Purpose of These Guidelines
These Prevention of Financial Wrongdoing policy guidelines have been produced to provide guidance to members on how to develop, implement and review their financial wrongdoing policies and procedures. They represent good practice in the prevention of financial wrongdoing and have been developed in a way that reflects both domestic and international good practice standards and the compliance expectations of the ACFID Code of Conduct.
This document combines guidelines for the development of a single Prevention of Financial Wrongdoing policy. Some members may choose to have different financial wrongdoing elements addressed in separate policies. Provided that all financial wrongdoing elements are covered, the latter approach would also be compliant with the ACFID Code of Conduct. The nature of the risk around each element of financial wrongdoing, your strategies and processes to mitigate risk and treat incidents and your operational context may determine whether it is appropriate to have one overall financial wrongdoing policy or for it to be split. In this regard, it is important to consider which approach best communicates your policy to its users. For example, where reporting and investigation processes are different for different types of financial wrongdoing, the policy may become too cumbersome and it may be better to have several policies to assist understanding.
Additionally, it is expected that organisations would have elements of other policies or documents that would support the prevention of financial wrongdoing. For example, a Recruitment and Selection Policy would contain clauses that deal with screening of staff prior to employment with the organisation, and the Staff Code of Conduct would contain a clause relating to conflict of interest.
Separate procedures and supporting tools should be created to operationalise the organisation’s Prevention of Financial Wrongdoing policy. Procedures should include specific guidelines on how the organisation will implement different components of the policy and may provide links to other organisational documents, policies, codes and tools in order to ensure that the prevention of financial wrongdoing is relevant and integrated into the organisational culture.