Appendix One OIA 03086 John FYI website Anti Fraud Policy February 2025.pdf

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Anti-Fraud Policy
February 2025

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1. Objective
1.1 This policy relates to all forms of fraud, corruption and bribery and its purpose is to provide
direction and help to all those who may identify or  suspect fraud. The policy details the
commitment of Oranga Tamariki to the proper use of public funds, outlines the roles and
responsibilities  for  the  prevention  of  fraud  and  the  policy  for  dealing  with  detected  or
suspected fraud and bribery.
2. Scope
2.1 The policy applies to all fraud incidents, whether suspected or proven, that are committed
against Oranga Tamariki by any person (defined by section 2 of the Crimes Act 1961) and
further outline  in the definitions section  (Section 10). The scope of this policy  is directly
linked to these definitions, ensuring clarity and consistency in its application. This policy
should be read in conjunction with the Anti-Fraud Standard Operating Procedure.
2.2 This policy applies to all:
•  Employees  of  Oranga  Tamariki  (permanent,  fixed  term/temporary,  casual  and
seconded).
•  Consultants and contractors, contractor staff, sub-contractors, or affiliated persons with
third parties (including partners that have access to CYRAS).
•  Members including independent members of an Oranga Tamariki committees, boards,
panels, advisory groups, governance groups, steering group or roopu;
•  Volunteers who work without reward and provide services to Oranga Tamariki or to
tamariki or rangatahi in the care or custody of the Chief Executive.
2.3 The term ‘individual’ in supporting information refers to all those  above. This means we
expect all those within the scope to understand and comply with this policy.
3. Policy statements
3.1 All individuals  have a personal responsibility to protect  Oranga Tamariki  assets -
Including all buildings, equipment and monies from fraud, theft, or bribery. It is expected
that  individuals  at  all  levels  will  lead  by  example  in  acting  with  the  utmost  integrity  and
ensuring adherence to all relevant regulations, policies and procedures.

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3.2 Oranga Tamariki is committed to maintaining an honest and open environment - We
uphold a zero tolerance approach to fraud and are dedicated to the rigorous investigation
of  any  allegations.  This  commitment  extends  to  taking  appropriate  action,  which  may
include criminal prosecution, the recovery of lost assets, and ensuring that our processes
remain fair and free from any fraudulent activity.
3.3 Any  malicious  allegations  will  be  subject  to  a  full  investigation  and  appropriate
disciplinary  action  -  We  are  committed  to  ensuring  a  fair  and  transparent  process  for
addressing any concerns or allegations. Allegations made with intent to harm the Ministry,
its  employees,  or  its  reputation  will  be  taken  seriously  and  investigated  thoroughly.
Individuals found to have made malicious or baseless claims will be subject to appropriate
disciplinary action.
3.4 Oranga Tamariki expects anyone having reasonable suspicions of fraud to report
them - We recognise that, while cases of theft are usually obvious, there may initially only
be  a  suspicion  regarding  potential  fraud  and,  thus,  individuals  should  report  the  matter
appropriately.
3.5 Oranga  Tamariki  will  implement  procedures  to  prevent  fraud  through  robust
controls and risk assessment – we have procedures in place that reduce the likelihood
of fraud occurring. These include financial controls and documented procedures, a system
of internal control (including Internal and External Audit) and a system of risk assessment.
The adequate procedures put in place by the organisation to prevent fraud are informed
by six principles – proportionate procedures, top-level commitment, risk assessment, due
diligence, communication (including training), monitoring and review.
3.6 Oranga Tamariki will undertake risk assessments to assess fraud – and how it may
affect the organisation at least every three years. The risk assessment will be led by the
Risk and Internal Assurance Team, who will report to the Chief Financial Officer and Te
Riu.
3.7 Oranga  Tamariki  does  not  tolerate  any  fraud  -  even  if  this  might  result  in  a  loss  of
business for it. Criminal liability must be prevented at all times. Any instances of suspected
fraud may be referred to the Police or relevant authorities for further investigation, ensuring
appropriate legal action is taken.
Code of Conduct
3.8 The code of conduct for Oranga Tamariki set out the key public service values. It states
that  high  standards  of  corporate  and  personal  conduct,  based  on  the  recognition  that
tamariki come first, have been a requirement throughout the Ministry since its inception.
3.9 The  below  diagram  sets  out  the  behaviours  we  will  demonstrate  when  we  uphold  our
values in the context of fraud management.

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3.10
In addition, all individuals who work for or are in contract with Oranga Tamariki should
exercise the following when undertaking their duties:
•  Selflessness - should take decisions solely in terms of the public interest. They
should not do so in order to gain financial or other material benefits for themselves,
their family or their friends
•  Integrity - should not place themselves under any financial or other obligation to
outside individuals or organisations that might influence them in the performance
of their official duties
•  Objectivity  -  should,  in  carrying  out  public  business,  (including  making  public
appointments, awarding contracts, or recommending individuals for rewards and
benefits), make choices on merit
•  Accountability - are accountable for their decisions and actions to the public and
must submit themselves to whatever scrutiny is appropriate to their office
•  Openness - should be as open as possible about all the decisions and actions that
they take. They should give reasons for their decisions and restrict information only
when the wider public interest demands
•  Honesty - have a duty to declare any private interests relating to their public duties
and to take steps to resolve any conflicts arising in a way that protects the public
interest
•  Leadership  -  should  promote  and  support  these  principles  by  leadership  and
example
•  Legal compliance - if exercising any powers under the Oranga Tamariki Act 1989,
they must also be guided by the principles outlines in the Act, ensuring decisions
and actions are consistent with statutory obligations and the public interest.

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4. Values
4.1 Our anti-fraud policy reflects the Ministry’s core value We are tika and pono by ensuring
integrity  and  accountability  are  upheld  across  all  operations.  By  proactively  preventing,
detecting,  and  addressing  fraudulent  activity,  we  demonstrate  our  commitment  to
maintaining  trust  with  our  stakeholders.  This  policy  ensures  that  every  action  we  take
aligns  with  our  promises,  fostering  a  culture  of  transparency  and  responsibility  in
everything we do.
5. Accountabilities
5.1 The  Chief  executive  has  overall  accountability,  while  the  Director  of  Risk  and  Internal
Assurance  is  responsible  for  the  implementation,  monitoring  and  compliance  with  this
policy.
6. Roles and responsibilities
6.1 Below are the key roles and accountabilities relating to this Policy.

Role
Accountability
Chief Executive
•  Has accountability for decisions relating to complex
cases.
•  Is accountable for funds entrusted to the Ministry,
including addressing instances of fraud.
Leadership Team
•  Approves the Anti-Fraud Policy and the Standard
(Collectively)
Operating Procedures
•  Sets the tone at the top and ensures an appropriate
and effective system of internal controls is in place.
•  Exercises a high standard of judgement in relation
to managing and reporting of fraud.
Deputy Chief Executives  •  Oversee their Group’s compliance with the system
(Individually)
of internal controls and provide assurance to the
Chief Executive that they are being identified and
managed.
•  Act in line with the Fraud Policy where instances of
fraud or corruption has occurred including in their
respective areas.
Director Risk and
•  Ensures there is fraud and corruption awareness
Internal Assurance
education/a training programme as a preventative
(Policy Owner)
measure to minimise the incidents of fraud and
corruption.
•  Ensure the policy is complied with, in line with
Protected Disclosure Policy and the Speak Up Staff
Guide

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•  Develops, maintains and disseminates the Anti-
Fraud Policy and the Standard Operating
Procedures.
•  Ensures all suspected cases of frauds are duly
investigated and where applicable, are reported to
the Police and/or Serious Fraud Office.
•  Ensures confidentiality when conducting fact finding
investigations in alignment with natural justice.
•  Provides recommendations to ensure control
deficiencies are remedied to prevent future
incidents of fraud or corruption.
•  Reports regularly on notifications received,
investigations undertaken and outcomes to the Risk
and Assurance Committee (RAC) and Fraud and
Integrity Assessment Team (FIAT)
All Managers
•  Reinforce and monitor their staff’s adherence to
internal controls, and the Ministry’s policies and
procedures to ensure these are not ignored or
overridden.
•  Ensure that an adequate system of internal control
exists within their areas of responsibility and that
controls operate effectively. The responsibility for
the prevention and detection of fraud therefore
primarily rests with managers but requires the co-
operation of all individuals.
•  Ensure they are aware of indicators of fraudulent or
other potential inappropriate activity and
understand how to report any suspected incidents.
It is appreciated that some individuals will initially
raise concerns with their manager, however, in
such cases managers must not attempt to
investigate the allegation themselves, and they
have the clear responsibility to refer the concerns to
the Fraud and Integrity Team.
Individuals
•  Note, understand and comply with the Fraud Policy.
•  Be aware of and comply with the Public Service
Commission Standards of Integrity and Conduct for
the public sector.
•  Ensure that Oranga Tamariki assets are protected
and only used for Ministry purposes.
•  Ensure to act in accordance with the standards laid
down by their professional body(ies) where
applicable and have personal responsibility to
ensure that they are familiar with them.

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•  Ensure to comply with all applicable laws and
regulations relating to ethical business behaviour,
procurement, personal expenses, conflicts of
interest, confidentiality and the acceptance of gifts
and hospitality. This means, in addition to
maintaining the normal standards of personal
honesty and integrity, all individuals should always:
•  act with honesty, integrity and in an ethical manner
o  avoid acting in any way that might
cause others to allege or suspect them
of dishonesty
o  behave in a way that would not give
cause for others to doubt that Ministry‘s
employees and associated individuals
deal fairly and impartially with official
matters
o  be alert to the possibility that others
might be attempting to deceive
•  Report any suspected or actual incidents of fraud
and corruption immediately.
People and High
•  Provide professional advice in undertaking any
Performance
disciplinary process which may be initiated because
of a fact-finding investigation.
•  Ensure that appropriate steps are taken when new
employees are appointed to establish, as far as
possible, their previous record of potential
employees as well as the veracity of required
qualifications and memberships of professional
bodies, in terms of their propriety and integrity.
Risk and Assurance
•  Provides independent, strategic advice to the CE
Committee (RAC)
on risk (including fraud risk) and assurance matters.
•  The Risk and Assurance Committee are
responsible for seeking assurance that Oranga
Tamariki has adequate arrangements in place for
countering fraud.
External Parties
•  Those organisations undertaking work on behalf
Oranga Tamariki are expected to maintain strong
anti-fraud principles and have adequate controls in
place to prevent fraud when handling public funds
and dealing with customers on behalf of the
Ministry. Contractors and sub-contractors acting on
the Ministry’s behalf are responsible through
contractual arrangements put in in place during the
tender process and through contracts, for

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compliance with the laws of New Zealand and with
this policy.
Any allegations or suspicions of fraud involving
external parties will be referred to the appropriate
authority for independent investigation, in line with
legal and contractual obligations.

7. Measures of success and compliance
management
7.1 The  policy  owner  will  assess  the  effectiveness  of  this  policy  based  on  the  following
measures of success:
•  The number of substantiated fraud incidents trends downwards as a result of
strengthening control environment
•  Increase successful prosecution of perpetrators where a fraud has been
established.
•  Implementation of counter fraud and prevention measures across the ministry.

7.2 The policy owner will monitor compliance with the policy as follows:
•  The Risk and Internal Assurance team will monitor overall compliance with this
policy and obtain feedback on its effectiveness.
•  A central register to record all fraud and integrity notifications will be held by the
policy owner.
•  All notifications will be assessed and investigated in accordance with Ministry
investigation processes.

8. Non-compliance
7.1 Failure to comply with this policy may be considered a breach of the Code of Conduct.
7.2 Any action taken as a result of a breach (actual or potential) of any of the obligations set
out in this policy will be conducted in good faith, a fair process will be followed, and the
person involved will have a full opportunity to respond to the concerns or allegations and
have access to appropriate support, advice or representation.
7.3 Non-compliance may be dealt with in accordance with the Oranga Tamariki Disciplinary
Policy  (if  the  breach  involves  a  Ministry  employee)  or  as  deemed  appropriate  by  the
Ministry and/or in accordance with any written contract for breaches by non-employees.
Managers who failed to fulfil their responsibilities outline within the Anti Fraud Policy may
be  subject  to  Oranga  Tamariki  disciplinary  processes.  Breaches  must  be  reported  in
accordance with Corporate Policy Requirements Policy.
9. Contacts
9.1 The Risk and Internal Assurance Team is the main point of contact for questions regarding
this policy and can be reached at [email address]

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10.  Definitions
10.1
In this policy the following definitions apply:

Term
Definition
Prevention
•  Reducing the risk of fraud from eventuating in the first place
through exercising strong controls.
Detection
•  Uncovering fraud at the earliest opportunity if it occurs and
providing effective options to report, manage and respond.
Response
•  Taking immediate corrective action and remedying the harm
caused by fraud, including the preservation of crucial
evidence to achieve a successful outcome.
Fraud
•  Fraud is dishonestly obtaining a benefit, or causing a loss, by
deception or other means. Fraud requires intent. It requires
more than carelessness, accident, or error. When intent
cannot be shown, an incident may be non-compliance rather
than fraud.
Examples of fraud include:
•  deliberate mishandling or misreporting of money or other
financial transactions
•  unauthorised access and misuse of Oranga Tamariki
systems and information for gain
•  submission of fraudulent claims for goods and/or services
•  unauthorised or illegal use/disclosure of confidential or
proprietary information
•  forging, falsifying or destroying documents, computer files
or records belonging to Oranga Tamariki e.g. purchase
orders, invoices.
•  theft (described further below).
•  corruption (described further below).
Theft
•  Acts dishonestly and without claim of right, takes, uses or
deals with any property with intent to deprive any owner
permanently of that property or of any interest in that
property.
Examples of theft include:
•  unauthorised access and/or sale of information (for
example, including that relating to Oranga Tamariki, its
employees, tamariki or any persons involved with the
Ministry)
•  unauthorised possession, use or misappropriation of
funds or property/assets belonging to Oranga Tamariki or
its employees
•  destruction, removal or inappropriate use of records,
equipment, furniture for gain
•  deliberate misuse of Oranga Tamariki resources e.g. work
time, vehicles, IEP and Corporate Cards, purchase
orders, taxi charge cards, mobile phones, and/ or
computers, for personal gain.

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Corruption
•  The abuse of entrusted power for personal gain or the benefit

of others, which undermines the integrity and effectiveness of
the Ministry’s operations. This includes activities such as
bribery, fraud, embezzlement, favouritism, and any other
conduct that compromises ethical standards and public trust.
            Examples of potentially corrupt practices include:
•  using knowledge, power, or resources of your position for
personal gain or the advantage of others
•  disclosing private, confidential, or proprietary information
to outside parties without consent
•  accepting or seeking anything of material value from
suppliers or other persons providing goods or services in
return for using them
•  members of the public trying to influence employees of
Oranga Tamariki to use their position in a way that is
dishonest, biased or breaches public trust
•  undeclared conflicts of interest that could adversely
impact Oranga Tamariki.

11.  Mandate
11.1. The mandate for this policy originates from the Standards of Integrity and Conduct. This
is  a  code  of  conduct  issued  by  the  Public  Service  Commissioner.  The  Public  Service

Act 2020. Clause 8 in Part C of Schedule 1 of that Act provides that the Standards of

Integrity and Conduct are to be treated as containing minimum standards set by the

Public Service Commissioner under Section 17 of the Public Service Act.
11.2. This Fraud Policy is based on the Standards of Integrity and Conduct, and it is therefore
a  reminder  to  all  Oranga  Tamariki  employees that  they  should  always be  honest  in  all
their dealings, and no one should use their position to gain advantages to which they are
not entitled. Poor judgment or ignorance of the law and what constitutes fraud does not
provide a defence to potential civil or criminal action.
12.  References
12.1 Additional information that supports the Fraud Policy can be found in:
•  Anti-Fraud Standard Operating Procedures (including the Fraud Investigation
Process)
12.2 This policy links to all policies at Oranga Tamariki, particularly those relating to:
•  Code of Conduct
•  Financial Delegations Policy
•  Sensitive Expenditure Policy and SOP
•  Travel Policy and SOP
•  Procurement Policy
•  Incidental Expenditure Payment (IEP) Care Policy

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•  Acceptable Use of OT Technology and Services Policy
•  Protected Disclosures (Whistle Blowing) Policy and Process Guidelines
•  Disclosure of Interest Policy
•  Privacy Policy
12.3 This Policy also links to:
•  Crimes Act 1961
•  Protected Disclosures (Protection of Whistleblowers) Act 2022
•  The Privacy Act 1993
•  The Public Records Act 2005
•  Health and Safety in Employment Act 1992
•  Employment Relations Act 2000
13.  Version control

Version
Date
Change Reason
1.0
March 2019
Latest published version.
2.0
February 2025
Significant changes were made to ensure
processes are robust against emerging risks
and better aligned with Oranga Tamariki
values.

POLICY OWNER
Director Risk and Internal Assurance
POLICY SPONSOR
General Manager, Office of the Chief Executive
DATE APPROVED
February 2025
DATE OF NEXT REVIEW    February 2027

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