By Andrew Sankoh, Australia.
Each government Ministry must develop a fraud and corruption policy in Sierra Leone. The Policy should have the following key themes. I hope that this may be able to help in developing a policy that works.
Purpose of the policy
The Ministry is designing this policy to mitigate the Ministry’s exposure to fraud and criminal acts committed by employees, customers, vendors or other third parties. This policy will apply to all divisions.
Definitions
For the purpose of the policy, the Ministry should define what fraud and corruption is. For example: " Fraud is an intentional act by one or more individuals among management, those charged with governance, employees, or third parties, involving the use of deception to obtain an unjust or illegal advantage" (International Auditing and Assurance Standards Board 2004).
Corruption defined as "the abuse of public or private office for personal gain" (World Bank Policy Research papers, 2501).
Responsibility
Which officer in the Ministry will be responsible for the overall management of fraud and corruption? However, all employees do have a responsibility to act honestly and follow procedures and controls that have been implemented to avoid fraud and corruption
Risk Management
A Board of Directors and Senior Managers must decide on a risk management strategy. An appointment of a Risk and Compliance section that will describe the risks, their likelihood and impact. The controls that will be put in place to reduce risks.
Reporting fraud incidents
A reliable channel must be developed on reporting incidences of fraud and corruption. Employees report to line managers, line managers to the risk and compliance section. Employees who report such cases must be seen to be protected from any adverse reaction.
Investigation
The head of Risk and Compliance is responsible for leading all investigations in a professional manner and in relation to relevant legislation and statutory requirements. No staff or management will conduct investigation on their own or confront suspects in relation to any matter under investigation. No actions should be taken that will jeopardise investigations.
Post investigations
Where investigations have proved evidence of corruption or fraud, the Ministry in consultation with a legal counsel will then take appropriate action which could include disciplinary action, referral to the police or civil action, or to the ACC.
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