This document sets out the policy and procedures of the Ocean Giants Trust (Ocean Giants Trust) against fraud, corruption, bribery and other forms of dishonesty, together with the steps that must be taken where any of these practices is suspected or discovered.
It applies to Trustees, volunteers and partner organisations. Anybody associated with the Ocean Giants Trust who commits bribery, fraud, theft, or any other dishonesty or who becomes aware of it and does not report it, will be subject to appropriate disciplinary action.
Statement of Intent
The Ocean Giants Trust will continually strive to ensure that all its financial and administrative processes are carried out and reported honestly, accurately, transparently and accountably and that all decisions are taken objectively and free of personal interest. We will not condone any behaviour that falls short of these principles.
All members of the organisation have a responsibility for putting these principles into practice and for reporting any breaches they discover.
A deliberate intent to acquire money or goods dishonestly through the falsification of records or documents. The deliberate changing of financial statements or other records by either a member of the public or someone who works for or is a volunteer for Ocean Giants Trust. The criminal act is the attempt to deceive and attempted fraud is therefore treated as seriously as accomplished fraud.
Dishonestly acquiring, suing or disposing of physical or intellectual property belonging to Ocean Giants Trust or to individual members of the organisation.
Misuse of equipment
Deliberately misusing materials or equipment belonging to Ocean Giants Trust.
Abuse of position
Exploiting a position of trust within the organisation.
Offering, promising or giving someone a financial or other advantage to encourage them to perform their functions or activities improperly, including where it is known or believed that the acceptance of the advantage in itself constitutes improper performance. It also means asking for or agreeing to accept a bribe.
Small bribes paid to speed up a service are sometimes called facilitation payments. Some charities work in areas where such payments are the norm in the local culture, often where charitable need is extreme. Notwithstanding the small amounts usually involved, they are still bribery payments. Therefore, they are an unacceptable use of charity funds.
Ocean Giants Trust’s culture is intended to foster honesty and integrity, and is underpinned by our values. Trustees and volunteers are expected to lead by example in adhering to policies, procedures and practices. Equally, supporters, partners and external organisations (such as suppliers and contractors) are expected to act with integrity and without intent to commit fraud against the Trust in any dealings they may have with the Trust.
In relation to the prevention of fraud, theft, misuse of equipment and abuse of position, specific responsibilities are as follows:
The Trustees are responsible for establishing and maintaining a sound system of internal control that supports the achievement of the Trust’s policies, aims and objectives, whilst at the same time controlling the risks that the Trust faces. Managing fraud risk is seen in this context.
Every volunteer is responsible for:
- acting with propriety in the use of the Trust’s resources and the handling and use of funds whether they are involved with cash, receipts, payments or dealing with suppliers;
- being alert to the possibility that unusual events or transactions could be indicators of fraud;
- reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events; and
- co-operating fully with whoever is conducting internal checks or reviews or fraud investigations.
Detection and Investigation
Whilst having regard to the requirements of the Data Protection legislation, the Trust actively participates in an exchange of information with external agencies on fraud, corruption and bribery. It is often the alertness of Trustees, staff or volunteers and the general public to the possibility of fraud and corruption that leads to detection of financial irregularity.
The Chair of the Board of Trustees must be notified immediately of all financial or accounting irregularities or suspected irregularities or of any circumstances which may suggest the possibility of irregularities including those affecting cash, stores, property, remuneration or allowances.
Reporting of suspected irregularities is essential as it initiates:
- a proper investigation by experienced staff, and ensures the consistent treatment of information regarding fraud and corruption;
- appointment of a designated officer, auditor or other adviser, by the Chair to conduct investigations;
- the designated officer, auditor or other advisor will:
- deal promptly with the matter;
- record evidence received;
- ensure the security and confidentiality of evidence;
- work closely with senior managers of the Trust and other agencies, such as the Police and Courts to ensure that all issues are properly investigated and reported upon; and
- ensure maximum recoveries are made on behalf of the Trust.
This policy will be reviewed on an annual basis.