An anti-fraud policy sets out a charity’s stance on preventing, detecting and responding to fraud
An anti-fraud policy (sometimes called a ‘fraud policy statement’) outlines a charity’s attitude to, and position on, fraud. It sets out the charity’s responsibilities for the prevention and detection of fraud and its response to fraud.
It also sends an important deterrence message to staff and third parties that the charity does not tolerate fraudulent conduct, and that this is supported and endorsed at the most senior level.
A good anti-fraud policy should aim to outline the charity’s commitment to:
The purpose of an anti-fraud policy is to: • encourage an anti-fraud culture by setting the tone at the top;
The policy should cover all instances of actual or suspected fraud and dishonesty involving trustees and staff as well as volunteers, suppliers, grant recipients, partners, contractors and other third parties that have a relationship with the charity.
Designate oversight to an individual or body with sufficient authority, such as a trustee, senior manager or the audit committee.
An anti-fraud policy sets out a charity’s commitment to building an anti-fraud culture and maintaining high ethical standards amongst its staff and volunteers.
An effective anti-fraud policy should be simple, concise and easily understood. As a minimum your anti-fraud policy should include the following elements.
Statement of intent
Preface the policy with a short statement that clearly sets out your charity’s commitment to prevent, detect and respond to fraud; the behaviour expected of staff and third parties; and the action that will be taken against fraudsters. You may also want to set out the culture you wish to foster within your charity.
Define fraud and provide examples
of what might constitute fraud and dishonesty in the specific context of your charity. This may include theft, the misuse of funds or other resources, or more complex crimes such as bribery and corruption, false accounting and/or the supply of false information.
Everyone has a role to play in protecting your charity from fraud. Highlight the responsibilities of trustees, senior managers, staff
and volunteers in preventing, detecting and reporting fraud, and in cooperating with any investigations. Specify the individual and/or body with overall responsibility for the policy.
Set out whistleblowing arrangements (if appropriate) and/ or specify designated individual(s) to whom staff and volunteers can report concerns on a confidential basis. Alternatively, if a separate whistleblowing policy exists, state where this can be found.
Fraud response plan
Outline the process that will be followed in the event of a fraud being suspected or discovered. Alternatively, if a separate fraud investigation or response plan exists, state where this can be found.
Set out how frequently the policy will be reviewed.
All staff, volunteers and third parties should be made aware of your anti- fraud policy. Actively and regularly promote it throughout the charity. This might include:
It is essential to review your policy regularly to ensure that it remains relevant, up to date and effective, and takes into account any changes to your charity’s operations.
Hallmoarks of an effective policy
Preventing Charity Fraud contains resources to help charities prevent, detect and respond to fraud.
This helpsheet was kindly prepared by the Fraud Advisory Panel
© Fraud Advisory Panel and Charity Commission for England and Wales, 2021. Fraud Advisory Panel and Charity Commission for England and Wales will not be liable for any reliance you place on the information in this material. You should seek independent advice.
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