JAC Fraud Policy Statement

 

1                     Introduction

 

1.1               No organisation or administrative process is free of risk.  Fraud is an ever-present threat and therefore should be a concern to everyone.

 

1.2               The Science & Technology Facilities Council (STFC) requires all staff at all times to act honestly and with integrity and to safeguard the public resources for which they are responsible.  STFC/JAC operates a ‘zero tolerance to fraud’ policy and all suspected cases will be vigorously investigated.  Proven cases will always lead to disciplinary action and will be pursued through the courts if necessary.  All staff at every STFC establishment must comply with the contents of this fraud policy.

 

2                     Scope and Definition of Fraud

 

2.1               Fraud generally involves a wilful or deliberate act with the intention of obtaining an unauthorized benefit, such as money or resources, by deception or other unethical means. All fraudulent acts are included under this policy and include such things as:

§         Embezzlement, misappropriation or other financial irregularities

§         Forgery or alteration of documents (checks, time sheets, contractor agreements, purchase orders, other financial documents, electronic files)

§         Improprieties in the handling or reporting of money or financial transactions

§         Misappropriation of funds, securities, supplies, inventory, or any other asset (including furniture, fixtures or equipment)

§         Authorizing payment for goods not received or services not performed

§         Authorizing or receiving payments for hours not worked

§         Any financial dishonesty that takes place in a computer environment including:  manipulation of data; altering programmes; altering output to obtain an illegal advantage; and, the most common form, inputting fraudulent data into a computer.

 

3                     Deterrence

 

3.1               To prevent fraud it is necessary to be alert to the risks that business systems are susceptible to, to have strong internal controls, and an acceptance of external evaluation and validation of systems and processes.  Everybody should be alert to fraud.  It is diverse, usually concealed and a product of the individual operational situation.  It usually occurs where critical controls are weak or not functioning as intended.

3.2               It is therefore a primary responsibility and duty laid on all staff that they must examine their working procedures with a view to ensuring that adequate controls and checks on the use of JAC resources exist and are applied effectively.

 

4                     General Protocol – Reporting Procedure

 

4.1               Anyone who believes fraud has occurred should report such an incident. Employees are protected under Hawaii; Whistle Blowers Protection Act (HRS Chapter 378); from retaliatory actions by the employer.

4.2               Use the channel of communication with which you are most comfortable. Accordingly, you may report your concerns to your immediate supervisor, Finance Officer, Head of Administration or directly to the Director JAC.

4.3               Supervisors must report all apparent cases of fraud brought to their attention to the Finance Officer, Head of Administration or directly to the Director JAC.

 

5                     Responsibilities

 

5.1               All staff are required to act with honesty and propriety in the use of official funds and resources entrusted to them.

 

5.2               Managers are responsible for establishing and maintaining proper internal controls that provide security and accountability for the resources entrusted to them. Administrators should be familiar with the risks and exposures inherent in their areas of responsibility and be alert for any indications of improper activities, misappropriation, or dishonest activity.

 

5.3               Responsibilities of all staff for handling fraudulent activities include the following:

§         Insure that notification promptly reaches the Finance Officer, Head of Administration or Director JAC.

§         If the situation warrants immediate action – for example, obvious theft has taken place, security is at risk, or immediate recovery is possible – staff receiving reports should immediately contact the police department.

§         Do not contact the suspected individual to determine facts or demand restitution. Under no circumstances should there be any reference to "what you did", "the crime", "the fraud", "the forgery", "the misappropriation", etc.

§         Managers should consult with the Head of Administration to determine if any immediate personnel actions are necessary.

§         Do not discuss the case, facts, suspicions, or allegations with anyone, unless specifically directed to do so.

§         Direct all inquiries from any suspected individual, his or her representative, or his or her attorney to the Director JAC or in his absence, the JAC Head of Administration.

5.4               Great care must be taken in dealing with suspected fraudulent activities to avoid any incorrect accusations, alerting suspected individuals that an investigation is under way, violating any person’s right to due process, or making statements that could lead to claims of false accusation or other civil rights violations.

 

6                     JAC Fraud Response Plan

 

6.1               The JAC has developed a Fraud Response Plan that provides a framework against which any allegation of fraud will be investigated.

 

6.2               The Plan includes provision for the establishment of a Fraud Crisis Committee, which will be responsible for the efficient and effective implementation of the Fraud Response Plan.

 

6.3               The Fraud Crisis Committee may investigate any suspected dishonest or fraudulent activity, which, in its opinion, may represent risk of significant loss of assets or reputation to the JAC.

 

6.4               The Fraud Crisis Committee is available and receptive to receiving relevant information on a confidential basis and may be contacted directly whenever a fraudulent activity is suspected.

 

6.5               The Fraud Crisis Committee may work with internal or external departments, such as the STFC Head Office, Research Councils Internal Audit Service, or the police department.

 

6.6               JAC staff will cooperate with the Fraud Crisis Committee and law enforcement agencies in the detection, reporting, and investigation of fraudulent acts, including prosecution of offenders. The Fraud Crisis Committee has full, free and unrestricted access to all records and personnel of the JAC. Every effort will be made to effect recovery of JAC losses from responsible parties.

 

6.7               The Fraud Crisis Committee will review the results of any investigations with responsible management and administrators as necessary, making recommendations for improvement to the systems of internal control.

 

6.8               The Fraud Crisis Committee may be contacted if guidance is needed to determine if an action might constitute fraud as defined in this policy.

 

6.9               The current members of the JAC Fraud Crisis Committee are:

 

Director JAC/JCMT

Head of UKIRT Operations

Head of Administration

Finance Officer

 

 

JAC Finance Officer

June 2004