fraud policy - city of · web viewresponsibility for fraud and corruption prevention rests...

Fraud and Corruption Control Policy and Procedure

Adopted 18 March 2013Incorporating Triennial Review (2016)

http://www.stonnington.vic.gov.au/

FRAUD AND CORRUPTION CONTROL POLICY AND PROCEDURE_____________________________________________________________________

Contents1. Purpose........................................................................................................................3

2. Policy...........................................................................................................................3

3. Scope...........................................................................................................................3

4. Definitions....................................................................................................................3

5. Responsibilities............................................................................................................5

5.1 Chief Executive Officer (CEO)..........................................................................5

5.2 General Manager Corporate Services.............................................................5

5.3 Manager People & Culture...............................................................................6

5.4 General Managers and Managers....................................................................6

5.5 Employees/Contractors/Volunteers..................................................................7

5.6 Councillors........................................................................................................7

5.7 Internal Audit....................................................................................................7

5.8 Risk Management Unit.....................................................................................7

6. Prevention....................................................................................................................8

6.1 Fraud and Corruption Control Framework.......................................................8

6.2 Risk Assessment..............................................................................................8

6.3 Mitigating the Risk of Corruption......................................................................9

6.4 Training.............................................................................................................9

6.5 Employment Screening....................................................................................9

6.6 Customer and Supplier Vetting......................................................................10

7. Detection....................................................................................................................10

7.1 Reporting Avenues.........................................................................................10

7.2 Employees......................................................................................................10

7.3 General Manager or Manager........................................................................10

7.4 Notifying the Chief Executive Officer (CEO)..................................................10

7.5 Anonymous Reports.......................................................................................10

7.6 Contractors.....................................................................................................10

7.7 Reporting Avenues.........................................................................................11

7.8 Protected Disclosure Policy............................................................................11

8. Response...................................................................................................................12

8.1 Investigation...................................................................................................12

8.2 Investigation Outcome....................................................................................13

8.3 Recovery of Losses........................................................................................13

8.4 Media..............................................................................................................13

8.5 Audit Committee.............................................................................................13

9. References.................................................................................................................13

10. Forms/Questionnaire.............................................................................................14

11. Policy Approval and Review..................................................................................14

Adopted by Council 18 March 2013 (Version 2.0 – 2016) of 1



12. Schedule of Reviews.............................................................................................15

Attachment 1.....................................................................................................................16

1. PURPOSE

The purpose of this Policy and Procedure is to promote and guide the conduct of all Councillors, employees and external parties associated with Council, with a view to the avoidance of fraud and corruption and management of situations, which may be regarded as unethical conduct or behaviour and to demonstrate that Council is committed to the detection and investigation of any such occurrences.

2. POLICY

The City of Stonnington is committed to protecting its revenue, expenditure and assets from any attempt by members of the public, contractors, agents, intermediaries, volunteers, Councillors or its own employees to gain financial or other benefits by deceit, bias or dishonest conduct.

The City of Stonnington’s commitment to fraud and corruption control will be managed by ensuring that fraudulent or corrupt activity is prevented, conflicts of interest are avoided, and auditing systems are in place to deter and/or identify corrupt activities.

In accepting its responsibility for good governance of the municipality, Council will set the example for transparency and integrity in the provision of services to the community and the management of the Council organisation.

All reports received will be fully investigated and appropriate action taken.Councillors and employees must be aware of the Council’s intention to suspend or dismiss employees, report internal and/or external fraudulent or corrupt activity to Police and prosecute Councillors or employees and any other parties to the matter, found to be involved in fraudulent and/or corrupt behaviour. Council will pursue recovery of any financial loss through civil proceedings.

3. SCOPE

This Policy applies to all employees, Councillors, and volunteers engaged directly by the City of Stonnington as well as all agents and contractors either engaged by the Council or by an authorised contractor of the City of Stonnington.

4. DEFINITIONS

Corruption can be defined as dishonest activity in which a Councillor, Executive, Manager, employee, contractor or volunteer of the City of Stonnington acts contrary to the interests of the organisation and abuses his/her position of trust in order to achieve some personal gain or advantage.




Fraud can be defined as the use of deception or misrepresentation to obtain an unjust advantage or to cause a disadvantage or loss to the City of Stonnington, including benefitting another, and includes theft or misappropriation of City of Stonnington assets or finances to the detriment of its employees, residents and ratepayers.Fraud can also involve misuse of confidential information, abuse of discretions, facilities or employment conditions, redirection of goods or services for personal use and inappropriate arrangements with contractors and other third parties.Offences of fraud may be prosecuted under a number of different Victorian laws. The offences are covered under the Crimes Act 1958 (Vic).

Examples of fraud, for the purpose of this Policy, include but are not limited to:

Theft and/or misappropriation of Council revenue in the form of cash, cheques, money order, electronic funds transfer or other negotiable instrument;

Theft of equipment, parts, software, and office supplies from Council premises;

Deliberate over-ordering of materials or services to allow a proportion to be used for personal purposes;

Submission of sham taxation arrangements for an employee or contractor to circumvent the Council’s procedures for engagement of employees and contractors;

Submission of fraudulent applications for reimbursement;

Unauthorised amendment or correction to previously authorised forms;

Payment of fictitious employees or suppliers;

Falsification of time or attendance records;

Damage, destruction or falsification of documents for the purpose of material gain; and

Misrepresentation of qualifications in order to secure a position of employment.

Corrupt conduct includes asking for, or receiving a benefit of any kind, the acceptance of a bribe, in any form, which is punishable under law by the Victorian common law offence of ‘Bribery of a Public Official’ and offences under the Local Government Act 1989 (Vic).

Council employees and Councillors are to be mindful that the inappropriate acceptance of a gift or hospitality may be seen as acceptance of a bribe. Refer to the Council’s Policy on Receiving Gifts, Benefits and Hospitality, Employee Code of Conduct, Councillor Code of Conduct and the Department of Planning and Community Conflict of Interest – a Guide for Councillors October 2012 –for further guidance.




5. RESPONSIBILITIES

Responsibility for fraud and corruption prevention rests with all levels of management, Councillors, employees, volunteers and agency or contract employees who represent the Council and who collectively must accept ownership of the controls relative to this Policy.

5.1 Chief Executive Officer (CEO)The Chief Executive Officer has principal responsibility for fraud and corruption control to ensure compliance with the Standards and Guidelines and that appropriate governance structures are in place and effective.

5.2 General Manager Corporate ServicesThe General Manager Corporate Services is responsible for the day to day management of this Policy as well as fraud and corruption control within the Council.

These responsibilities include:

Collating information on detected fraud and corruption incidents;

Recording the response to detected fraud and corruption incidents;

Managing the investigation of, and resources required for the investigation of, detected incidents;

Where necessary, reporting matters to Victoria Police or other external agency as necessary;

Managing reports made to Victoria Police or other external agency;

Ensuring risk assessment tools on fraud and corruption are available for relevant employees;

Collating the outputs of fraud and corruption risk assessment exercises conducted across the organisation;

Liaising with the Risk Management and People & Culture Departments on detected fraud and corruption matters that require investigation pursuant to the Council’s Disciplinary Procedure;

Co-ordination of the provision of fraud and corruption awareness training for Councillors and employees;

Benchmarking the policies that comprise the Council’s Fraud and Corruption Control Framework with other like organisations;

Scheduling internal assessments of high-risk Units;

Reporting any known or suspected incidents of fraud to the CEO and

Reporting incidents of fraud to the Audit Committee with recommendations for action to avoid further such incidents.




5.3 Manager People & CultureThe Manager, People & Culture is responsible for providing advice on matters that require investigation pursuant to the Council’s Disciplinary Procedure. These responsibilities include:

Providing advice on the application of the Council’s Disciplinary Procedure;

Incorporating fraud and corruption prevention responsibilities into the Council’s staff development program;

Ensuring that fraud and corruption prevention responsibilities are specified in the position descriptions of Council Managers; and

Liaising with the General Manager Corporate Services and the CEO when required.

5.4 General Managers and ManagersGeneral Managers and Managers have a responsibility to:

identify risk exposures to corrupt and fraudulent activities within their Division//Department;

establish and monitor controls and procedures for prevention and detection of such activities;

ensure that employees under their direction are aware of and understand the Policies that comprise the Council’s Fraud and Corruption Control Framework outlined in Section 6 of this Policy;

provide guidance and instruction to all employees relative to responsibilities and fraud and corruption reporting requirements;

maintain effective auditing and reporting on key financial systems;

undertake a risk assessment on fraud and corruption control every two years or when a major change occurs;

identify positions where employees may be more exposed to the risk of fraud and/or corruption (‘at risk’ positions);

implement action plans for risks identified in risk assessments to eliminate or reduce the fraud and/or corruption risk;

monitor and actively manage excessive outstanding leave of employees in at risk positions;

ensure that losses due to fraud and/or corruption are allocated against the profit/cost centre in which the loss occurred;

ensure that internal controls are risk focused, documented and reviewed on a regular basis;

ensure that any internal controls are communicated to employees and that information is easily available to enable the purpose of the controls to be understood; and

ensure that in each instance where fraud and/or corruption is detected, the Manager responsible will reassess the adequacy of the internal control environment and consider what improvements, if any, are required.

General Managers/Managers will ensure that all contractors working for their Division/Department are aware of the relevant elements of Council’s Fraud and Corruption Control Policy and Procedure, that it is incorporated into the Contract where applicable and




to ensure that the Contractors’ employees are made aware of their responsibilities and acceptable behaviours.

5.5 Employees/Contractors/VolunteersEmployees/contractors/volunteers have the following responsibilities:

be aware of the content and provisions of this Policy and the Policies that comprise the Council’s Fraud and Corruption Control Framework;

assist in the identification of risk exposures to corrupt or fraudulent activities in the workplace; and

report concerns regarding suspected fraudulent and/or corrupt conduct at the earliest opportunity.

5.6 CouncillorsCouncillors shall be aware of and where applicable, comply with this Policy. Councillors must also be aware of and adhere to the provisions of the Local Government Act 1989.

5.7 Internal AuditInternal Audit is responsible to test and identify weaknesses in Council’s systems and processes. Internal Audit activity can be, in the context of addressing all business risks, an effective part of the overall control environment to identify the indicators of and the potential for fraud and corruption.

5.8 Risk Management UnitThis Unit is responsible for assisting the General Manager Corporate Services in the management of this Policy. In particular, the Unit will:

assist the General Manager Corporate Services with the development and assessment of fraud and corruption awareness training;

develop and make available risk assessment tools on fraud and corruption; act as the conduit between the organisation, the insurers and the investigators

where a fraud is suspected to have occurred; provide a process to store, record and preserve any evidence discovered during an

investigation; collate on behalf of the General Manager Corporate Services, the outputs of fraud

and corruption risk assessment exercises; undertake on behalf of the General Manager Corporate Services, benchmarking of

the Polices that comprise the Fraud and Corruption Control Framework; in support of Departmental Managers, assist in the conduct of regular internal

assessments of high-risk Units and oversee the completion of a fraud and corruption risk assessment for all other Departments every two years;

oversee the implementation of action plans developed by Departments to mitigate fraud and corruption as identified through the questionnaire or detailed risk assessments;

retain copies of completed Departmental Fraud Assessment Questionnaires and detailed risk assessments for audit purposes; and

assist the General Manager Corporate Service, in reviewing this Policy every three years or in circumstance of major change to Council’s business and/or operations or legislation.




6. PREVENTION

6.1 Fraud and Corruption Control FrameworkThe Council has a number of policies that make up the Council’s Fraud and Corruption Control Framework. These Policies are:

City of Stonnington Protected Disclosure Procedures;

City of Stonnington Disciplinary Procedure;

City of Stonnington Employee Code of Conduct;

City of Stonnington Councillors Code of Conduct;

City of Stonnington Risk Management Policy;

City of Stonnington Fraud Control Plan;

City of Stonnington Procurement Policy;

City of Stonnington Information Technology Policy;

City of Stonnington Accounting Policy and Procedures;

City of Stonnington Media Policy; and

City of Stonnington Receiving Gifts, Benefits and Hospitality Policy.

Council’s senior management is responsible for ensuring the fraud and corruption control initiatives covered in Council’s Policies are implemented, communicated and monitored.

The Council has a program of continual improvement, and all of the Council’s Policies that comprise the Fraud and Corruption Control Framework are periodically benchmarked against industry and other Local Government organisations.

All Council employees, contract employees, and Councillors will, on commencement of employment, engagement or election, be provided with directions on how to find the Policies that comprise the Council’s Fraud and Corruption Control Framework in order that they may be aware of and comply with these Policies.

Council’s employee induction programme for new employees will also contain a presentation regarding fraud and corruption policies and definitions within the local government context.

6.2 Risk AssessmentRegular fraud and corruption risk assessments are to be undertaken by all business areas of the Council every two years. The Risk Management Unit will assist Departments to perform these risk assessments as required. All risk assessments are to be undertaken in line with the Council’s Risk Management Policy and AS/NZ ISO 31000-2009 Risk Management – Principles and Guidelines. The results of the fraud and corruption risk assessments undertaken are to be communicated to the General Manager Corporate Services by the Risk Management Unit. Areas of weakness identified as part of the risk assessment process are to be mitigated with the implementation of appropriate controls and will be reflected in the Strategic Risk Register. The outcomes of the fraud and corruption risk assessments will also be provided to Internal Audit for consideration in the Strategic Audit Plan.

When new major Policies are being developed, or when there is a significant change to current Policy, the risk of fraud and/or corruption must be considered by the responsible Department.




6.3 Mitigating the Risk of CorruptionIn addition to the Policies that comprise the Fraud and Corruption Control Framework and the conducting of regular risk assessments, the Council employs the following prevention mechanisms:

personnel in ‘at risk’ positions are managed to ensure that improper relationships are less likely to develop;

high risk providers are subjected to random audits at the discretion of the Council;

separation of orders, authorisation or other controls;

rotation of tasks;

maintenance of detailed records such as asset registers;

fraud and corruption risk assessments;

monitoring of various discrete behaviours which may indicate impropriety;

internal audit reviews; and

discrete preliminary investigation into any incidents of concern.

6.4 TrainingCouncillors and Employees will be informed of Council’s Policy, the consequences arising from fraud and corruption, and who to speak to if they suspect fraud and/or corrupt conduct is occurring. Training and support on the conduct of risk assessments will also be provided by the Risk Management Unit and/or agent. This training shall be conducted at regular intervals.

Fraud and corruption awareness training will be provided to all employees, at least every two years. The General Manager Corporate Services, with the support of the Risk Management Unit, is responsible for organising the provision of the relevant training sessions. The training sessions will also include information on the Employee Code of Conduct and other Policies that comprise the Council’s Fraud and Corruption Control Framework.

The General Manager Corporate Services, will organise for all fraud and corruption training provided, whether internally or by an external provider, to be evaluated to determine if it has been successful and that the target group is as a result of the training, more aware of fraud control issues and their responsibilities.

6.5 Employment ScreeningScreening of new employees is an effective fraud and corruption prevention mechanism. The Council’s Recruitment and Selection Policy includes the screening of prospective employees and can include Police checks and psychometric testing as well as detailed reference checks to confirm the veracity of the applicant’s integrity, identity and credentials.

6.6 Customer and Supplier VettingChecking the bona fides of new suppliers and customers at the point of engagement can be an effective fraud and corruption prevention mechanism. The Council has procedures which cover these processes which are covered by the Council’s Procurement Policy.

Financial checks are also undertaken for all service contracts.




7. DETECTION

7.1 Reporting AvenuesThe following procedure shall be used for reporting of suspected fraudulent and/or corrupt conduct.

7.2 EmployeesWhere an employee suspects that an act of fraud or corrupt conduct is occurring or has occurred, that employee should report such suspicions to their Manager.

Where the employee does not feel comfortable reporting their suspicions to their Manager they should report such matters to their respective General Manager. If neither of the above options are appropriate, then the employee should report such matters to the General Manager Corporate Services. In the circumstance that it is inappropriate to report the matter to the General Manager Corporate Services, the employee should report the matter to the CEO.

7.3 General Manager or ManagerOn receiving a report of suspected fraud or corrupt conduct, the General Manager or Manager must record details of the report, including the time and date the report is made and details of matters raised. The matter must then be reported to the General Manager Corporate Services or where this is inappropriate, the CEO. Where the issue may involve disciplinary action against an employee, the Manager People & Culture must also be advised prior to any such action being undertaken.

7.4 Notifying the Chief Executive Officer (CEO)Except where it is has been reported as a Protected Disclosure action (which is a specifically legislated protected action – see below), all reported incidents of suspected fraud or corrupt conduct must be reported to the CEO by the General Manager Corporate Services immediately and prior to, any investigation of such allegations being undertaken. Where this is inappropriate, the General Manager Corporate Services is to report the matter to the Mayor.

7.5 Anonymous ReportsAlthough not encouraged, anonymous reports may be directed to the General Manager Corporate Services. Adequate supporting information to enable an investigation to be undertaken must be provided.

7.6 ContractorsContractors or other people involved in the contracting processes may become aware of or have information indicating fraudulent or unfair activity in relation to the procurement/tender processes or service provision. Contractors should report any such concerns to the Appointed Officer in charge of the contract/tender. Where contractors feel reluctant to report suspected fraud and/or corruption, behaviour that is intimidatory or grossly unfair for fear of repercussions affecting their future business dealings with Council, they are requested to contact Council’s General Manager Corporate Services.

As contractors would not normally have access to this Policy, the above advice should be included in all procurement / tender documentation.

7.7 Reporting AvenuesThe following table provides the reporting avenues available for matters of fraud or corruption to be reported. The second report option is provided in event that the first report person may be sympathetic or potentially involved with the suspect.




PERSON SUSPECTED FIRST REPORT SECOND REPORTEmployee Manager & Divisional General

ManagerGeneral Manager Corporate Services

Contractor Contract Manager & Divisional General Manager

General Manager Corporate Services

Contract Manager Manager and Divisional General Manager


Manager Divisional General Manager General Manager Corporate Services

General Manager General Manager Corporate Services

Chief Executive Officer


Chief Executive Officer Mayor

Chief Executive Officer General Manager Corporate Services

Mayor

Councillors General Manager Corporate Services

Chief Executive Officer

Members of the Public Manager & Divisional General Manager


Special Rate Traders’ Associations

Manager General Manager Corporate Services

7.8 Protected Disclosure PolicyAll managers, employees and contractors have the option to report a suspected fraud and/or corrupt behaviour via the Council’s Protected Disclosure Policy which is available on Council’s website.




8. RESPONSE

All suspected incidents of fraud and/or corruption detected will be investigated pursuant to these procedures. This includes incidents detected through proactive detection programmes or by a report from an employee or other person.

The Fraud Control Plan provides specific and detailed advice regarding the immediate management of a fraud event and should be consulted in concert with this Policy.

8.1 InvestigationAll reported incidents of fraud and/or corruption will be assessed by the General Manager Corporate Services as to whether an investigation is required. The General Manager Corporate Services will advise the CEO of the decision made whether to investigate a matter or not and where appropriate, the CEO will assist in the decision making process.

Once the decision has been made that the evidence supports further investigation,, the General Manager Corporate Services will immediately advise the Independent Broad-based Anti-corruption Commission (IBAC) of the issues and seek their guidance.

The Risk Management Unit will also advise Council’s insurers under the obligation of disclosure as required by the Insurance Policy.

Should IBAC direct the Council to initiate an investigation, the General Manager Corporate Services will appoint an appropriately skilled and experienced person who is independent of the business unit in which the alleged fraudulent or corrupt conduct occurred.

The independent investigator may be an external law enforcement agency, a manager or other senior person within the Council or an external consultant such as a specialised fraud investigator operating under the direction of the General Manager Corporate Services. The General Manager Corporate Services will ensure that the investigator appointed is mindful of legislative provisions that are relevant to the investigation, including the provisions of the Information Privacy Act 2001(Vic) regarding the disclosure and use of personal information.

Reports will be received in confidence and the person reporting the event will be protected from any adverse repercussions, provided that there is no evidence of malice.

Any person contacted by an investigator or any other person nominated by the General Manager Corporate Services regarding any investigation, must co-operate fully with the process.

Where an external investigation is required by an independent authority or agency, for example the Victoria Police, they will be in charge of the investigation. Where the allegation has arisen through a Protected Disclosure, then the investigation will be in accordance with Council’s Protected Disclosure Guidelines and Procedures.

In all cases, strict confidentiality and the principles of natural justice will be observed and maintained.

Where a Council employee is the subject of an investigation, the General Manager Corporate Services will seek the advice of the Manager, People & Culture to ensure adherence to the provisions of Council’s Disciplinary Procedure and relevant industrial relations laws.




8.2 Investigation OutcomeOnce an investigation has been finalised, the investigator will provide a report of the findings of the investigation to the General Manager Corporate Services. In consultation with the Risk Manager, the Manager, People & Culture and the CEO, the General Manager Corporate Services will make a determination as to the action required. The course of action taken could include:

Disciplinary proceedings;

Referral to Victoria Police for a criminal investigation;

Referral to another external agency for investigation (e.g. the Local Government Inspectorate); and

Civil action.

8.3 Recovery of LossesIn each case where there is clear evidence of fraud or corruption, the General Manager Corporate Services, in consultation with the CEO, will consider all reasonable avenues available for recovering any funds lost or compensation for other fraud losses. Due consideration will be given to the likely benefits of recovery action exceeding the funds and/or resources required for the recovery action.

8.4 MediaThe City of Stonnington Media Policy shall be observed at all times, and no employee, Councillor or other persons associated with Council other than the CEO, unless specifically delegated to do so, shall make any public comment in relation to any suspected fraud or corruption, whether proven or otherwise.

Where it is deemed necessary to make a statement to the media, the CEO shall consider legal and media advice prior to making the statement.

8.5 Audit CommitteeAll incidences of proven fraud and corruption are to be reported to the Audit Committee in a timely manner with details of mitigation measures already taken or proposed to prevent further instances occurring.

9. REFERENCES

Local Government Act 1989 Crimes Act 1958 (Vic)Australian Standard on Fraud Control and Corruption Control (AS 8001: 2008)Guidelines for Managing Risk in the Australian and New Zealand Public Sector (HB143-1999)Risk Management Principles and Guidelines AS/NZ ISO 31000-2009Fraud Prevention Strategies in Local Government – Victorian Auditor General Report June 2012

10. FORMS/QUESTIONNAIRE

To assist Managers to undertake a fraud risk assessment of their area/s, an assessment questionnaire has been prepared (Attachment 1). The Risk Management Unit will oversee the completion of these assessments and based on an analysis of the level of fraud and




corruption exposure, assist Departmental Managers in undertaking detailed risk assessments of those aspects of their business with the highest exposure.

The Risk Management Unit will collate and assist in the implementation of action plans to mitigate fraud and corruption that are identified during this process.

Subsequent assessments are to be undertaken periodically or when a major change occurs and this periodic review will be monitored by the Risk Management Unit.

Such assessments will be retained by the Department for internal audit purposes with a copy retained by the Risk Management Unit.

11. POLICY APPROVAL AND REVIEW

A Fraud Policy and Procedure was adopted by Council on 6 July 2009 and became effective from that date. This Policy was developed from an internal operational Fraud Policy and Procedure which was introduced in May 2006.

Following a review conducted in 2013 the Policy and Procedure was updated and re-titled.

This Policy will be reviewed every three years. The review will be managed by the General Manager Corporate Services in consultation with the Risk Management Unit and endorsed by the Chief Executive Officer and the Audit Committee prior to adoption by Council.

This Policy will also be reviewed in circumstances where there are major changes to the Council’s business and/or operations or legislation.

The Policy review will take into consideration any changes to the business conditions, outcomes of risk assessments conducted and outcomes to detected fraud and/or corruption events.




12. SCHEDULE OF REVIEWS

Document ControlVersion: 2.0 Date: 9 February 2016

Author: Risk Management & Contracts Compliance

QA: GM Corporate Services

Owner: General Manager Corporate Services

Review Period:

3 Years

No. Change Adopted by Council

1. Fraud Policy and Procedure - New Policy Endorsed by Executive Management Team - 2 May 2006

2. As part of good governance policy adopted by Council and made applicable to Councillors as well as employees.

Adopted by Council - 6 July 2009

3. Fraud and Corruption Control Policy and Procedure 2013Re-titled, policy updated

Endorsed by Audit Committee - 14 February 2013Adopted by Council - 18 March 2013

4 Triennial review and update Adopted by CEO Notice Paper - 9 February 2016



FRAUD AND CORRUPTION CONTROL POLICY AND PROCEDURE_____________________________________________________________________ATTACHMENT 1

FRAUD RISK ASSESSMENT QUESTIONNAIRE

DEPARTMENT…………………………………… MANAGER’S NAME…………………...………..

QUESTION RESPONSE COMMENTS/ACTIONS1. What is the location of your Department

or Service Unit?

2. How many employees are employed in your area (full-time, part-time, and casual).

Full-time:Part-time:Casual:

3. Does your Department require Police Checks to be undertaken prior to employing new employees?

YES/NO

4. Does your Department undertake background checks prior to employing new employees?

YES/NO

5. What is the total of your Department’s annual operational budget? i.e., total income, total expenditure.

6. Does your Department utilise a range of Council assets, and if so what are they? e.g., vehicles, plant, equipment, computers.

7. Provide a brief summary of the services provided by your Department including identifying your customer base.

8. Does your Department use the services of external contractors or consultants? If so, provide details of type, value and incidence.

9. Has your Department ever been subject to internal audit reviews? If so what areas?

10. Does your Department have documented policies and procedures for operations? YES/NO

11. Does your Department handle cash or any other means of financial instruments for transactions? e.g., cheques, credit cards etc. If so what levels of income are derived p.a.?




QUESTION RESPONSE COMMENTS/ACTIONS12. Does the Department utilise or control

accessible assets that could be easily stolen or misused? If so, please detail, e.g., computers, minor transportable equipment.

13. Does your Department possess intellectual property which could be commercially traded or has a cash value? e.g., specific technical or business expertise. If so, please detail.

14. Does your Department provide or have information that could be commercially traded or has a cash value? eg, data base information. If so, please detail.

15. Is there scope for Department employees to misuse facilities (e.g., private work in Council time; abuse of cars, telephones, computers, copying facilities etc)?

16. Does the Department, or do employees within the Department, have public, client or business relationships which could potentially lead to offers of inducement for preferred treatment/service etc?

17. Are there any legislative or statutory restrictions that affect the way your Department delivers services? If so briefly explain.

18. Does the Department operate under stringent deadlines, productivity pressures or economic variances which can materially impact on service provision?

19. Is there continuity in personnel involved in the Department’s control systems? YES/NO

20. Are the Department’s physical asset security measures adequate? YES/NO

21. Is the Department involved in materiel levels of purchasing? e.g., greater than $10,000 p.a.

YES/NO

22. Is the Department involved in the allocation of funding to clients? YES/NO

23. Is the Department involved in billing clients? YES/NO




QUESTION RESPONSE COMMENTS/ACTIONS24. Does your Department use a Corporate

Credit Card for payment of goods or services?

YES/NO

25. Is the Department’s management or employees involved in recording variable working hours for payroll purposes?

YES/NO

26. Is the Department involved in collecting debts? YES/NO

27. Does your Department procure the services of contractors either by purchase order or Contract. If so, please advise how many.

YES/NO

28. Does the Department have procedures for recording acquisitions, disposal and maintenance of assets?

YES/NO

29. Do any of the Department’s information technology systems present opportunities for fraudulent behaviour by employees or misuse by the public?

30. Do you believe the accountability/ control systems in your Department are adequate, and if not what areas could be improved?

31. Does the Department have any unique characteristics that could adversely affect fraud control?

32. Do you believe your Department could in any way be perceived as an easy target for fraud? If so please elaborate.

33. Has your Department experienced in the last 5 years, any previous issues of fraud or corrupt activity? If so, please elaborate and specify what was the function being performed.



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