The purpose of this Policy is to articulate Skintap Inc’s fraud prevention plan. Skintap adopts a comprehensive approach to the management of fraud risk.
2 SCOPE OF THE POLICY
This policy applies throughout the department in as far as risk management is concerned.
3 POLICY STATEMENT
Fraud represents a significant potential risk to Skintap’s assets, service delivery efficiency and reputation. The Institution will not tolerate fraudulent or corrupt activities, whether internal or external to the Institution, and will vigorously pursue and prosecute any parties, by all legal means available, which engage in such practices or attempt to do so.
4 THE CONCEPT OF FRAUD PREVENTION
Fraud prevention is a process that is adopted by the Institution, in putting mechanisms in place, to manage Skintap’s vulnerability to fraud. Such mechanisms are designed to prevent, deter and detect fraud.
As part of the Enterprise Risk Management (ERM), it is the responsibility of the Accounting Officer / Authority to establish structures to address the threat of fraud.
4.1 INVESTIGATION PROCEDURES
Skintap has developed investigation procedures to ensure uniformity in the reporting and investigation of incidents of fraud and corruption.
- Reporting of suspicious acts;
- Preliminary investigation of incidents reported;
- Investigation procedure;
- Involvement of other law enforcements agencies;
- Procedure in taking resolutions; and
- Recovery of loss.
4.2 ANTI-FRAUD PROGRAM
Skintap has developed the following programs to address the threat of fraud and corruption:
- Recruitment policy;
- Accounting and operational policies;
- Fraud awareness training (indicators of fraud);
- Dysfunctional environment assessment;
- Fraud awareness audit;
- Fraud risk assessment;
- Automated alerts;
- Code of ethics and conduct;
- Investigation policy / procedure; and
- Fraud response plans.
5 ROLE PLAYERS
Skintap has taken a stance that management of fraud and corruption threat like any other risks is the responsibility of everyone in the organization.
The Accounting Officer / Authority has delegated the ownership and communication of fraud risk management to Business Unit Managers / Line managers / Division managers / Employee in specific areas of the Institution (refer to fraud prevention strategy).
5.1 RISK MANAGEMENT OVERSIGHT
5.1.1 Executive Authority
The Executive Authority takes an interest in fraud risk management to the extent necessary to obtain comfort that properly established and functioning systems of risk management are in place to protect the department against significant fraud risks.
5.1.2 Audit Committee
The Audit Committee is an independent committee responsible for oversight of the department’s control, governance and risk management. The responsibilities of the Audit Committee with regard to fraud risk management are formally defined in its charter. The Audit Committee provides an independent and objective view of the department's fraud risk management effectiveness.
5.1.3 Risk Management Committee
The Risk Management Committee is appointed by the Accounting Officer / Authority to assist them to discharge their responsibilities for fraud risk management. The Committee’s role is to review the fraud risk management progress of the department, the effectiveness of fraud risk management activities, the key fraud risks facing the department, and the responses to address these key fraud risks
5.2 RISK MANAGEMENT IMPLEMENTERS
5.2.1 Accounting Officer
The Accounting Officer Authority is accountable for the department’s overall governance of fraud risk. By setting the tone at the top, the Accounting Officer promotes accountability, integrity and other factors that will create a positive control environment.
Management is responsible for executing their responsibilities outlined in the fraud risk management strategy and for integrating risk management into the operational routines.
5.2.3 Other Officials
Other officials are responsible for integrating fraud risk management into their day-to-day activities. They must ensure that their delegated risk management responsibilities are executed and continuously report on progress.
5.3 RISK MANAGEMENT SUPPORT
5.3.1 Chief Risk Officer
The Chief Risk Officer is the custodian of the Fraud Prevention Strategy, and coordinator of fraud risk management activities throughout the department. The primary responsibility of the Chief Risk Officer is to bring to bear his/her specialist expertise to assist the department to embed risk management and leverage its benefits to enhance performance.
5.4 RISK MANAGEMENT ASSURANCE PROVIDERS
5.4.1 Internal Audit
The role of the Internal Auditing in fraud risk management is to provide an independent, objective assurance on the effectiveness of the department’s system of fraud risk management. Internal Auditing must evaluate the effectiveness of the entire system of fraud risk management and provide recommendations for improvement where necessary.
5.4.2 External Audit
The external auditor (Auditor-General) provides an independent opinion on the effectiveness of fraud risk management.
6 POLICY REVIEW
This Policy shall be reviewed annually to reflect the current stance on risk management.