Corruption Matters - June 2021 | Issue 57
How to produce a fraud and corruption control policy
Most NSW public sector agencies must have a fraud and corruption control policy (Treasury Circular 18-02). The main purpose of the policy is to set the basic approach to controlling fraud and corruption, rather than specifying detailed controls and behavioural expectations.
A policy is not the same as an agency’s code of conduct, nor should it seek to replace key integrity policies relating to matters such as conflicts of interest, gifts or public interest disclosures.
For this reason, a policy is usually a relatively short document, especially when compared with a fraud and corruption control plan, which is a comprehensive document that goes into significant detail about how the agency controls fraud and corruption.
In addition to describing some roles and responsibilities, the policy should set out some of the key ways in which the agency has chosen to control the risk of fraud and corruption. This could include:
- alignment to an industry standard
- commitment to having prevention, detection and response/investigation controls
- commitment to conduct regular fraud and corruption risk assessment (for example, every two years)
- timetable for reporting to the audit and risk committee
- commitment to cooperating with relevant agencies
- general requirement for all staff and managers to refrain from and discourage any behaviour that falls outside the appetite/tolerance statement.
The ICAC has prepared a guide, Advice on developing a fraud and corruption control policy (pdf), and a Sample fraud and corruption control policy to help your agency meet the requirements of NSW Treasury’s NSW Fraud and Corruption Control Policy.