There are specific requirements that all organisations should take note of in their formulation of a sound foundation for managing fraud and corruption risks and this foundation requires augmentation in respect of organisation specific environments.

As a minimum, organisations should have all of the measures below in place (this list is not exhaustive and serves as a foundation for managing fraud and corruption risks):

1. Embed an effective fraud prevention strategy: Ensure that there is an approved Fraud Prevention Strategy, Protected Disclosures Policy, Conflict of Interest Policy, Anti- Bribery and Corruption Policy and Fraud Response Plan (including cyber-incident response), which are clearly articulated, implemented and communicated throughout  the  organisation.
2. Implement a tiered approach: Implement a three-tier approach to reducing fraud and corruption, which should include essential elements of prevention, response and detection.
3. Effective fraud risk assessments: Initiate on-going Fraud Risk Assessments (including assessment of cyber-related risks), which are a non-negotiable element of mitigating the risks of fraud; these should be conducted at an Enterprise and Business Unit level.
4. Optimise the use of technology in detecting fraud: Leverage technology in order to implement Continuous Control Monitoring measures through Forensic Data Analytics aimed at the early detection of fraud and corruption risk indicators.
5. Assessing employee awareness: Conduct an annual online Fraud Health Check survey amongst employees, which should ideally be anonymous in nature.
6. Eliminating conflicts of interests: Manage the risk of Conflicts of interest through implementation of an auditable declaration process where all declarations are assessed and verified.
7. Managing relationships with external stakeholders: Discourage/prohibit the receipt of gifts from suppliers as this alleviates the risk of potential irregularities and furthermore reduces the administration of any gift register.
8. Know your business partners: Supplier vetting should entail stringent verification and approval measures, including a Conflict of Interest Declaration.
9. Creating awareness: Fraud Awareness and Anti- Fraud Education should be consistently applied throughout the organisation and a continuous basis.
10. Inform employees how to raise concerns: Organisations should ensure all employees know the policy for making protected disclosures under the Protected Disclosure Act 2014.