Fraud advice for parent carer forums As an organisation, Contact is aware that parent carer forums are vulnerable to fraud from time to time. Find out how to protect your forum. In this article What is fraud? Action Fraud (the UK’s national reporting centre for fraud and cyber crime) states that “fraud is when trickery is used to gain a dishonest advantage, which is often financial, over another person.” Fraud can be committed against individuals and organisations. Why do forums need to educate themselves about fraud? As an organisation, Contact is aware that parent carer forums are vulnerable to fraud from time to time. This can be in the form of internal fraud, committed by someone within the forum. Or it can be external fraud, by people that may not be directly involved in the forum. Although fraud or misuse of funds is not a common occurrence, it is something that all forums need to be aware of, take steps to protect against, and combat. It is important to take fraud seriously as a parent carer forum. By taking immediate action, you will help to protect individuals in the forum, and the forum itself, allowing it to continue its good work. We believe the best way to counter fraud is through education. A better informed forum will be able to put measures in place to prevent fraud from occurring and to spot it quickly if it does happen. Your forum’s responsibilities as the recipient of the Department for Education (DfE) grant – a reminder to all forums Parent carer forum committees or steering groups are responsible for managing public money effectively and for putting appropriate policies and safeguards in place to protect it. Forums are accountable to both their membership and the DfE. They must spend the grant money wisely to maximise their positive impact on the development of services for families of children and young people with special educational needs and disabilities (SEND) in their area. If your forum needs support with budgeting, planning or any other aspect of managing the grant or running the forum, talk to your parent carer participation adviser. What actions should you be taking now? We don’t expect forums to take on all this information and guidance overnight. You should be continually working towards implementing these common-sense steps to protect public money and your forum’s members. Induction of new forum members and staff We recommend that all new forum members* and any forum staff familiarise themselves with the forum’s policies and procedures, including the finance and fraud policy, as part of their induction process. * who will either be involved in the forum’s financial procedures, are employed staff, or who will claim expenses or remuneration from the forum, make purchases on the forum’s behalf, or who has a potential conflict of interest. More information about the DfE grant For further information about managing the DfE’s parent carer participation grant, see our grants page and supporting documentation: Managing your parent carer participation grant (advice on POE’s expense claims and remuneration claims) Your forum also has complimentary access to Community Matters for specialist advice on Governance and legal matters. What do we need to know about fraud? Below we’ve put together some useful resources for forums that are available online. Most of these materials focus on ‘charities’, and although not all forums are charities, the resources are still relevant. It is important that you read the materials to understand the potential risk of fraud to your forum and to incorporate elements of what you learn into your forum’s financial policy. Parent carer forums are organisations in receipt of public money, and the expectations upon them will be very similar. Tackling charity fraud: Eight guiding principles Here are some key points from the Charity Commission (UK government), from October 2019. 1. Fraud will always happen – simply being a charity is no defence Even the best-prepared organisations cannot prevent all fraud. Charities are no less likely to be targeted than organisations in the private or public sector. Fraudsters don’t give a free pass to charitable activities. 2. Fraud threats change constantly Fraud evolves continually, and faster, thanks to digital technology. Charities need to be alert, agile and able to adapt their defences quickly and appropriately. 3. Prevention is (far) better than cure Effective prevention can reduce financial loss and reputational damage. It is far more cost-effective to prevent fraud than to investigate it and remedy the damage done. 4. Fraudsters exploit trust Charities rely on trust and goodwill, which fraudsters try to exploit. A strong counter-fraud culture should be developed to encourage the robust use of fraud prevention controls and a willingness to challenge unusual activities and behaviour. 5. Discovering fraud is a good thing The first step in fighting fraud is to find it. This requires charities to talk openly and honestly about fraud. When charities don’t do this the only people who benefit are the fraudsters themselves. 6. Report every individual fraud The timely reporting of fraud to police, regulators and other agencies is fundamental to strengthening the resilience of individual charities and the sector as a whole. 7. Anti-fraud responses should be proportionate to charity’s size, activities & fraud risks The vital first step in fighting fraud is to implement robust financial controls and get everyone in the charity to sign up to them. 8. Fighting fraud is a job for everyone Everybody involved – trustees, managers, employees, volunteers, beneficiaries – has a part to play in fighting fraud. Trustees in particular should manage fraud risks actively to satisfy themselves that the necessary counter-fraud arrangements are in place and working properly. Download the Guiding Principles for Tackling Fraud – October 2019 [PDF]. “Small Charities Guide to Preventing Fraud” (Counter Fraud Campaign) Small Charities Guide to Preventing Fraud We recommend that forum committees/steering groups read the excerpt from ‘Small Charities Guide to Preventing Fraud”: How to protect your charity from fraud, pages eight to 14. Develop an anti-fraud policy But this must not sit on the shelf, it must be something actively advocated. What should a fraud policy include? Culture of ethical behaviour. Think about your charity (forum). What is your culture towards fraud? Everyone, not just finance people, are responsible for stopping fraud. Assess your risks. Undertake regular assessments. Implement robust financial controls Review your fraud policy annually A fraud policy cannot just sit on the shelf; it needs to be adapted. Communicate your fraud policy to all staff, volunteers and trustees Ensure robust recruitment procedures. Trustees (committee/steering group) need to know their legal duties Communicating about your work to combat fraud Regular emails, verbal updates, information in annual report. Develop a whistleblowing policy Keep records of suspected and confirmed fraud. Serious Incident Reporting. Tips for protecting against fraud from our parent carer participation team Using expense claim forms Always check expense claims thoroughly, including claims for remuneration. Check that everything adds up correctly. Check for any duplicate claims. Check mileage against AA Route Planner or another online mileage calculator. Have clear guidance on mileage claims in your financial control policy, e.g. mileage is from the starting point to the destination, and return. If any additional mileage is claimed, it must be on behalf of forum business and approved. People cannot approve their own mileage, expense or remuneration claims. Check all claims and invoices and authorise before actioning any payment. It is really important that the approval process is more than just a box-ticking exercise – check the accuracy and authenticity of all claims. Making financial decisions Financial decisions should be made by authorised officer from the committee or steering group, or a finance sub-committee depending on what your forum’s governing document states. Key decisions should be recorded in minutes of meetings. ‘Conflicts of interest’ should be a regular item on your meeting agenda. Anyone with a vested interest in financial or business decisions should not be part of the discussion or decision making and should step out of the room while discussions take place and decisions are made. Obtain two or three quotes for large spend items or pieces of work. Record all decisions about paid work. Proper agreements should be in place with the people or organisations providing these services. All forum committees or steering groups should carry out an annual planning session that includes finance, to properly budget for activities. Forum committee or steering group members are all responsible for the forum’s finances. It’s everyone’s business to have oversight of spend and funding. Never sign on someone else’s behalf, and don’t let anybody else sign for you. Only use your own signature for documents. Have a clear and specific expenses policy to outline what can and can’t be claimed for and keep a check on your budget. Making payments Be clear about how many people can sign cheques, use a debit card or make online payments. Have a minimum of three signatures for the bank account. Nobody should sign a cheque or make a payment to themselves, a partner, spouse or other relative. Keep cash withdrawals to a minimum. If you use petty cash, at least two people should check this monthly and reconcile petty cash slips. Never sign blank cheques. Never make personal purchases using the forum money. This includes purchases with cash, online accounts or online banking. Nobody should be signing off or paying their own expenses or those of a family member or partner. Communication If you’re concerned about anything, talk to your parent carer participation adviser. Be open and honest with funders about the forum’s finances, share annual accounts, budgets and progress against spend to build trusting relationships with them. Handle public money responsibly – budget and plan carefully. If you need help with this, contact your parent carer participation adviser. Set up systems and communication channels to ensure that all approved activities from the grant are on track. Individual email accounts of forum members should not be accessible to anybody other than the individual and should be password protected to ensure that nobody is able to read/edit/delete/or send their emails. This is especially important if they authorise expenses/expenditure via email. Common types of fraud to look out for: Falsifying or inflating claims for travel or remuneration e.g. claiming for more hours than have been worked or claiming more miles than were travelled when on forum business. Dishonesty regarding the forum’s financial position, or deception. Fraudulent invoices for: website design, venues, refreshments, IT support or office rent. Submitting genuine invoices as proof of expenditure which have not been paid. Withdrawing petty cash and submitting fraudulent receipts as evidence of spend. Duplicating or making double claims e.g. claiming the same expenses twice. This can be accidental in many cases, but can also be done deliberately. Useful online resources for forums about fraud See below for resources that will support your understanding of how to protect your forum, and its members, from fraud:. “Invoice fraud” (Fraud Advisory Panel) Invoice Fraud – April 2019 A factsheet from the Fraud Advisory Panel explaining what invoice fraud is, how to detect it, what the warning signs are, and what actions to take. It encourages groups to trust their instincts. “If you think something is suspicious, it probably is.” Forums will find this particularly useful and relevant. “Your Group’s Money” (Resource Centre, a useful place for community groups) Your Group’s Money Information and tips to help your whole community take responsibility for looking after your group’s money. Includes lots of easy-to-follow and practical advice. A key point is that “finances are the responsibility of the committee and members not just the treasurer!” “Financial Rules” (Resource Centre, a useful place for community groups) Financial Rules are your community group’s agreements about how it will look after its money. As well as helping your group to function better, financial rules show funders and other bodies that your group is looking after its money well. “Protect your charity from fraud and cyber-crime” (The Charity Commission, GOV.UK) Protect Your charity from fraud and cyber-crime Information about fraud and cyber-crime, how to spot it and what you can do to protect against it. Preventing Charity Fraud – Insights + Action (Fraud Advisory Panel/Charity Commission) Preventing Charity Fraud – October 2019 Useful website links The Charity Commission gov.uk/government/organisations/charity-commission gov.uk/guidance/charity-money-how-to-keep-it-safe Charity Finance Group cfg.org.uk Fraud Advisory Panel fraudadvisorypanel.org The Foundation for Social Improvement (FSI) thefsi.org National Cyber Security Centre (NCSC) ncsc.gov.uk NCVO – Financial Management – Fraud knowhow.ncvo.org.uk/organisation/financial-management/processes-procedures-and-controls/fraud Resource centre – a useful place for community groups resourcecentre.org.uk resourcecentre.org.uk/wp-content/uploads/2014/07/Your-groups-money.pdf Small Charities Coalition smallcharities.org.uk Small Charity Finance Programme smallcharityfinance.org.uk smallcharityfinance.org.uk/resources smallcharityfinance.org.uk/wp-content/uploads/2016/06/CF240-Small-Charities-Guide-1.pdf