Checks and Balances: QAHC Anti-Fraud Protection Policy

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1 Checks and Balances: QAHC Anti-Fraud Protection Policy Introduction The purpose of this policy is to protect QAHC s assets and reputation by outlining the processes and procedures QAHC uses to prevent and detect fraud, as well as creating a culture within the organisation of anti-fraud and anti-corruption. The QAHC Board has ultimate responsibility for the prevention and detection of fraud and is responsible for ensuring that appropriate and effective internal control systems are in place. All managers must ensure that there are mechanisms in place within their area of control to assess the risk of fraud, educate staff/volunteers about fraud prevention and detection and facilitate the reporting of suspected fraudulent activities. QAHC requires all staff and volunteers at all times to act honestly and with integrity and to safeguard the public resources for which they are responsible and to act in accordance with the QAHC Code of Conduct. Any fraud or corruption committed against QAHC is a major concern and any case will be thoroughly investigated and appropriate disciplinary action will be taken, including referral to the police and/or dismissal. For the purpose of this policy, fraud is described as the wilful misuse of QAHC s resources or using one s position and power for personal gain. This includes theft and acts of omissions, improper use of influence or position, and/or improper use of information. Examples of fraud on QAHC could include: using QAHC s assets for private use or unlawful activity causing a loss or liability for QAHC through unauthorised activity claiming travel or other entitlements which are not due false invoicing for goods or services never rendered using information gained at QAHC for private gain receiving kickbacks or commissions from a contractor theft of cash or goods theft of intellectual property use of credit cards, store cards or taxi cards for non-work purposes unauthorised disposing of QAHC property Fraud could be perpetrated by staff, volunteers, Board members or contactors, and all have a responsibility to prevent and report fraud. Page 1

2 The negative impacts of fraud on QAHC may include financial loss, damage to our reputation, loss of key staff/volunteers, diversion of organisational energy and a reduction in staff morale. While QAHC does not believe that fraud is a problem within our organisation, we all have a duty to ensure that standards, policies and procedures are in place to ensure that it does not happen, and if it does happen, it is detected early and appropriately dealt with. Contents This policy summarises anti-fraud policies and procedures across the following areas, listed in alphabetical order. In many areas more detail is provided in the respective full policy/procedure, as noted. Accounts Payable... 3 Assets... 3 Cash Receipts... 3 Credit Cards... 4 Financial Management... 5 General Resources/Inventory... 5 Governance... 6 Information Technology... 6 Intellectual Property... 7 Motor Vehicles... 7 Payroll... 8 Personnel... 9 Petty Cash... 9 Purchasing (Procurement)... 9 Staff Travel Reporting Suspected Fraud Investigating Suspected Fraud Page 2

3 Accounts Payable Wherever possible, a Purchase Order should be raised for the purchase of goods or services, signed by a Program Manager/Team Leader and a copy (pink page) provided to the QAHC Finance section. Payment for goods/services will only occur on the provision of a Tax Invoice, matched to a Purchase Order and a Payment Requisition form signed by a Program Manager/Team Leader. The Payment Request form should be co-signed by the person who received the service/good, to ensure that QAHC does not pay for things we did not receive. Paid invoices should be stamped Entered with the date processed and bundled together with other electronic fund transfers or a carbon copy of Cheque Remittance attached. Two signatures (Program Manager/Team Leader) are required on cheques and two authorisations for electronic funds transfer. Finance staff have authority to raise payments, but cannot authorise them. No blank cheques are to be signed. Assets New assets/equipment valued at over $500 will be given an asset number and placed in the Asset Register. The asset will be tagged with the asset number. The asset register should note funding source. Asset disposal (e.g. selling, donating, trashing) must be approved by the Office Manager and a Program Manager. Details of the disposal will be entered into the Asset Register. An annual stock-take of assets/equipment against the Asset Register will be conducted. Two members of staff will visually verify the asset and sign the stock-take form. Cash Receipts Each QAHC office will be issued with an official QAHC receipt book. Receipt books will be inspected on a regular basis by QAHC Finance and reconciled with deposited funds. All individuals/businesses who provide QAHC with cash/cheques will be provided with a receipt (except for donations into collection tins). Where money is provided in person, a receipt should be provided immediately. Where money is sent through the post, a receipt will be posted. Page 3

4 Cash collected is to be banked regularly, using a QAHC deposit slip. Details on money banked by non-brisbane based staff should be notified to QAHC Finance using the Cash Reconciliation Form. Cheques collected should be provided to QAHC Finance for banking. Where money is received through the QAHC PayPal account, a receipt will be issued by PayPal and a QAHC receipt will be posted to the payer by QAHC (memberships Office Manager, donations Finance, sales staff member). (see Cash & Cheques Receipts Procedure for more information). Credit Cards Credit Cards will be issued to non-brisbane staff (including SEQ and Gold Coast/Logan HPOs) and Managers & Team Leaders. Cards may be issued to additional staff on the approval of the General Manager. The limit on cards will be $2,500 for HPOS and $5,000 for Managers except for the Office Manager card (where travel is booked) which is $15,000. Cash withdrawal will generally not be enabled on cards. Where cash withdrawal is necessary, prior approval must be sought from the General Manager and arrange with ANZ. The cardholder must ensure the following authorisation/documentation is completed each time a credit card is used. a. When used in-store, the cardholder must sign and retain the credit card receipt; b. When used over the Internet, the cardholder must print off, sign, and retain a copy of the electronic receipt; c. When used over the phone, the cardholder must enter the date and receipt number provided on to the Credit Card Expenditure Form. All credit card receipts (and credit notes) bearing the signature of the cardholder, or the Internet electronic receipt, must be attached to a duly completed Credit Card Expenditure Form. Credit Card Expenditure Forms should be signed by the person who made the purchase, approved by their supervisor/program manager and given to the QAHC Finance section. Lost or stolen Cards must be reported and cancelled immediately to the ANZ s Lost/Stolen Cards Regional Office ( ). The Senior Finance Officer and the General Manager must be notified within 2 business days of this of the loss or theft of a card. Credit cards may only be used for QAHC purchases and should not be used for personal reasons. Reviews of credit card expenditure will be conducted each month by the Finance section and Manager of the staff member. Unusual transactions, or those without the required paperwork, will be investigated. Page 4

5 (see QAHC Credit Card Policy for further details). Financial Management All financial transactions must be entered into the QAHC finance system and coded to a project centre. Preference is given to making payments via electronic funds transfer (EFT), or where this is not possible via cheque. Monthly financial project income and expenditure reports to budgets will be produced and provided to Program Managers & budget holders, along with summaries of individual transactions. Managers will analyse monthly reports and query unusual or unknown transactions as well as significant variances (+/- 10%). Monthly summaries of program/project income and expenditure budgets will be produced and provided to the Board. Board members will analyse monthly reports and query unusual transactions and significant variances (+/- 10%). Quarterly balance sheets and summaries of investments will be provided to the General Manager and Board. An independent auditor will undertake an annual financial audit of the organisation and report to the Board and membership through the Annual Report. General Resources/Inventory QAHC phones (mobile or landline) may be used for occasional personal calls where no other option is available. Staff must reimburse QAHC the costs of personal overseas calls or lengthy personal interstate calls. Regular reviews of telephone accounts will be undertaken by the QAHC Finance section and/or Program Managers and unusual calls will be investigated. QAHC s stationery, photocopying and mail system are not for personal use. Limited occasional use of low value (e.g. a few photocopies, pen) is permissible. Any other personal use of QAHC resources, in exceptional circumstances, must be approved by a Program Manager and the costs reimbursed to QAHC (e.g. postage of private letter). Adequate physical security should be maintained over stores (e.g. stationery) and regular reviews of the reasonableness of requisitions should be undertaken. Stationery should only be ordered through QAHC s online supplier. Orders are made monthly by the Office Manager or Administrative Officer in each office. Page 5

6 Governance Induction training and manual is to be provided to all new Board members. QAHC will develop and regularly review policies relating to organisational processes (e.g. staff selection, grievance process, conflict of interest, service delivery, OH&S, risk management, fraud control, fundraising, asset management etc.). A Delegations of Authority policy is in place, including financial authorisations and delegations, and is reviewed by the Board annually. Annual budgets will be prepared for programs and projects and presented to the Board for scrutiny before approval. Board meetings will usually be held monthly, with formal agenda papers distributed before meetings and accurate minutes taken, signed and glued into a Minute Book. The General Manager will have a written job description and an annual work plan agreed with the President. The performance of the General Manager will be reviewed at least annually, with input from staff, Board and external stakeholders. A Finance Committee will meet monthly to oversee QAHC finances and related issues. The committee with consist of at least the Treasurer, General Manager and Senior Finance Office. At audit time this will expand to include the external auditor. Information Technology Access to QAHC computers/network requires a unique user name and password. Passwords are not to be shared with others and will be re-set regularly. Access to the QAHC wireless network only provides access to printers and internet, not to the QAHC server or individual computers on the network. Access to contact database (ACT!) requires additional user name and password and finance/payroll software is only accessible by Finance staff. Computers should be locked when staff are away from their desk for extended periods (e.g. lunch time). QAHC s computer, internet and facilities must not be used for the violation of the rights of others; commercial use; breach of copyright or intellectual property; illegal activity or gambling; use for harassment, threat or discriminatory acts; accessing or transferring obscene or illegal material. Page 6

7 QAHC may monitor and maintain records of activities on the network, programs and usage to ensure the integrity of the system (see Code of Conduct for more details). On completion of employment with QAHC, staff access to computers/network will be terminated. Software should not be installed onto QAHC computers/network without the approval of the Office Manager. At no time should illegal (pirated) software be installed. Data on the QAHC server will be backed-up each day onto an external hard-drive and taken off site. Intellectual Property The Queensland Association for Healthy Communities Inc. is the owner of intellectual property created by staff and volunteers in the course of their work, unless a specific agreement with the General Manager has been made to the contrary. Intellectual property rights associated with funded contracts, such as from Queensland Health are controlled by the funding body and as per specific service agreements/contracts. This means that staff & volunteers cannot sell or otherwise use for private gain or profit any resources produced during their time at QAHC (e.g. workshop/training program, printed or electronic resources), either while working for QAHC or when they have left QAHC. Motor Vehicles Use of QAHC cars for business use, by authorised drivers, should be booked by staff using an Outlook calendar (or other method) and logged in the log book held in each car at the conclusion of the journey. Regular reviews of the log books will be undertaken by the Office Manager and unusual entries will be investigated. QAHC cars are not for the personal use of QAHC staff/volunteers. To improve operational efficiency, QAHC staff may drive a QAHC car: directly home from QAHC, then directly to a meeting away from QAHC premises the next day from a meeting away from QAHC premises, directly home, then directly to QAHC the next day from a meeting away from QAHC premises, directly to home, then directly to a meeting away from QAHC the next day An inventory of equipment (e.g. GPS, first aid kit) kept in QAHC cars will be kept by the Office Manager. Equipment should be secured from theft, by drivers of the cars at all times. Page 7

8 Regular reviews of expenditure on fuel cards will be conducted by the QAHC Finance section, and unusual purchases will be investigated. (see QAHC Motor Vehicle Policy for more details) Payroll On appointing a new member of staff, the appointing manager will send a memo to the QAHC Finance section notifying them of the name, start date and salary grade & point of the new worker. A Summary of Terms and Conditions (including Fair Work Information Statement) will be sent to the new appointee for them to sign (along with other paperwork) and return to Finance for their personnel record. On the termination of staff, the manager will send a completed Termination Form to the Finance section, who will process any outstanding wages and entitlements (see QAHC Staff Termination Procedure for more details). Only Finance staff will have access to the payroll system. At the beginning of employment at QAHC, the 1 st of July each year, at any time their salary increases and/or when HECS/FEE-HELP or student loan payments become due, staff should notify the Finance Section of additional tax to be deducted from their pay to cover FEE-HELP and/or student loan repayments. QAHC is not responsible for ensuring sufficient amounts are deduced. Staff are encouraged to seek independent taxation advice. All staff must complete fortnightly timesheets detailing work hours, leave, TOIL etc. and have these approved by their supervisor before providing them to the Finance section (see QAHC Timesheet Procedure for more details). Leave of more than 2 days due to sickness must be accompanied by a doctor s certificate. Staff can not accrue more than a normal week s TOIL, without the approval of their manager. The Senior Finance Officer will conduct a review of Payroll payments on a quarterly basis to check for accuracy. Monthly summaries of accumulated TOIL, annual leave and sick leave will be provided to managers/supervisors to monitor. Staff should submit requests for leave using the Leave Application Form to their manager/supervisor and forward to the Finance section (see QAHC Leave Application Procedure for more details). Page 8

9 Personnel All staff at QAHC will need to provide proof of holding a current Blue Card or apply for and be given a Blue Card as a condition of ongoing employment at QAHC. QAHC will cover the costs of applying for/renewing Blue Cards. Criminal Record checks may be carried out on staff, especially those who handle money or who work unsupervised with vulnerable people. At least 2 reference checks must be completed by the appointing Manager/Supervisor before confirming appointment of staff. Preferably one of these should be the current/most recent employer. Copies of original documentation are required to verify personal details, qualifications etc. and should be kept in the staff member s personnel file. Petty Cash Petty cash will only be kept in the Brisbane Office and will be kept in a cash box, in a locked filling cabinet in a locked office. Staff, especially those not based in Brisbane, are encouraged to use their work credit cards, store accounts (e.g. Coles Card) or purchase orders to make purchases so as to minimise/eliminate the need for regular access to petty cash. Petty cash claims will only be paid on presentation of receipts of the item purchased. Purchasing (Procurement) Accounts with regular suppliers will be opened (e.g. stationery) and discounted terms negotiated. Purchasing of good/services will usually occur through the Finance section or Office Manager, using accounts established above. This will ensure consistency of purchase and control of stock numbers. Purchases should be made wherever possible through official QAHC Purchase Order books, and be signed by a Program Manager. A copy should then be provided to the Finance section. The following information should be completed on all purchase orders: Date; Cost, including GST; Description/quantity of purchased items; Project code; and Page 9

10 Authorised signatory. Purchase Order books commit QAHC to paying for purchases, and so should be kept secure at all times. Staff wishing to make a purchase should request this through their Program Manager. Staff should not use QAHC to purchase items for private use. Staff responsible for purchasing who have a personal and/or pecuniary interest in any firm which QAHC does business must declare this to the General Manager or President and should not be involved in deciding on or negotiating with these firms Staff responsible for purchasing must not accept any major gifts, hospitality, travel or benefits that might in any way tend to influence, or appear to influence, your ability to act impartially. You should also ensure that partners and family members are not recipients of benefits that could be seen to indirectly influence you or secure favourable treatment. Staff must not solicit or accept any bribe, or other improper inducement. Any approaches of this nature are to be reported to senior management (see QAHC Code of Conduct for more details). Staff Travel QAHC taxi cards or etickets are not for personal use. Regular reviews of taxi expenditure will be undertaken by the QAHC Finance section and/or Program Managers and unusual journeys will be investigated. (see Use of Taxi Cards and etickets Policy for more details). Staff travel (flights, accommodation, car hire) is to be made through the Officer Manager for staff based in Brisbane, or directly for non-brisbane based staff. Payment Requisition and/or Credit Card Purchase Form should be authorised by the Supervisor of the staff member concerned. QAHC will pay for travel and accommodation relating to QAHC work away from normal place of residence. If staff wish to extend their stay, this must be paid for by the staff member. Costs associated with meals not included in the accommodation costs (or conference registration etc.) may be claimed by the staff member, using the Meal Allowance Claim Form. (See QAHC Travel and Accommodation Expenses Policy for more details.) Reporting Suspected Fraud Page 10

11 Any person who suspects fraud or corruption at QAHC is required to report this to their supervisor, or if it is not felt appropriate to disclose to their supervisor, then to a Program Manager, General Manager or President. Any such allegations will be treated in strict confidence and investigated as considered appropriate. In the event that QAHC s preliminary assessment of a matter indicates that a criminal offence may have been committed by an individual, the information will be referred to the police. While investigation is likely to be easier when those making a disclosure make their identity known, staff/volunteers are able to make an anonymous report. The more information and evidence provided will make the investigation more successful. The Whistleblowers Protection Act 1994 (Qld) protects staff who report misconduct or maladministration. Under this Act the reporting of misconduct or maladministration is called a public interest disclosure'. It is against the law to persecute someone for making a public interest disclosure. Reprisals against whistleblowers occur when others attempt or conspire to harm someone who has made or intends to make a disclosure. As long as whistleblowers have acted in good faith, they are protected against reprisals by the Whistleblowers Protection Act 1994 and the Crime and Misconduct Act These Acts make it illegal to victimise anyone making a public interest disclosure. Investigating Suspected Fraud The decision to investigate a suspect fraud will be made by the General Manager and/or President, and will be carried out by the General Manager/President and relevant Program manager. External professional advice or assistance may also be sought. The subject matter of the investigation should be defined and an investigation plan developed. It is necessary to determine what questions need to be answered, what information is required to answer those questions and the best way to obtain that information. The investigation must be structured to allow the gathering of sufficient reliable information to enable the issues to be properly addressed by proving or disproving matters relevant to the allegation. An investigation may potentially involve the following investigative activities: interviewing relevant witnesses, both internal and external to QAHC reviewing and collating documentary evidence forensic examination of computer systems examination of telephone records enquires with banks and other financial institutions (subject to obtaining appropriate court orders) data search and seizure Page 11

12 liaison with police or other law enforcement body interviewing persons suspected of fraud or corruption Matters relating to a criminal offence will be reported to the police as early as possible to avoid jeopardising potential police investigation e.g. theft, assault, obtaining benefit by deception, embezzlement or misappropriate of money, bribery. At the conclusion of any investigation, the investigating officers must submit a written report to the General Manager and Board. References: Macquarie University, Fraud and Corruption Prevention Policy City of Onkaparinga, Fraud Prevention and Control Policy ourcommunity.com.au, Fraud Risk Management Policy Tasmania Department of Health and Human Services, Community Sector Fraud Control: Self- Assessment Guide Written & Approved: June 2010 Reviewed: Page 12