To quote our July 8 blog post, “Checklists are used in many settings, typically with the intent to reduce error, increase reliability, and improve the quality of processes and outcomes.” That post explored the U.S. Department of Defense’s whistleblower investigation checklist, one example of how compliance professionals can use checklists.
The Association of Certified Fraud Examiners (ACFE) offers another example with its fraud prevention checklist, found in the 2016 Report to the Nations on Occupational Fraud and Abuse. Whereas the whistleblower investigation checklist mentioned above serves as a self-assessment tool for investigators to use before they finalize and submit investigation results, the ACFE checklist will help compliance professionals and others to assess the effectiveness of their organization’s fraud prevention measures.
The checklist asks eleven questions, many of them followed by additional, related questions.
- Is ongoing anti-fraud training provided to all employees?
- Is an effective fraud reporting mechanism in place?
- To increase employees’ perception of detection, are proactive measures taken and publicized to employees?
- Is the management climate/tone at the top one of honesty and integrity?
- Are fraud risk assessments performed to proactively identify and mitigate the company’s vulnerabilities to internal and external fraud?
- Are strong anti-fraud controls in place and operating effectively?
- Does the internal audit department, if one exists, have adequate resources and authority to operate effectively and without undue influence from senior management?
- Does the hiring policy include reference, credit, and background checks and related steps (where permitted by law)?
- Are employee support programs in place to assist employees struggling with addiction, mental/emotional health, family, or financial problems?
- Is an open-door policy in place that allows employees to speak freely about pressures, providing management the opportunity to alleviate such pressures before they become acute?
- Are anonymous surveys conducted to assess employee morale?
Taken together, these eleven questions and their related follow-ons (and the rest of the information in Report to the Nations) provide not only a way to assess the effectiveness of fraud prevention programs, but also offer an outline for building effective programs.
Of course, there are many other ethics and compliance-related checklists to add to your arsenal. For example, the Society of Corporate Compliance and Ethics’ (SCCE’s) Complete Compliance and Ethics Manual—2016 provides its readers a “general checklist for global code [of ethics] implementation,” a “checklist for assessing investigation capabilities,” and a “checklist for managing third-party risk.” With a little research, you should be able to find checklists to use with all aspects of your ethics and compliance program—hotlines, policies and procedures, training, and more.
Ethical Advocate provides comprehensive ethics and compliance solutions, including ethics and compliance training and confidential and anonymous hotlines. Please contact us for additional information.
ACFE. Report to the Nations on Occupational Fraud and Abuse: 2016 Global Fraud Study, 2016. http://www.acfe.com/rttn2016.aspx
SCCE. Complete Compliance and Ethics Manual—2016. Learn more at http://www.corporatecompliance.org/Products/Books.aspx