We can place these three at the same level - they are all improper conduct. This guide will refer to fraud and anti-fraud policies when referring to all three of the aforementioned categories. To deal with fraud, it is necessary to for organizations establish an anti-fraud policy document. Likewise, the entity must periodically assess the exposure to the risk of fraud.
The anti-fraud policy must contemplate three elements: prevention, control and reaction.
|Prevention||through Through the appropriation of the organization's values by its workers, which in turn explains the possible consequences of fraud for the organization. Organizations should also seek to establish a code of Ethics and Conduct, which must be communicated and disseminated throughout the organization, including the appropriate communication channels and complaint formats. Thus, staff Staff should be trained in the identification, categorization and use of these channels and formats. In short, establish Establish alert mechanisms that can anticipate and prevent the commission of fraud.|
|Control||creating Creating an Anti-Fraud Commission whose responsibility is the investigation and verification of compliance with the policies of the institution, dedicated to the systematic or ad hoc examination of the practices observed by persons or bodies of the institution. This commission will be in charge of establishing a compliance program with the established policies and norms and their monitoring. For a good information base to exist, staff must feel safe when reporting, but at the same time, they must feel the responsibility to provide truthful information, so clear . Clear responsibilities must be established and due protection to the complainant and protection against false reports.|
|Reaction||displaying Displaying the principle of zero tolerance through quick and determined actions, always under strong evidence. This is only achieved with the collaboration of whistleblowers and in-depth investigations and the prior establishment of appropriate and consistent measures. Except for security risks that advise against it, these processes should be made public, and communicated among the staff or even with our donors and beneficiaries, so it will be necessary for there to be consistent in these actions. These communications are usually sensitive and should be studied and planned in advance.|
It is important to be aware that fraud prevention regulations , cannot by themselves , guarantee the non-existence of situations or events that have the potential to harm the institution. The effectiveness of fraud prevention guidelines will be based on the definition of the moral tone and the transmission of an ethical culture, which reflect the interests of the organization and the individuals that comprise it.
Here are some examples of types of Procurement procurement fraud (this is not an exhaustive list):
- Collusion between providers ; for example, bid rotation / bundling whereby a - A group of suppliers work together to manipulate their bids in order to rotate winners.
- Division of the offer ; whereby the demand - Demand is split into multiple bids to pass through a lower threshold and therefore reduced due diligence supervision.
- Adaptation of the offer ; whereby the Head of Procurement deliberately drafts the - Persons within the agency deliberately draft bid documentation to tailor it to the specific strengths of a specific supplier.
- Price manipulation ; whereby a supplier - A supplier charges a price higher than the one agreed in the Contract / Framework Agreement.
- Product substitution ; whereby the organization - The organization obtains and pays for a certain specification, but the supplier provides a lower / different specification.