International Fraud Awareness Week (also called “Fraud Week”) kicked off on Sunday and is in full swing. CRI Group is a proud supporter of this important initiative every year, and we encourage business leaders to take this time to consider all of their fraud prevention measures, including anti-fraud training for employees.
Does your organisation have a training program in place that addresses fraud, bribery and corruption? And, if so, how robust is your training? How often is it administered? And how do you know it’s working?
These are important questions, especially considering the fact that we know most fraud is discovered internally through employee tips. A recent case study is a perfect illustration of that.
Case study: Conflicts of interest
A major pharmaceutical company’s security department received conflict of interest complaints that reportedly involved a range of employees, from sales personnel on up to the chief financial officer (CFO). The company engaged CRI Group to conduct an integrity due diligence and conflict of interest investigation in order to uncover unethical practices, including bribery and corruption, by senior employees.
CRI Group’s investigators quickly launched a risk assessment of the company’s third-party relationships, which included several interviews with identified vendors and suppliers to help ascertain the engagement process and associated risks.
Investigators found one of the vendors used letterhead that lacked a physical address, and the only contact information listed was a single cell phone number. Site visits, background checks and interviews helped determine that the suspicious vendor was not a company at all – but a single person, and he was none other than the brother-in-law of the client company’s CFO. Worse still was the fact that this obvious fraud was being conducted right under the noses of the company’s procurement and finance professionals.
CRI Group investigators discovered that the individual’s residence was being utilized as warehouse to help facilitate the fraud. A comprehensive litigation records check with local and regional courts found that the subject was previously convicted in federal court and spent three years in prison for the charges of selling counterfeit products, physician samples and expired medicines; further regulatory checks found that his pharmacist license had been cancelled.
The fraud had continued for five years. However, the one thing that saved the company from further financial harm was the fact that employees had stepped forward to report unethical behavior. If not for their action, the fraud could have continued indefinitely.
Fraud Week reminds us that awareness is any organisation’s first line of defense against fraud and corruption, as properly trained employees will have a better opportunity to recognize the red flags of fraud, and a better understanding of their organisation’s zero tolerance policy toward such behavior.
CRI Certification provides employee training as part of the curriculum for a participating organisation. In fact, ISO 37001:2016 certifies that your organisation has implemented reasonable and proportionate measures to prevent bribery, and these measures involve training, top-level leadership, bribery risk assessment, due diligence adequacy, financial and commercial controls, reporting, audit and investigation.
Some key things to remember:
- Anti-fraud training should be mandatory. This includes managers and executives, who should also receive special training regarding their position of responsibility.
- Anti-fraud training should be an element of new employee orientation. After that, it should be provided to all employees on an annual basis, if not more frequently.
- Training might be presented live (in-class), on video or online in an interactive format. Live class is preferred, as it allows questions and personal engagement. However, in today’s business world, some employees work remotely and an online format may be more feasible.
Fraud is everybody’s problem, and it cannot be prevented and detected if employees aren’t provided with the information they need to combat it. Providing a robust anti-fraud training program increases your company’s protection from risks of fraud and unethical behavior. An ounce of prevention is worth more than a pound of cure.