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Fraud Policy
Overview
This document contains the framework and principles for the management of
fraud and corruption relating to any parties working with Queenstown Lakes
District Council.
Contents
Topic
See Page
Introduction
1
Policy
3
Introduction
Purpose
The Council is committed to preventing the occurrence of fraud and corruption.
This fraud policy has been established to facilitate the development of controls
that will aid in the detection and prevention of fraud against the Council.
Fraud is defined as ‘the use of deception with the intention of obtaining an
advantage, avoiding an obligation or causing loss to another party’.
It is the intent of Council to promote an anti-fraud culture by providing these
guidelines and by assigning responsibility for the development of controls and
conduct of investigations.
Scope
This policy applies to any fraud, impropriety or dishonesty (suspected or actual),
involving employees of QLDC.
Page 2 of 5
Fraud
Associated
Other documents that are relevant to the contents of this document are:
documents
Type
Title
QLDC Corporate
Staff Handbook
Gifts and Hospitality Policy
Legislation
Privacy Act 1993
Crimes Act 1961
Note: Any legislation referred to should be interpreted
as meaning the Act and its amendments.
Other
Employment Agreements
QLDC Code of Conduct
RFP Process
Reviewed:
August 2017
Issued by:
Human Resources
Authorised by: CEO
This information is correct at date of issue. Always check in the relevant QLDC policy manual that this copy is the most recent version
Page 3 of 5
Fraud
Policy
Principles
Council personnel and contractors must have and be seen to have, the
highest standards of honesty, propriety and integrity in the exercise of their
duties.
Council will not tolerate fraud, impropriety or dishonesty and will
investigate all instances of suspected fraud, impropriety or dishonesty by
Council personnel or contractors.
Council personnel and contractors must not defraud the Council, or other
personnel, clients or contractors of Council.
The Council will take action – including dismissal and/or criminal
prosecution against any member of personnel defrauding or attempting to
defraud the Council or other personnel, clients or contractors of Council. In
every case the Council will make every effort to gather sufficient reliable
evidence to support a prosecution.
The Council will always seek to recover funds lost through fraud.
Definitions
The terms fraud, impropriety and dishonesty refer to, but are not limited to:
Any dishonest or fraudulent act;
Misappropriation of funds, securities, supplies, or other assets;
Impropriety in the handling or reporting of money or financial
transactions;
Profiteering as a result of insider knowledge of Council activities or
activities of Council Controlled Organisations;
Disclosing confidential and proprietary information to outside
parties;
Disclosing to other persons securities activities engaged in or
contemplated by the Council or any Council Controlled Organisation;
Accepting or seeking anything of material value from contractors,
vendors, or persons providing services/materials to the Council or
any Council Controlled Organisation. An exception is made for gifts
of less than $100 in value in accordance with the Gifts Policy;
Destruction, removal, or inappropriate use of records, furniture,
fixtures and equipment; and/or
Any similar or related irregularity.
Reviewed:
August 2017
Issued by:
Human Resources
Authorised by: CEO
This information is correct at date of issue. Always check in the relevant QLDC policy manual that this copy is the most recent version
Page 4 of 5
Fraud
Application
Management
Management is responsible for the detection and prevention of fraud,
Responsibilities
impropriety and dishonesty. Each member of the management team will
be familiar with the types of improprieties that might occur within his or
her area of responsibility, and be alert for any indication of irregularity.
Management should be alert to the possibility that unusual events may be
symptoms of fraud or attempted fraud and that fraud may be highlighted
as a result of management checks or be brought to their attention by a
third party.
They are responsible for:
Being aware of fraud; and
Ensuring that an adequate system of internal controls exists within
their area of responsibility and that those controls are operating
effectively.
These controls should include a system for undertaking regular reviews of
transactions and activities that may be susceptible to fraud.
Any irregularity that is detected or suspected must be reported
immediately to the CEO, who coordinates all fraud investigations.
Investigation
The CEO has the primary responsibility for the investigation of all
Responsibilities
suspected fraudulent acts as defined in the policy. This may require the
formation of an investigation team comprising suitably qualified persons
(these could be staff or external parties). This responsibility will include
full documentation of the facts and circumstances of the matter.
If the investigation substantiates that fraudulent activities have occurred,
the CEO will issue reports to appropriate designated personnel and, if
appropriate, to the Office of the Auditor General through the Finance and
Corporate Accountability Committee.
Decisions to prosecute or refer the examination results to the appropriate
law enforcement and/or regulatory agencies for independent
investigation will be made in conjunction with legal counsel and senior
management.
Confidentiality
The CEO will treat all information received confidentially. Any employee
who suspects dishonest or fraudulent activity will notify the CEO
immediately, and should not attempt to personally conduct investigations
or interviews/interrogations related to any suspected fraudulent act (see
Reporting Procedure section below).
Reviewed:
August 2017
Issued by:
Human Resources
Authorised by: CEO
This information is correct at date of issue. Always check in the relevant QLDC policy manual that this copy is the most recent version
Page 5 of 5
Fraud
Investigation
Members of the Investigation Team as appointed by the CEO will have:
Authorisation
Free and unrestricted access to all Council records and premises,
whether owned or rented; and
The authority to examine, copy, and/or remove all or any portion
of the contents of files, desks, cabinets, and other storage facilities
on the premises without prior knowledge or consent of any
individual who might use or have custody of any such items or
facilities when it is within the scope of the investigation.
Any investigative activity required will be conducted without regard to the
suspected wrongdoer’s length of service, position/title or relationship to
Council.
Reporting
Great care must be taken in the investigation of suspected improprieties
Procedures
or irregularities so as to avoid mistaken accusations or alerting suspected
individuals that an investigation is underway.
An employee who discovers or suspects fraudulent activity will notify the
appropriate person immediately as per the procedures laid down in the
Protected Disclosures Policy; this may be a supervisor, Manager or the
CEO depending on the circumstances.
The employee or other complainant may remain anonymous. All inquiries
concerning the activity under investigation from the suspected individual,
his or her attorney or representative, or any other inquirer should be
directed to the CEO. No information concerning the status of an
investigation will be given out.
The reporting individual should be informed of the following:
Do not contact the suspected individual in an effort to determine
facts or demand restitution.
Do not discuss the case, facts, suspicions, or allegations with
anyone unless specifically asked to do so by the CEO or members
of the Investigation team.
Termination
If an investigation results in a recommendation suspend and/or
consider disciplinary action that made led to the termination an
individual, the recommendation will be reviewed for approval by the
HR Director and, if necessary, by legal counsel, before any such action is
taken. The CEO must give final approval.
Reviewed:
August 2017
Issued by:
Human Resources
Authorised by: CEO
This information is correct at date of issue. Always check in the relevant QLDC policy manual that this copy is the most recent version
