Developing a fraud and protected disclosure policy
All cemetery trusts are required to have a documented fraud and protected disclosure policy. The department has prepared a template Fraud, Corruption Control and Protected Disclosures Framework which is designed to provide organisations with a 'fill in the blanks' policy structure that they can adapt for their use.
What is a fraud policy?
While the template contains a number of sub-topics, there are three key elements of a fraud policy:
- Articulation of the organisation's position on fraud (that is, fraud is unacceptable). Even though it might seem obvious, it is important to articulate this to set expectations and discourage inappropriate conduct.
- Identification of strategies and procedures that contribute to fraud prevention. Many of these will be things that the trust already does -- for example, following the department's Financial Control Guidelines.
- Documenting procedures for managing incidents or allegations. This can be as simple as referring allegations to the police or the Independent Broad-based Anti-corruption (IBAC).
What is a protected disclosure?
You might know protected disclosures under a different name, 'whistleblowing'. Cemetery trusts cannot receive protected disclosures so it is important that you recognise what a protected disclosure is. If someone wants to make a protected disclosure, refer them to IBAC, which is equipped to manage protected disclosures appropriately.
Keep in mind that a disclosure can be protected even if the person making the disclosure doesn't use the term 'protected disclosure'. It is all about whether the content of the disclosure related to 'improper conduct' as described on page 11 of the template.
What do trusts need to do?
All cemetery trusts should review the template, note the commentary in red and then formally adopt a fraud and protected disclosure policy at a trust meeting. The policy should be made available to all members and employees.