Introduction

This document has been adopted by the EDF executive committee on September 17^th 2021, to form part of our core financial management.

The purpose of this Fraud Policy is to outline EDFs approach to preventing and dealing with fraud.  EDF is committed to ensure all resources entrusted to the organisation are well managed and protected against any misuse. EDF will take the strongest possible action against EDF staff or representatives who commit fraud.

This policy applies to any irregularity or suspected irregularity involving EDF staff or representatives, as well as with our project partners, or anyone with a formal relationship with EDF, which includes financial transactions, contract, payment, etc.  All fraud allegations will be investigated in the same way, regardless of who is concerned. This policy serves to raise awareness amongst staff and EDF representatives that response plans have been developed to deal with, and minimise the damage caused by any fraudulent event.

Definition of fraud

Fraud may include

• Any dishonest act concerning contracts or finances including theft of money or supplies, false accounting, bribery and corruption, deception and collusion concerning EDF or our partners assets
• Dishonest handling of financial transactions or falsification of expense claims either in paper or online financial records
• Making profit from EDF work beyond someone’s job that they are contracted for
• Accepting or trying to gain things of material value from contractors

Fraud prevention

EDF provides clear guidelines on our financial management; these are made available to all EDF staff and members. Core guidance includes:

• The procurement policy which guides all purchasing and contracting
• The financial handbook which explains to members how to claim expenses and provides tools to do so
• EDF’s accounts, books and financial management are subject to annual revision from an independent external auditor and accounts and financial procedures are regularly checked by an external accountant

How to report suspected cases of fraud

• Suspected cases of fraud should be reported to the Director. This can be done via email (available on the EDF website), and it can be anonymous, although it is better if the person is willing to be identified to assist with the investigation.
• If the Director is implicated in the fraud accusation, the suspected case of fraud should be reported to the President and Treasurer of EDF
• EDF fraud policy, including the relevant contact details for reporting, are included on the Financial Transparency page of our website

Steps taken if suspected fraud is reported

• Each fraud claim will be investigated and responded to within 1 month; all records will be kept securely for 7 years at the EDF office
• The Director or the Treasurer/ President assign responsibility for the investigation and next steps.
• All instances of suspected fraud will be thoroughly investigated and reported to the responsible authorities
• Where initial investigations reveal that there are reasonable grounds for suspicion, and to facilitate the ongoing investigation, it may be appropriate to suspend an employee against whom an accusation has been made. Suspension should not be regarded as disciplinary action, nor should it imply guilt.
• All evidence will be preserved to inform the investigation and made available to the police or others with appropriate authority as necessary
• Confidentiality. Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct.
• The EDF accountant can be called on to review and report on the case- and must be if the amount of the fraud is significant (Over 500 EUR)
• If the fraud case is confirmed, EDF will undertake both disciplinary and corrective actions

• • Corrective actions include: communication with the accused, taking all measures to recover funds, addressing the weaknesses in our policies and procedures which may be identified during the investigation of fraud
  • Disciplinary actions to include: a formal warning at the appropriate level, which may affect eligibility for promotion or salary rises, or in the event of gross misconduct can mean dismissal
• Any illegal financial activity will be reported to the police

Public communication and media enquires

EDF communicates opening on our finances throughout website. Each year our previous years audited accounts are also published.

Should a case of fraud be proven EDF will inform donors and others with a legitimate interest of the case, our response, and measures to prevent further instances.

If there is a fraud case which results in media enquiries EDF will present an open public statement which has been agreed by the EDF President and Treasurer.

• Download Fraud policy Adopted September 17th 2021 (Word)