i : Introduction

 

The information outlined in this policy and procedures of Oasis Senior Home Care ltd. is against fraud and other forms of dishonesty.

 

It applies to Directors, self-employed professionals, volunteers and anybody associated with Oasis who commits fraud, theft or any other forms of dishonesty, or who becomes aware of it and does not report it, will be subject to appropriate disciplinary action, along with their details passed onto the relevant authorities.

 

Here at Oasis, we take fraud and security extremely seriously. We are mindful that most of the service users are seniors and therefore have the tendency to be more vulnerable. We have stringent procedures we operate by, to protect against an ever-evolving landscape of crime where matters relate to personal and cyber security.

 

 

 

ii : Statement of Intent

 

Oasis 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(s). We will not condone any behaviour that falls short of these principles.

 

All members of Oasis and wider network of professionals have a collective responsibility for putting these principles into practice and for reporting any breaches they discover.

 

 

 

iii : Definitions

 

a) Fraud:  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, someone who works with or is a volunteer or is a subcontractor for Oasis. The criminal act is the attempt to deceive and attempted fraud is therefore treated as seriously as accomplished fraud itself.

 

b) Theft: Dishonestly acquiring, using or disposing of physical or intellectual property belonging to Oasis or the service user or to individual members of the organisation.

 

c) Misuse of equipment: Deliberately misusing materials (incl. intellectual property) or equipment belonging to Oasis for financial or material benefit.

 

d) Abuse of position:   Exploiting a position of trust within the organisation for financial or material benefit.

 

 

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iv : Culture

 

Oasis fosters honesty and integrity in its entire company as with its wider associations, director(s), self-employed staff and volunteers are expected to lead by example in adhering to cultural norms and expectations as with policies, procedures and practices. Equally, members of the public, service users and external organisations (such as suppliers and contractors) are expected to act with integrity and without intent to commit fraud against the company.

 

As part of this, Oasis will provide clear routes by which concerns may be raised by directors, professionals and volunteers. Details of this can be found in the Oasis service user /professional handbook.

 

Senior management are expected to deal promptly, firmly and fairly with suspicions and allegations of fraud or corrupt practices.

 

 

 

v : Responsibilities

 

In relation to the prevention of fraud, theft, misuse of equipment and abuse of position, specific responsibilities are as follows:

 

a) Trustee and Non-Executive Directors:

 

The Directors are responsible for establishing and maintaining a sound system of internal control that supports the achievement of the company’s policies, aims and objectives. 

 

The system of internal control is designed to respond to and manage the whole range of risks which the company faces. 

 

The system of internal control is based on an on-going process designed to identify the principal risks, to evaluate the nature and extent of those risks and to manage them effectively.  Managing fraud risk is seen in the context of the management of this wider range of risks.

 

b) The Chief Executive Officer (CEO):

 

Overall responsibility for managing the risk of fraud has been delegated to the CEO.  The day to day responsibility has been delegated to the HR Lead or equivalent in order of seniority within the company to act on behalf of the CEO in their absence.

 

Their responsibilities include:

• Undertaking a regular review of the fraud risks associated with each of the key organisational objectives.

• Establishing an effective anti-fraud response plan, in proportion to the level of fraud risk identified.

• The design of an effective control environment to prevent fraud.

• Establishing appropriate mechanisms for:

  • reporting fraud risk issues

  • reporting significant incidents of fraud or attempted fraud to the Board of Seniors of the company;

• Liaising with the company’s appointed Auditors (HR Lead)

• Making sure that all parties are aware of the company’s Anti-Fraud Policy and know what their responsibilities are in relation to combating fraud;

• Ensuring that appropriate anti-fraud training is made available to Directors, professionals and volunteers as required; and

• Ensuring that appropriate action is taken to minimise the risk of previous frauds occurring in the future.

 

 

c) Senior Management Team

The Senior Management Team is responsible for:

• Ensuring that an adequate system of internal control exists within their areas of responsibility and that controls operate effectively;

• Preventing and detecting fraud as far as possible;

• Assessing the types of risk involved in the operations for which they are responsible;

• Reviewing the control systems for which they are responsible for regularly;

• Ensuring that controls are being complied with and their systems continue to operate effectively;

• Implementing new controls to reduce the risk of similar fraud occurring where frauds have taken place.

 

d) Self-employed professionals

Everyone is responsible for:

• Acting with propriety in the use of the company’s and service user resources and the handling and use of funds whether they are involved with cash, receipts, payments or dealing with suppliers;

• Conducting themselves with selflessness, integrity, objectivity, accountability, openness, honesty and leadership;

• Being alert to the possibility that unusual events or transactions could be indicators of fraud;

• Alerting the senior members of Oasis and the client when they believe the opportunity for fraud exists e.g. because of poor procedures or lack of effective oversight;

• Reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events; and

• Cooperating fully with whoever is conducting internal checks or reviews or fraud investigations.

 

e) Volunteers

Every volunteer is responsible for:

• Acting with propriety in the use of the company’s and client’s resources and the handling and use of funds whether they are involved with cash, receipts, payments or dealing with suppliers;

• Conducting themselves with selflessness, integrity, objectivity, accountability, openness, honesty and leadership;

• Being alert to the possibility that unusual events or transactions could be indicators of fraud;

• Alerting the senior officials of Oasis when they believe the opportunity for fraud exists e.g. because of poor procedures or lack of effective oversight;

• Reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events; and

• Cooperating fully with whoever is conducting internal checks or reviews or fraud investigations.

 

 

 

 vi : Checks

 

The carers and third-parties we supply, although self-employed delivering any service in any capacity have been verified and checked rigorously by us to ensure you are engaging with a legitimate and where applicable, qualified individual to ensure their competence, as with having the necessary practicing privileges to ensure you are dealing with a character of good-faith. This is to safeguard you so that you can disclose and interact with them freely with confidence and a peace of mind knowing your health and social care provisions are in safe hands. As means of an extra level of protection, everyone will have the necessary insurance cover for their tasks you (The Service User) are commissioning, therefore you can make an informed decision going forward with any under-takings.  

 

Although we carry out the necessary checks to verify an individual, the information supplied to us is ultimately out of our control and is provided by the professional on a request-basis. Whilst every effort is maintained by us to verify the legitimacy of the evidence as with challenging any misleading information within reasonable doubt, it is by no means a guarantee.

 

 

 

vii : Verification & Identity

 

We will never ask for any payments or bank details over the phone or change any methods of transactions to that of what was originally registered/gathered in your original service user profile and agreed with us. We advise accordingly that no party/individual(s) are authorised by us as (Oasis) to divert any monies away from our accounts into private holdings, you have the responsibility to alert us as (Oasis) immediately on the first inclination of suspected foul-play so we can deal with the potential issue early to minimalise further damages and or losses, before it becomes a greater problem. We will always verify your identity with you or your nominated power of attorney to act in ones best interest before discussing any confidential or sensitive matters, thus including the use of a unique SMS message system each time as an identifier, which is registered and referenced against your original contact details on your information we hold on file, it is your responsibility to notify us at first instance if your personal information has been compromised and vice-versa, whichever comes first.

 

 

 

viii : Professionalism & Behaviours

 

Any immoral behaviour or gross-misconduct by any individuals are by no means a reflection of the – Oasis Senior Home Care Ltd. company/brand or its associates, the individual if proven guilty has acted on their own accord as with their actions/intentions/omissions. We have professional expectations and guidelines on how parties we supply should behave, of which they have agreed and signed to follow accordingly in their terms of engagement as well as being outlined in their personal handbook for reference. Oasis Senior Home Care Ltd. condemns the misuse of any information(s) and any forms of exploitation for personal benefit which renders the victim(s) out of monies and for personal interests to gain advantage which has the potential to lead to any degree of suffering caused to the service user.

 

 

 

ix : Investigating an allegation of fraud – procedure

 

Vigorous and prompt investigations will be carried out into all cases of actual or

suspected fraud.

The focus of each investigation is to:

 

• minimise and recover losses;

• establish and secure evidence necessary for criminal or disciplinary action;

• review the reasons for the incident, the measures taken to prevent a

recurrence, and any action needed to strengthen future responses to fraud;

• keep appropriate parties suitably informed;

• assign responsibilities for investigating the incident; and

• establish circumstances in which external specialists should be involved.

 

a) Initiating Action

All actual or suspected incidents should be reported to the Chief Executive Officer.

In certain circumstances, as outlined in the Whistle-Blowing Policy, it may be

necessary to report suspicions directly to the Executive Chairman, the Deputy

Chairman, the Lead of Human Resources, or to an external ‘Prescribed Person’.

You should not contact the suspected individual to determine facts or demand

restitution, or for any other reason. Nor should you discuss the case, facts,

suspicions, or allegations with anyone else, unless specifically asked to do so by

the investigating officer.

If there are reasonable grounds for suspecting that a fraud has occurred, the Chief

Executive Officer should hold a meeting with senior company officials within 24

hours of being notified of the suspicion. A decision will be taken at this stage about

the severity of the suspected fraud.

 

b) Process of investigation

Suspected fraud will be investigated without any undue delay, in an independent,

professional manner and in the interests of all involved.

The investigation process will vary according to the circumstances of each case

and will be determined by the Chief Executive Officer. An investigating officer will

be appointed to take charge of the investigation on a day-to-day basis.

The investigating officer will act in an independent manner, and will hold a senior

management position. The investigating officer will not disclose the details of any suspected or actual incident to other persons, except where such disclosure is necessary to facilitate

the investigation. The investigating officer must not disclose information that may

damage the reputation of persons who may later be found to be innocent of any

alleged wrongdoing, or who may successfully apply for name suppression in a

court of law. Cases of a sensitive nature are to be dealt with by a restricted team

only.

 

c) Suspension of professional against whom an accusation has been made

If there are reasonable grounds for suspicion of fraud, and to facilitate the

investigation, it may be appropriate to suspend an individual against whom an

accusation has been made. This decision will be taken by the Chief Executive

Officer with advice from external Legal Services and Lead of Human

Resources.

In these circumstances, the individual will be supervised at all times before leaving

the premises. Any security passes or keys must be returned. Access to

any system(s) will be withdrawn.

Suspension should not be regarded as disciplinary action nor should it imply guilt.

 

d) Collecting evidence

The investigating officer will take immediate steps to secure physical assets,

including computers/phones and any records and all other potentially evidential

documents. He or she will ensure that appropriate controls are introduced to

prevent further loss.

At all stages of the investigation the investigating officer, in consultation with

Oasis’s nominated Legal advisors, will comply with the Police and

Criminal Evidence Act 1984 (PACE).

The investigating officer will maintain detailed records of the investigation. In

particular, he or she will keep a record of:

 

• telephone conversations;

• face to face discussions;

• document reviews;

• results of investigations.

In addition, the investing officer will keep, where possible, a record of who has

handled each item of evidence, categorising the evidence into the following

groupings:

• prime documents;

• certified copies;

• physical items;

• secondary evidence for discussions;

• circumstantial.

 

e) Investigative interviews

All interviews will be conducted in a fair and proper manner and in accordance with

PACE. Notes of any interviews will be taken and retained on the investigation file.

 

f) Interim reporting

The investigating officer will provide periodic confidential update reports to the

Chief Executive Officer,

Each report will summarise:

• circumstances surrounding case, contributing factors, etc.;

• quantification of losses;

• progress with recovery action;

• progress with any disciplinary/criminal action;

• estimate of resources required to conclude investigation;

• action taken to prevent and detect similar incidents.

The Chief Executive Officer will inform the Lead HR to enable

the preparation of a communications strategy, should it be required.

 

g) Further action

The findings of the investigation will be reported to the Chief Executive Officer

 

h) Final reporting

On completion of an investigation and following the conclusion of action taken a

written report shall be submitted to the Audit Committee, the National Audit Office

and the Internal Auditors containing:

• a description of the incident, including value of any loss, people involved,

and the means of perpetrating the fraud;

• measures taken to prevent recurrence;

• action needed to strengthen future responses to fraud, with a follow-up

report on whether the actions have been taken.

 

i) Recovery of Losses and outcome

The Chief Executive Officer will be responsible for quantifying the amount of any

loss for all fraud investigations. Repayment of losses will normally be sought and

legal advice will be obtained about the options available.

In the event of the discovery of criminal behaviour, Oasis reserves the right to

inform the police who may take the investigation further.

Oasis will take steps to minimise the risk of similar frauds occurring in future.

 

 

 

x : Discipline

 

Oasis will take appropriate legal and/or disciplinary action against the

perpetrators of fraud and those whose failures contributed to the fraud.

 

 

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xi : Disclaimers & Our Role

 

Although we as Oasis have no ongoing management role with the daily provisions of any care/regulated activities, we make regular checks and visits to ensure you are happy with the collective services that are being provided and will support you and the professional accordingly. 

 

 

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xii : Updates & Changes

 

We at – Oasis Senior Home Care Ltd. and the authorised officer(s) reserve the right to amend and change our information and listings accordingly as we see fit on any of our platforms as means of a continual and ongoing process to better improve our company and collective services, it is the service user’s responsibility to check for these periodic changes and updates. This policy will be reviewed on an annual basis.