Introduction
This document sets out the policy and procedures of the company against fraud and other forms of dishonesty.
It applies to Directors, Managers and staff. Anybody associated with the company who commits fraud, theft or any other dishonesty, or who becomes aware of it and does not report it, will be subject to appropriate disciplinary action.Statement of intent
the company will continually strive to ensure that all its financial and administrative processes are carried out and reported honestly, accurately, transparently and accountably and that all decisions are taken objectively and free of personal interest. We will not condone any behaviour that falls short of these principles.
All members of the company have a responsibility for putting these principles into practice and for reporting any breaches they discover.

Definitions
a) Fraud: A deliberate intent to acquire money or goods dishonestly through the falsification of records or documents. The deliberate changing of financial statements or other records . The criminal act is the attempt to deceive and attempted fraud is therefore treated as seriously as accomplished fraud
b) Theft: Dishonestly acquiring, using or disposing of physical or intellectual property belonging to the company or to individual members of the organisation.
c) Misuse of equipment: Deliberately misusing materials or equipment belonging to the company for financial or material benefit.
036-PO-Anti-Fraud Policy-v1 pg. 2
d) Abuse of position: Exploiting a position of trust within the organisation for financial or material benefit.

Culture
The company fosters honesty and integrity in its entire staff. Directors, managers and staff are expected to lead by example in adhering to policies, procedures and practices. Equally, members of the public, service users and external organisations (such as suppliers and contractors) are expected to act with integrity and without intent to commit fraud against the company.
As part of this, the company will provide clear routes by which concerns may be raised by employees. Details of this can be found in the the company Staff Handbook.
Senior management are expected to deal promptly, firmly and fairly with suspicions and allegations of fraud or corrupt practice

Responsibilities
In relation to the prevention of fraud, theft, misuse of equipment and abuse of position, specific responsibilities are as follows:
a) Non-Executive Directors:
The Directors are responsible for establishing and maintaining a sound system of internal control that supports the achievement of the Company’s policies, aims and objectives.
The system of internal control is designed to respond to and manage the whole range of risks which the Company faces.
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. Managing fraud risk is seen in the context of the management of this wider range of risks.
b) The Managing Director
Overall responsibility for managing the risk of fraud has been delegated to the Managing Director. The day to day responsibility has been delegated to the Finance and Business Support Manager to act on behalf of the Managing Director.
Their responsibilities include:
• Undertaking a regular review of the fraud risks associated with each of the key organisational objectives.
• Establishing an effective anti-fraud response plan, in proportion to the level of fraud risk identified.
• The design of an effective control environment to prevent fraud.
• Establishing appropriate mechanisms for:
o reporting fraud risk issues
o reporting significant incidents of fraud or attempted fraud to the Board of Director;
• Liaising with the company’s appointed Auditors.
• Making sure that all staff are aware of the company’s Anti-Fraud Policy and know what their responsibilities are in relation to combating fraud;
• Ensuring that appropriate anti-fraud training is made available to Directors, manages and staff as required; and
• Ensuring that appropriate action is taken to minimise the risk of previous frauds occurring in future.
c) Senior Management Team
The Senior Management Team is responsible for:
• Ensuring that an adequate system of internal control exists within their areas of responsibility and that controls operate effectively;
• Preventing and detecting fraud as far as possible;
• Assessing the types of risk involved in the operations for which they are responsible;
• Reviewing the control systems for which they are responsible regularly;
• 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.
d) Staff


Every member of staff is responsible for:
• Acting with propriety in the use of the Company’s resources and the handling and use of funds whether they are involved with cash, receipts, payments or dealing with suppliers;
• Conducting themselves with selflessness, integrity, objectivity, accountability, openness, honesty and leadership;
• Being alert to the possibility that unusual events or transactions could be indicators of fraud;
• Alerting their manager when they believe the opportunity for fraud exists e.g. because of poor procedures or lack of effective oversight;
036-PO-Anti-Fraud Policy-v1 pg. 4
• Reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events; and
• Cooperating fully with whoever is conducting internal checks or reviews or fraud investigations.
e) Agency Workers & Consultants
Every agency worker and consultant is responsible for:
• Acting with propriety in the use of the Company’s resources and the handling and use of funds whether they are involved with cash, receipts, payments or dealing with suppliers;
• Conducting themselves with selflessness, integrity, objectivity, accountability, openness, honesty and leadership;
• Being alert to the possibility that unusual events or transactions could be indicators of fraud;
• Alerting a member of the Senior Management Team when they believe the opportunity for fraud exists e.g. because of poor procedures or lack of effective oversight;
• Reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events; and
• Cooperating fully with whoever is conducting internal checks or reviews or fraud investigations