Fraud Control Plan 2011

Chapter Two

Roles and Responsibilities for Fraud Management

Corporate Governance Framework

The department has an overarching corporate governance framework made up of the Ethics Committee, the Audit and Risk Committee, the CEU and broader operational arrangements.

The Ethics Committee

The departmental Ethics Committee was established in 1997. It meets regularly to review ethics policy and conduct issues and to oversee the work of the CEU. The Committee's terms of reference are to:

• promote high standards of ethical behaviour
• prevent fraud and misconduct
• ensure that investigations are carried out fairly and expeditiously
• provide clear and consistent guidance on standards of conduct.

The Management Strategy Conduct and Coordination Section (MCS) in Corporate Management Division (CMD) provides the secretariat for the Ethics Committee. The Committee operates on a basis of strict confidentiality and is meticulous in protecting the right to privacy of employees who make or are the subject of allegations.

The Audit and Risk Committee

The Audit and Risk Committee plays a vital role in enhancing the department's corporate governance, risk management and control framework and in providing guidance on the department's external accountability and other legislative compliance responsibilities. One of its specific functions is to "review the risk management strategy and fraud control plans of the Department to ensure they remain current and focus on areas of high risk." As such, the Audit and Risk Committee has an oversight responsibility for the Plan.

The Conduct and Ethics Unit (CEU)

The CEU has a primarily investigative purpose. The CEU also has a preventative and educational role that enhances the corporate governance framework. It provides ad hoc confidential advice to staff on many issues, including fraud. The CEU also conducts fraud and ethics training throughout the department in Australia and overseas.

Corporate Governance Arrangements

The department's approach to fraud management is supported and augmented by related and ancillary corporate governance arrangementsincluding:

• publishing all procedures on departmental systems
• training and development
• active encouragement of best practice and continuous improvement principles
• comprehensive financial and management reporting
• regular management meetings.

Managers

Departmental managers have an ongoing requirement to be vigilant in relation to the possibility of fraud and to respond accordingly. In undertaking their duties managers should:

• ensure that risk treatments and general fraud awareness practices in their areas are regularly reviewed to ensure a satisfactory level of risk management
• regularly review their performance against the indicators set out in Chapter Four
• advise CEU of any significant changes in functional area responsibilities that result in new inherent fraud risks
• inform new staff, including contractors and non-ongoing staff, of the fraud control measures that are to be observed in their area and where applicable, the broader department.

Heads of Mission (HOMS)

The Head of Mission (HOM) is responsible for effective, efficient and accountable financial management at post. HOMS must ensure that all staff understand the statutory and departmental requirements related to the performance of their duties, including all aspects of fraud control.

Senior Administrative Officers (SAOs)

Senior Administrative Officers have a high degree of responsibility for managing, detecting and minimising fraud risks at posts. Additionally, SAO roles include managing the following functions that have fraud risks associated with them:

• Human Resource Management
• A-Based Personnel Functions
• Travel and Removals
• Diplomatic and Consular Privileges
• LES Management
• Financial Management
• End of Month/Year Reporting Requirements (EOM)/(EOY)
• Budget Management
• Capital Budgets and Assets Management
• Cash Management
• Property Management
• Information Technology (IT) and Communications Issues
• Records Management.

All Employees

All DFAT staff have a responsibility to:

• seek to promote professional and ethical practice by other staff and clients by setting an appropriate example and recognising the contributions of others
• not condone, or fail to take appropriate action in relation to, suspected fraudulent or improper conduct within their area of responsibility
• implement fraud risk management strategies and participate fully in activities relating to fraud control
• immediately advise their supervisor and/or the CEU where they hold any concern, suspicion or information of any example of fraudulent, corrupt, or improper conduct and encourage others to do the same
• assist with all reports of fraud or improper conduct in a professional and prompt manner
• not knowingly make a false or misleading report of suspected fraud;
• not act in a retaliatory, discriminatory or otherwise adverse manner in regard to a person, on account of that person making a genuine report or providing assistance in a relevant inquiry
• not hinder or impede an investigation, and give every courtesy and assistance to any person authorised by management to conduct an investigation.