Reflections on how organisations can implement new ways of thinking to combat fraud

Following the development of new mitigation framework, Amnesty International’s Pascale Nicholls, reflects on how the organisation implemented new ways of thinking and working in relation to bribery, corruption and fraud. ...

Amnesty_Pascale_52586695_co Following the development of new mitigation framework, Amnesty International’s Pascale Nicholls, reflects on how the organisation implemented new ways of thinking and working in relation to bribery, corruption and fraud. Throughout 2015 we were bombarded with messages in the media, at finance conferences and seminars and from our peers, that all organisations are losing millions of pounds annually to fraud. We were led to believe that an organisation of our size could be losing up to £3.4 million per annum. We did treat this statistic with some caution – our expenditure model is probably different to many other organisations in the sector. Nonetheless we needed to take this seriously: this is a potential loss of Amnesty International’s donor funds that should be being spent on delivery of core human rights work. This galvanised us to develop a new mitigation framework that covered bribery, corruption and fraud including the development of a communication strategy and education programme. The key elements of our combined fraud, bribery and corruption mitigation framework are:
  • Risk assessment and internal controls: As the foundation for our updated policy and training and communication programme, we started with an assessment of our key fraud risks - this would allow us to provide employees with practical, implementable knowledge using examples that would resonate. We did this by looking at all the ways that the International Secretariat receives or spends funds; this helped us focus on the risk areas and identify the weak links in our controls.
  • Policy: A combined anti-bribery, corruption and fraud policy was prepared and launched during our inaugural awareness week, timed to coincide with 2016’s International Fraud Awareness week.
  • Due diligence: We plan to review the effectiveness of our due diligence procedures relating to the ethical practices of current and prospective suppliers in late 2017. Earlier this year, our HR colleagues issued new guidance on pre-employment checks designed to mitigate against ‘insider threat’ (including fraud).
  • Compliance: We plan also to review the effectiveness of our current compliance model – staff, budget holders and the International Board all have a responsibility to ensure full compliance with anti-fraud policies and processes.
  • Reporting: Our reporting system for bribery, corruption and fraud has been articulated in the new policy document.
  • Training and communication: Staff training and communications were developed for the inaugural Amnesty International Fraud Awareness Week.
Our starting position was to raise awareness and change behaviours in relation to fraud as an additional element of our existing bribery and corruption mitigation strategy, as opposed to trying to tackle this as a distinct element. We commenced with a communication plan, the purpose of which was two-fold:
  1. To raise awareness of the potential fraud, bribery and corruption risks faced by Amnesty International and how as an organisation we are working to mitigate against these risks
  2. To ensure that the efforts of the full staff can be harnessed in anti-fraud, bribery and corruption activities and thus to reduce the cost of fraud to the organisation
We also reflected on our responsibilities, along with our peer organisations, as a founding member of the INGO accountability charter. The charter includes reporting requirements regarding staff training in this area and seeks to improve transparency around these issues in the public. We want to affect positive behaviour change, so needed the messages to resonate with our staff. Supported by our internal communications team, we developed five key messages:
  • Staff need to think of themselves as protectors/guardians of Amnesty’s assets
  • Whilst Amnesty has zero tolerance to fraud, bribery and corruption, where staff personal safety is compromised, this is of paramount importance
  • All staff must comply with policies and processes to ensure that anti-fraud controls operate effectively
  • Staff should be encouraged to ask questions and ask for support
  • All staff have a responsibility to fully participate in Amnesty’s formal anti-bribery, corruption and fraud training programme
To deliver these messages in an engaging way, we employed a variety of communication methods during our fraud awareness week including a poster campaign, a series of articles on our intranet, a pop up cake shop (fundraising to recoup our fraud losses!) and also ran a spot the fake fraudulent transaction competition (dummy requisitions were uploaded to our systems and staff were challenged to reject these). We are now busy working on the launch of the new fraud e-learning module, planning workshop based training sessions for staff and scoping activities for the second fraud awareness week in late 2017.  We have also signed CFG’s Counter Fraud Pledge and will be ensuring that in all our efforts we adhere to the promises outlined, as the pledge provides a great standard to uphold all our work we are doing in this area. CFG is proud to support Charity Fraud Awareness Week 23-27 October. Sign up to the CFG Counter Fraud Pledge and we'll send you a toolkit to get you started on your journey to preventing fraud in all its forms: CFG Pledge - for print « Back to all blog posts