Appendix B Counter Fraud and Response Policy

2.1 Scope and Introduction

The Organisation is committed to ensuring that high legal, ethical and moral standards are in place across the organisation, including where third parties act on the Organisation’s behalf, at both home and abroad and is committed to countering any form of fraud or corruption.

It is therefore vital that measures are in place to ensure that there is an anti-fraud culture in the Organisation in which fraud is deterred, prevented and detected and that all suspected frauds are appropriately investigated and the necessary sanctions are imposed where a fraud is proven.

Organisation to have a robust and comprehensive system of risk management, control and corporate governance and that this should include the prevention and detection of corruption, fraud, bribery, money laundering and other irregularities.

This Policy sets out the roles and responsibilities of staff, Committees and other parties towards achieving this. Specifically, the sections which follow outline responsibilities for preventing and detecting fraud and set out how staff should respond if they suspect that a fraud is or has been taking place.

This Policy applies to all members of the Organisation including subsidiary companies and associated persons. Organisation includes employees and independent members of Council and its Committees.

The policy applies to any fraud, or suspected fraud, involving employees as well as consultants and contractors. ...

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