response to Allegations of Fraud, Theft or Corruption Policy
familiarising themselves with this policy
seeking clarification and/or support as to the exercise of their judgement on issues covered
by this policy
complying with the WDHB Code of Conduct and WDHB policies and procedures
complying with accepted accounting practices, including recording all transactions promptly
and accurately and ensuring that entries do not distort or disguise the true nature of any
transaction
being alert to irregularities and inappropriate conduct
rejecting and reporting any offers of
gifts/benefits or the like made in an attempt (or
apparent attempt) to bribe and
bringing any concerns regarding the use of public money or property and conduct to the
attention of WDHB management in good faith and in a responsible manner.
Management
All managers are responsible for:
ensuring compliance with the employment Relations Act
Act
demonstrating the highest standards of ethical behaviour and commitment, and maintaining
an ethical climate where employees are encouraged to take an active part in protecting
public money and property, including reporting any breaches of the required standards
considering the types of irregularities and improprieties that might occur in their area of
responsibility and ensuring that internal controls both exist to reduce opportunities for and to
Information
detect such occurrences
reinforcing and monitoring employees' adherence to existing internal controls, WDHB
policies and procedures, and the WDHB Code of Conduct (including making sure that these
Official
are not ignored or overridden)
educating staff as to their responsibilities in regard to the prevention of fraud, theft and
the
corruption
detecting, and acting quickly, constructively, and in good faith in response to, irregularities
and improprieties
under
ensuring that those acting on their behalf are made aware of relevant internal controls and
authorisation procedures.
Chief Financial Officer & General Manager Corporate Services
Released
The Chief Financial Officer & General Manager Corporate Services has responsibility for:
the development and maintenance of corporate guidance related to Fraud, Theft, and
Corruption Control an
d Protected Disclosures
disseminating information on and raising awareness of the WDHB’s Fraud, Theft, and
Corruption Control Policy and Protected Disclosures Policy
supporting the WDHB’s managers in educating staff about the policy and their
responsibilities in regard to the prevention of fraud, theft and corruption
include in the annual WDHB risk analysis, consideration of fraud, theft and corruption risks
and ensuring that any risks so identified are managed
monitoring the WDHB’s internal control environment, including ensuring that the WDHB’s
management delegations are current and
maintaining an open environment of checks and controls.
Investigation Coordinator
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Response to Allegations of Fraud, Theft or Corruption Policy
The Investigation Coordinator is the Chief Financial Officer & General Manager Corporate
Services. The Investigation Coordinator will act in consultation with the Chief Executive Officer.
If there is any conflict of interest in relation to an allegation on the part of:
the Chief Financial Officer & General Manager Corporate Services, the General Manager
Human Resources will act as Investigation Coordinator
the Chief Executive Officer, the General Manager Human Resources will act in his/her
stead.
Where the allegation is made against the Chief Executive Officer the Chair of the Board of the
DHB shall be the Investigation coordinator.
The Investigation Coordinator may exercise a financial sub-delegation by virtue of this policy to
carry out preliminary assessments and initiate investigations into allegations of fraud, theft, and
corruption, including the appointment of external experts.
The Investigation Coordinator is responsible for:
promptly carrying out a preliminary assessment of reported irregularities and improprieties
(this may require obtaining expert advice)
ensuring that the Board Chair and Audit & Risk Committee Chair are advised immediately of
Act
serious or politically sensitive allegations of fraud, theft, and corruption and the outcome of
all investigations
referring cases of suspected fraud, theft, and corruption to law enforcement authorities,
where appropriate (Note: all suspected criminal offences will be reported to the New
Zealand Police)
Information
supervising and seeking to ensure the quality, efficiency, effectiveness and legality of work
carried out by any detection and investigation experts retained by the WDHB
initiating recovery action, where appropriate
Official
advising the WDHB's insurers of suspected wrongdoing, where appropriate
providing feedback on assessment an
the d investigation progress and outcomes to the
individual who made the initial report, where possible and appropriate
providing options for action to the
Chief Executive Officer
under
ensuring information relating to allegations of fraud, theft, and corruption is documented and
filed securely.
4.0
DEFINITIONS
Released
Corruption is dishonest or preferential use of power, influence, position, or public office for
personal
gain*. Corruption often involves at least two people (a buyer and a seller), bribery,
and a breach of public trust.
Fraud is difficult to define, but for the purposes of this policy is considered to be wilful or
deliberate deceit or other dishonest conduct, involving acts, omissions, or the making of false
statements (orally or in writing), with the intention of obtaining an unauthorised
benefit* or
evading a liability to the Crown.
Individual for the purposes
of this policy the term ‘individual’ shal include:
any employee of the WDHB, or a person who was an employee of the WDHB at the time of
any alleged breach of this policy
any consultant or contractor retained by the WDHB, or a person who was a consultant or
contractor retained by the WDHB at the time of any alleged breach of this policy.
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Response to Allegations of Fraud, Theft or Corruption Policy
Public / WDHB Property includes not only physical items of property and stationery for
individual use, but also computer software and copies of it, official information, and materials
and documentation prepared during official time and/or using WDHB resources and services.
Serious Wrongdoing includes:
an unlawful, corrupt or irregular use of the funds or resources of a public sector organisation
or
an act, omission, or course of conduct:
o that constitutes a serious risk to public health or public safety or the environment
o that constitutes a serious risk to the maintenance of law, including the
prevention, investigation, and detection of offences and the right to a fair trial or
o constitutes an offence or
o by a public official that is oppressive, or improperly discriminatory, or grossly
negligent, or that constitutes gross mismanagement.
(This definition is the same as that in the Protected Disclosures Act.)
Theft is dishonest appropriation of property belonging to the Crown with the intent to
Act
permanently deprive the Crown of it.
* This policy is not restricted to monetary or material benefits (i.e. it includes intangible benefits
such as information). Benefits / gain may be destined for the party to the fraud, theft, or
corruption or for a third party (including immediate family members).
5.0
POLICY
Information
Principles
Wairarapa DHB will not tolerate any fraud, theft or corruption if proven and any allegation will be
appropriately investigated.
Official
It is the intent of WDHB to fully investigate any suspected acts of fraud, misappropriation, or
the
similar irregularity.
The WDHB will pursue every reasonable course (including court ordered restitution) to obtain
recovery of any loss from the offender.
under
In line with its commitment to having (and maintaining a reputation for) an environment that
encourages high ethical conduct and responsible stewardship of resources, the WDHB will:
promote high ethical conduct and principles both internally (for example through staff talks
and the promulgation of internal guidance material) and externally (for example through the
Released
WDHB Code of Conduct and the WDHB’s Annual Report)
take steps to deter and prevent
fraud, theft and corruption
provide access to independent, confidential counselling for employees who may be at risk
from pressures known to lead to workplace crime and abuse. (refer to the Employee
Assistance Programme.)
respect the rights of employees to report concerns and mak
e protected disclosures
make sure that individuals reporting their concerns in good faith and in a responsible
manner do not suffer detrimental action as a consequence, so that disclosures of
wrongdoing are seen as a positive aspect of the WDHB’s culture
treat seriously any allegation of suspected fraud, theft or corruption
take prompt action on all reported concerns, both to bring the activity to an end and to
discourage others who may be inclined to similar conduct
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Response to Allegations of Fraud, Theft or Corruption Policy
act impartially, fairly, and equitably when handling cases of suspected fraud, theft or
corruption, which includes having proper regard for the principles of natural justice and the
avoidance of entrapment, bias, and favouritism
treat people consistently, regardless of their relationship with the WDHB, status, length of
service, or position / title
exercise good judgement, in the public interest
be satisfied as to the facts of the case before initiating any
disciplinary or legal action (this
will involve a preliminary assessment, and where appropriate, investigation of the allegation)
impose and articulate strong deterrent penalties, including seeking prosecution and
recovery of any losses wherever possible and practicable, including making details of
successful prosecutions public, wherever possible and
cooperate fully with any investigations of alleged wrongdoing undertaken by external
parties, such as an 'Appropriate Authority' (as defined under the Protected Disclosures Act
2000), a Minister of the Crown, or an Ombudsman.
Wairarapa DHB will undertake regular reviews of transactions and activities for possible fraud,
theft or corruption. These reviews will be undertaken in conjunction with the DHB's internal
auditor and will be included in the Internal Audit Universe, which will be ap
Act proved by the Audit &
Risk Committee annually.
6.0
REFERENCES
State Services Commission Guidance on Response to Allegations of Fraud, Theft and
Corruption Policy
Information
Protected Disclosures Act 2000
7.0
RELATED WAIRARAPA DHB DOCUMENTS
Official
Disclosure of a Serious Wrongdoing Policy
the
WDHB Code of Conduct
8.0
FURTHER INFORMATION / ASSISTANCE
under
Further Information
Examples of activities covered by this policy
Corruption including:
accepting a bribe or other inducement to award a contract (refer to the WDHB’
s Gifts and
Released
Benefits Policy)
accepting payments to ignore non-performance of obligations or as an inducement to grant
favours
unauthorised disclosure or use of confidential, personal, or proprietary information or
intellectual property whether for personal gain or otherwise
seeking (or accepting in contravention of the
Gifts and Benefits Policy) anything of material
value for personal gain (including secret commissions, gifts, and entertainment) from
contractors, vendors, or persons providing goods or services to the WDHB
profiteering as a result of insider knowledge of WDHB activities or intentions.
Misappropriation of WDHB assets, including:
theft or inappropriate use of cash, consumables, or inventory
theft, inappropriate use, unlawful/unauthorised destruction, or removal (by electronic or
other means) of WDHB property (e.g. stealing equipment such as computers and other
technical devices; furniture; fixtures and fittings; property that should have been officially
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Response to Allegations of Fraud, Theft or Corruption Policy
disposed of; records; documents; and forms or certificates, or abuse of WDHB
telephones/facsimile machine
s/email/voicemail/internet services)
misuse of a WDHB credit card or taxi chits / cards (e.g. using these for personal rather than
official use).
Dishonest handling of documents or reporting, including:
tampering with cheques
fictitious or altered invoices submitted for payment
forgery (e.g. submission of false receipts or invoices or forged certificates of competency or
qualifications)
deliberately charging the WDHB/Crown for goods and services not delivered or only
delivered in part
claims for reimbursement of false or personal purchases (e.g. false travel expense claims)
bogus claims f
or leave
payroll abuse.
For further information please contact the Chief Financial Officer & General Manager Corporate
Services.
Act
9.0
APPENDICES
Procedures to follow in implementing the Policy
Record of Report Form for suspected fraud, theft or corruption
10.0
KEY WORDS (maximum of 4)
Information
Fraud
Theft
Corruption
Investigation
Official
the
under
Released
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Response to Allegations of Fraud, Theft or Corruption Policy
PROCEDURES IN IMPLEMENTING THE POLICY
Preliminary assessment of an allegation
The purpose of a preliminary assessment is to determine whether there is any substance to an
allegation of susp
ected fraud, theft, or corruption, and to protect employees from false or vexatious
allegations. Evidence required for these purposes will be collected and secured in a manner that
ensures the integrity of that evidence, and the individual under investigation, and does not jeopardise
any future investigation. The allegation will be assessed by the
Investigation Coordinator, with
assistance where required.
The outcome of the assessment process is a set of recommended actions for the
Chief Executive
Officer (or an appropriate independent authority, should a conflict of interest exist). These
recommendations may include, but are not limited to:
resolving the matter via performance management and/or disciplinary procedures
referring the matter to an appropriate authority for investigation
retaining external experts to undertake an investigation on behalf of the WDHB
closely monitoring the situation or
no further action.
Act
Details of decisions made must be recorded and placed on a secure file.
Preliminary assessment results will not be disclosed or discussed with anyone other than those who
have a need to know.
False or vexatious allegations
Information
Employees who intentionally make false or vexatious allegations of fraud, theft, or corruption will be
dealt with in accordance with the WDHB’s disciplinary procedures.
Note that individuals who make protected disclosures of information with the knowledge that the
Official
allegation is false or otherwise act in bad faith may not be afforded protection under the Protected
Disclosures Act 2000.
the
Investigation
Where the preliminary assessment shows that a prima facie case of
fraud, theft, or corruption exists,
under
the allegation should be investigated. An investigation is the process by which facts are lawfully
established through enquiry and analysis in order to determine (to an appropriate standard of proof)
whether or not a particular event (or series of events) has occurred, and who is responsible for these
events.
The WDHB will not undertake an investigation itself. Rather, the
Investigation Coordinator will refer
Released
cases for investigation to the New Zealand Police or the Serious Fraud Office for investigation.
Where referral is not appropriate (e.g. it is unclear that a law has been violated), or the case has been
referred and not accepted for investigation, the Investigation Coordinator may retain experts to
undertake an investigation for the WDHB.
If additional information indicating that the matter is more serious than first indicated becomes available
during such an investigation, the matter may again be referred to the appropriate enforcement agency
for consideration.
While the individual(s) will not be presumed guilty without proper proof, it may be necessary for the
WDHB to suspend employees suspected of being involved in alleged fraud, theft, or corruption for the
duration of the investigation and subsequent proceedings. (Refer to the WDHB’s
Discipline
Procedures.)
Loss control strategies will be considered as early as possible in any investigation. Where appropriate,
recovery action wil be initiated (i.e. action wil be taken against the suspected individual’s assets and/or
income).
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Response to Allegations of Fraud, Theft or Corruption Policy
Where experts are retained to undertake an investigation for the WDHB, the Investigation Coordinator
will ensure (at an appropriate time that does not jeopardise the investigation) that the individual(s)
involved in the alleged fraud, theft, or corruption is /are:
made aware of the allegation
made aware of their rights, including the right to representation
provided with the opportunity to provide an explanation before any final decisions are made.
Retaining detection and investigation experts
The
Investigation Coordinator may retain detection and investigation experts to assist with preliminary
assessments of allegations and to undertake investigations for the WDHB. The selection of external
experts will take into account whether the expert(s) (and their organisation) have:
sufficient standing, qualifications, capabilities and relevant experience
the ability to meet security clearance requirements for the task that they are engaged to do and
no conflict of interest (real or apparent) in terms of their relationship both with the WDHB and the
individual(s) under investigation.
External experts must be asked to comply with relevant legislative provisions and government policy
Act
(particularly in relation to the collection, handling, storage, use or disclosure of information) and with
the
confidentiality provisions of this policy and any additional provisions that may be specified in their
contract.
Investigation outcome
At the completion of an investigation, the
Investigation Coordinator will seek investigation findings and
Information
information regarding the causes of the fraud, theft, or corruption from the enforcement agency
involved or the experts retained by the WDHB. Investigation findings will not be disclosed or discussed
with anyone other than those who have a legitimate need to know.
Based on this information, the Investigation Coordinator will propose a set of options, including
Official
suggestions for preventing the situation from happening again, to the Chief Executive Officer (or the
Board Chair and Audit & Risk Committee Chair should a conflict of interest exist). These actions may
the
include, but are not limited to:
legal proceedings
under
dismissal
disciplinary action
close monitoring of the situation or
no further action. Released
If a decision is made to monitor the situation, adequate information should be retained on file to enable
an investigation to be reactivated if necessary. All investigations may be reopened upon the receipt or
discovery of new evidence.
In those cases where an employee is found guilty of an offence that amounts to a fundamental breach
of his or her responsibilities as an employee (e.g. theft as a servant), the employee is liable for
dismissal and details of the prosecution will be made public, except cases where exceptional
circumstances exist to render such action inappropriate.
Feedback will be given to the individual who reported the matter, where appropriate.
Confidentiality
Information relating to the allegation and investigation process
Confidentiality needs to be maintained for a number or reasons, for example to avoid mistaken
accusations damaging the audit trail alerting the suspected individual(s) to or prejudicing any
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Response to Allegations of Fraud, Theft or Corruption Policy
investigation that may be under way or damaging the reputation of the suspected individual(s) who are
innocent.
Individuals who report, are involved in, or become aware of an allegation of
fraud, theft, or corruption
must keep details and assessment / investigation findings confidential, unless prior authorisation to
disclose such information is granted by the
Investigation Coordinator or disclosure is absolutely
necessary (e.g. in the context of confidential counselling sessions). Employees who breach
confidentiality will be subject t
o disciplinary action.
Experts retained by the WDHB and any other on-site investigation team members should not express
opinions or conclusions concerning the matter under investigation to the individual who made the initial
report, employees, the media, or members of the public, unless specifically authorised to do so by the
Investigation Coordinator.
Identity of person reporting suspected wrongdoing
Where the reporting individual requests that their identity be kept confidential, the WDHB will make
best endeavours not to disclose any identifying information. However, confidentiality cannot be
guaranteed. For example, confidentiality may not be able to be maintained where disclosure of
identifying information is in the public interest or is essential to having regard for the principles of
natural justice, the effective investigation of an allegation, or legal proceedings. Should such a
situation arise, the WDHB will make every effort to forewarn the individual concerned that their identity
Act
may become known. (Refer also to the Disclosure of a Serious Wrongdoing Policy.)
Information management
Access to information
For the purposes of assessing and investigating allegations of
fraud, theft, or
corruption, the
Investigation Coordinator shall have (and may sub-delegate):
Information
free and unrestricted access to all WDHB records, computer equipment, premises and storage
facilities
Official
the authority to examine, copy and/or remove all or any portion of the contents of files, desks,
cabinets on WDHB premises or in storage facilities (electronic or otherwise) without prior
the
knowledge or consent of any individual who might use of have custody of such items or facilities
when it is within the scope of assessment or investigation.
Note: The Investigation Coordinator (or delegate) must have a reasonable suspicion or cause before
under
proceeding. Items may only be removed if reasonable grounds exist to suggest relevance. It may be
appropriate for a schedule of removed items to be provided to the person who held them. Particular
care must be taken in accessing an employee's office computer files or personal property held on
WDHB premises without the employee’s permission or knowledge.
Requests from individual(s) alleged to be involved to have access to the investigation file will be
Released
considered on a case by case basis. Such access would not normally be given until the matter had
been resolved. Access to all or part of the file will be denied where a disclosure was made under the
Protected Disclosures Act 2000 and where this is necessary to protect the reporting individual(s).
Records management
All information relating to allegations of fraud, theft, or corruption, activities undertaken to assess and
investigate such allegations, and any subsequent proceedings must be placed on a secure file and
managed in accordance with the WDHB information management principles (which require adherence
to relevant legislation and Standards such as the Public Records Act 2005 and AS4390 Australian
Standard on Records Management).
The Investigation Coordinator should ensure that external experts do not retain sensitive information
relating to any investigation once proceedings are complete (especially material identifying the subject
of and individuals involved in the investigation). Particular care should be exercised with regard to
computer-based HR and financial management systems. Information should at all times remain the
property of the Crown.
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Response to Allegations of Fraud, Theft or Corruption Policy
Personal information
Reports of suspected
fraud, theft, or
corruption and records relating to the assessment and
investigation of such allegations, as well as any subsequent proceedings, may contain personal
information. Such information must be stored securely in the WDHB’s records repository, in
accordance with the Privacy Act 1993 and other relevant legislation and Standards, such as those
regarding record keeping.
Care must be taken to ensure the existence of the information is not identifiable to the detriment of the
individual(s) alleged to have been involved or individuals who were part of an investigation, such as
witnesses.
Personnel files
Where an allegation is proven, copies of documents relating to any investigation in respect of a WDHB
employee for involvement in work-related fraud, theft, or corruption, should be placed on that
employee’s personnel file in a sealed envelope.
Where an allegation is unproven, this must be clear from the file and copies of documents relating to
any investigation in respect of a WDHB employee for involvement in work-related fraud, theft, or
corruption, should be placed on that employee’s personnel file in a sealed envelope. The employee
concerned may request that the documents be removed from their personnel file. Such requests will
Act
be considered on a case by case basis.
Procedures
Internal reporting
WDHB employees who discover, suspect, or are alerted to irregularities or improprieties are expected
to report these immediately.
Information
There are a number of ways that employees can report their concerns. Which reporting procedure is
appropriate will depend upon the seriousness of the matter and whether the employee wishes to invoke
the protections under the
Protected Disclosures Act 2000.
Official
Employees
must not attempt to investigate their concerns themselves or to contact the suspected
individual(s) in an effort to determine the facts. It is important that employees treat information relating
the
to an allegation responsibly an
d confidentially.
Reporting suspected serious wrongdoing
under
Where the nature of the allegation involv
es serious wrongdoing within or by the WDHB, employees
should consider whether they wish to make a protected disclosure. The Protected Disclosures Act
2000 provides protection from civil and criminal prosecution, retaliatory action by the employer and
victimisation, provided all of the criteria for protection are met. Special internal procedures that must
be followed by employees seeking protection under the Act are contained in the WDHB’
s Disclosure of
Released
a Serious Wrongdoing Policy
Reporting suspected fraud, theft or corruption
To report susp
ected fraud, theft or corruption (where the employee does not wish to seek protection
under the Protected Disclosures Act 2000 or the criteria for protecting a disclosure have not been met)
the employee should contact the
Investigation Coordinator in the first instance.
Where this is not practicable or a conflict of interest exists, any Deputy Commissioner may be
contacted.
The
Deputy State Services Commissioner or the
State Services Commissioner may be contacted in
cases where the reporting individual either believes that the designated contact people may be involved
in the matter or is no longer employed by the WDHB.
Reporting minor concerns
Employees who become aware of minor irregularities or improprieties that do not necessarily constitute
fraud, theft, or corruption (e.g. financial reporting errors, wastage of WDHB resources, and/or non-
compliance with internal controls) are encouraged to advise a member of the WDHB's management
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Response to Allegations of Fraud, Theft or Corruption Policy
team of their concerns. The rationale for reporting minor concerns i
s risk management - early reporting
of areas of concern can prevent a situation from becoming serious and may provide opportunities for
improving the WDHB’s internal management systems.
Reports from external parties
Employees contacted by someone external to the WDHB wishing to report susp
ected fraud, theft, or
corruption, should first determine whether that individual is attempting to make a protected disclosure
concerning
serious wrongdoing in or by
organisations other than the WDHB.
External parties wanting to report susp
ected fraud, theft, or corruption in or by the WDHB should be
directed immediately to the
Investigation Coordinator. The individual making the report should be
informed of the
confidentiality provisions of this policy.
Where the reporting individual does not wish to contact the Investigation Coordinator himself or herself,
the employee should record (when contacted or as soon as practicable thereafter) as many of the
details required to prepare a
Record of Report and pass this information on to the Investigation
Coordinator as soon as possible.
If a written allegation is received, record the date of receipt and pass it (and related documentary
evidence) directly and immediately to the Investigation Coordinator.
Anonymous reports
Act
Anonymous reports, while not encouraged, will be treated seriously and should contain sufficient
information for the Investigation Coordinator (or other designated contact person) to prepare a Record
of Report.
Employees contacted by someone external to the WDHB wishing to make a report and requesting that
this to be treated as anonymous (i.e. they want their identity to be kept confidential), should refer to the
Information
confidentiality provision relating to identity in this policy.
External reporting
Employees wishing to report susp
ected fraud, theft, or corruption should follow the WDHB'
s internal
Official
reporting procedures in the first instance. An exception is provided for by the Protected Disclosures
Act 2000, which permits a protected disclosure of
'serious wrongdoing' to be made immediately to
the
external appropriate authorities', as defined in the Act, where the employee has reasonable grounds to
believe that this action is justified by the urgency of the matter, or some other exceptional circumstance
(e.g. if the employee cannot approach any of the contact people designated in the
Disclosure of a
under
Serious Wrongdoing Policy, because they may be involved or associated with the serious wrongdoing
alleged in the disclosure).
Process subsequent to a report of alleged wrongdoing being made
Record of report
Released
The Investigation Coordinator, or other internal designated person who is approached, needs to
document the allegation and will either ask the reporting individual to put their concerns in writing using
a Record of Report Form or will prepare the record of report for sign off by the reporting individual.
This and other documents prepared in relation to the allegation will be kept on a secure file.
Information gathering
Upon receiving a report of suspected fraud, theft, or corruption, the Investigation Coordinator will begin
collecting (or supervise the collection of) readily accessible evidentiary information in order to
undertake a preliminary assessment of the allegation and, where necessary, an investigation. Note
that maintaining
confidentiality is particularly important at this stage, as the individual(s) allegedly
involved will not normally be alerted to the process of gathering and assessing evidentiary information.
The Investigation Coordinator and other persons involved in the preliminary assessment and any
investigation (e.g. investigation experts or Police officers) may need to interview the individual who
reported the suspected fraud, theft, or corruption, as well as any other individuals who may be able to
assist, for the purposes of seeking clarification and gathering further evidence.
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Response to Allegations of Fraud, Theft or Corruption Policy
Feedback to reporting individual
When the investigation is complete, the individual(s) will be advised, where appropriate:
that the investigation is complete
whether or not any evidence was found to support the allegation and
confirm that appropriate action has been taken.
(Note: details of any disciplinary action taken against the individual(s) involved will not be disclosed).
Complaints
Individuals who believe that an allegation has not been satisfactorily dealt with or have concerns about
the investigation process should discuss these with the
Investigation Coordinator or, where a conflict of
interest exists, with the Chief Executive Officer.
Dealing with enquiries
All enquiries concerning the matter under investigation, including those from the suspected
individual(s), their representatives, or the media, should be directed to the
Investigation Coordinator.
Employees may not give out any information concerning the status of a preliminary assessment or
investigation without prior authorisation from the Investigation Coordinator. Under no circumstances
Act
should any specific references be made to the allegation or the nature of the allegation.
Information
Official
the
under
Released
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RECORD OF REPORT FORM FOR SUSPECTED FRAUD, THEFT &
CORRUPTION
Provide a summary of the matter.
Provide the source of the information and explain how the individual(s) become aware of this matter.
Act
Provide the names and positions of any public servants believed to be involved.
Information
Official
the
Provide the names and addresses of any private citizens or companies believed to be involved.
under
Note significant times, dates, and locatio
Released ns relating to this matter.
Has the matter been raised with anyone else in the WDHB or been reported to an external agency? If
so, please provide names and dates.
Record of Report Form for Suspected Fraud, Theft & Corruption
List and describe any supporting evidence (documents, records, etc).
Are there other people who know about this matter who could assist in any investigation? (e.g. original
witnesses or informants). If so, please provide their names and contact details, and indicate whether
they are aware that this report has been made.
Individual who prepared this written record:
Act
Name:
……………………………………………………….
Designation: ……………………………………………………….
Information
Official
Signature:
………………………………… Date:
………………………
the
Individual who reported the matter:
I agree that this written record is an accurate record of the matter I wish to report.
under
Name:
……………………………………………………….
Contact
Released
Details:
……………………………………………………….………………………………………………………
.
Signature:
………………………………… Date:
………………………
Record of Report Form for Suspected Fraud, Theft & Corruption
To be completed by WDHB employees who make a report:
I understand that:
this disclosure will not be protected under the Protected Disclosures Act 2000 unless I follow the
special internal protected disclosures procedures set out in the WDHB’
s Disclosure of a Serious
Wrongdoing Policy
I need to comply with the confidentiality provisions set out in the
Response to Allegations of Fraud,
Theft and Corruption Policy
even if I request for my identity to be kept confidential, there may be reasons (e.g. where disclosure
of identifying information is in the public interest or is essential to having regard for the principles of
natural justice, the effective investigation of an allegation, or legal proceedings) to disclose
identifying information.
Signature:
………………………………… Date:
………………………
Act
Once this form is completed it should be given to the Investigation Coordinator. (This is usually the
Chief Financial Officer & General Manager Corporate Services but if you are unsure check the
Response to Allegations of Fraud, Theft and Corruption Policy.)
Information
ADMINISTRATIVE USE ONLY
Contact Person:
Official
Date and time of receipt:
………………………………………
the
Signature:
………………………………………
Designation:
………………………………………
under
Investigation Coordinator:
Date and time of receipt:
………………………………………
Released
Signature:
………………………………………
