CONCEMPTS AND GUIDELINES TO HELP FIGHT FRAUD AND CORRUPTION IN PUBLIC SECTOR ORGANISATIONS by Richard Gudoi Gid'Agui MSc.Audit,MBA,CIA,CFE,CGFM,CFSA

An outline of concepts and guidelines to help fight fraud and corruption in public sector organisations. This documents can go a long way to developing a project implementable and supervised in areas where there is lack of laws and regulations that underpin the struggles in fighting fraud and corruption ,graf and influence pedling in society and or public institutions through procurements and in manay ther areas of concern. This outline does not tnd to ignore other peered reviewd publications towards the same. My intetions is only to stimulate debates around the guidelines with such questions as "what if" Why and by who? toward service delivery expetations. It is food for thought. Concepts and guidelines for fighting fraud and corruption in Public Sector Environment 13th March 2006.revised 2011. CONCEPT PAPER ON ANTI-CORRUPTION/ FRAUD STRATEGY IN PUBLIC SECTOR. By Richard Gudoi Gid’Agui , MSc. Audit(UK), MBA,PGdip.Audit(UK),CIA,CFSA,CGFM,CFE 1.0.Legal frame work: Leadership codes Penal codes Public Procurement and Disposal of Assets -Uganda UN-Charter on rumor-mongering Etc. 2.0.Institutional framework IGG-Inspector General of Government-Uganda POLICE PPDA-Public Procurement and Assets Disposal Act SRPS- Special Revenue Protection Service HOTLINES/Whistle Blowers CIVIL SOCIETY ORGANISATIONS COALITION FOR ANTI CORRUPTION MINISTRY OF ETHICS AND INTEGRITY FREEDOM OF WORSHIP UGANA HUMAN RIGHTS 3.0.Scenario Scandals in procurement processes, Privatization caused downsizing, right sizing of workers hence lots of job loss Abuse of state intelligence facilities Contracts and consultancies favors Not sure of job security-JOB Insecurity Economic pressure for bread earners Investors policy not proper regarding manpower, profit flight People not having the country at heart-not nationalistic Traditional culture in promoting bribes Laxity in enforcement of laws, regulations and guidelines 4.0.Way forward: 1. Detailed employee code of conduct 2. Attitude change through sensitization and 3. Culture of compliance to create and maintain a culture of honesty and high ethics a. Develop an ethical framework to cover fraudulent financial reporting, misappropriation of assets, and Corruption as well as other issues b. Setting the tone at the top- declarations and implementations c. Creating a positive work place environment i. Recognition and reward systems that are in line with the goals and results ii. Equal opportunities iii. Team oriented, collaborative decision making policies iv. Professionally administered compensation programs and career development 4. Hiring and promoting appropriate employees i. Conduct background investigations on individuals being considered for employment or for promotion o positions of rust ii. Thoroughly check a candidate’s education, employment history, and personal references iii. Periodic training of all employees about governmental and work values and code of conduct iv. Incorporating into regular performance reviews an evaluation of how each individual has contributed to creating an appropriate workplace environment in line with the government values and code of conduct. v. Continuous objective evaluation of compliance with governmental /work values and code of conduct, with immediate violations being addressed vi. Background checks for all new hires 5. Training i. Train employees at the time of hiring about the work vales regarding • Cover the expectations of all employees regarding • Their duty to communicate certain matters • A list of types of matters including actual or suspected fraud, to be communicated with specific examples • Information on how to communicate those matters. Other chief accounting officers should confirm employees’ expectations and communicated responsibilities. Training should be at a specific level which shall include the fraud awareness program. ii. Confirmation • Management needs all employees to clearly articulate that all employees will be held accountable to act within the entity’s code of conduct. iii. Discipline • Thorough investigation of the incident should be conducted • Appropriate and consistent actions should be taken against violations • Communication and training should occur to reinforce the government values, code of conduct and expectations 6. Evaluate the risk o fraud and implement the processes, procedures and controls needed to avoid the risks and reduce the opportunities for fraud 7. Evaluate anti-corruption/anti fraud processes and controls I government entity’s i. Identify and measure fraud risks ii. Mitigate fraud risks iii. Implement and monitor appropriate internal controls iv. Appropriate and consistent actions should 8. Develop an appropriate oversight process i. Independent audit committees of the board of directors with appropriate academic and professional qualifications like Certified Internal Auditors and Accountants on their Committee ii. Enact specific internal audit laws immediately iii. Independent auditors and their work to be vetted for quality assurance and compliance with accounting standards iv. Fraud examiners- train national fraud examiners 9. Develop / evaluate organizations code of conduct 10. Review of relevant laws and making them consistent with legal framework 11. Encourage and facilitate whistle blowing in all sectors of the economy 12. Job placement of qualified staff 13. Staff motivation through labor laws 14. Create multi disciplinary committees by strengthening institutions like chartered public accountants of Uganda, association of internal auditors of Uganda, etc. 15. Encourage professionalism(audit and financial reporting) 16. Empower citizen participation on government behalf-local councils 17. Share of proceeds in case one successfully reports fraud 18. Protect whistle blowers and encourage policy on rumor mongering and false allegations 19. Borrow experience from other countries like Israel, USA ,UK, EUROPE ,JAPAN ,e tc on anti corruption measure 20. Enforce deterrent punishments like Honorable Ken Lukyamuzi’s for non observance of leadership code of Uganda. 21. Confirm and investigate declared assets for prudence 22. Investigate conflict of interest and establish un declared directorships of employees in other institutions and compliance with government laws and regulations. 23. Development of government strategy on anti corruption from a holistic approach. Encourage good corporate governance in both public and private institutions 24. Create and facilitate an independent body to vet published accounts separate from Auditor Generals or PAC. Which body shall review all the compliance with standards of financial reporting of CPAs and institutions published accounts to avoid Enron’s case. 25. Provide necessary resources to manage the ant corruption strategy 26. Establish quality controls through satisfaction surveys 27. Institutions of higher learning to start up courses in the philosophy of internal auditing and fraud awareness culture in staff, standards and quality of services and good monitoring mechanism. 28. Corporate governance to critically scrutinize structure, processes, procedures and operational framework to build integrity 29. Develop the concept of integrity to have a positive attitude to foster honest and ethical behavior and work practices that build a strong organization 30. Decision making for employees to increasingly be involved in decisions ,processes and operations of the organizations that results into employee integrity and satisfaction, increased productivity and service satisfaction 31. Corruption resistance to provide zero tolerance to corruption in establishing the capacity to assess the current level of corruption resistance, progressively develop, implement corruption prevention measures, complement corruption trouble shooting and integrity, corruption resistance strategy with the covenant strategic planning. To include: i. Managing conflict of interest ii. Whistle blowing policy-citizen participation hence to report anything that is unethical in relation to government activities 32. Strengthen audit and investigations 33. Empower internal audit and accountancy professions with emphasis on standards and to report fraud related cases 34. Fraud prevention-enact deterrent laws 35. Strong implementation mechanism 36. Effective monitoring mechanism 37. Review of risk management standards 38. Effective communication i.e networks 39. Business and staff code of conduct 40. Review regularly frameworks that are uniformly applied 41. Client partnership i. Shall involve relationship between an organization and its clients for purposes of achieving a common goal. • By setting compliance and compliant systems through hotlines, leaflets, official policies, mass media, information centre links library, • Client satisfaction surveys in government institutions 42. Assessing, detecting and preventing fraudulent activities in government i. achieve buy ins from management and board ii. Educate all stakeholders on the system of internal control activities, information and communication, and monitoring iii. Consider computer assisted audit techniques, ratio analysis, self assessment surveys, fraud interviews iv. Depend on your expertise and experience and trust instincts v. Expand valuable reasoning and examination skills, analytical skills, problem solving, Acton listening. vi. Ask the right questions • How far do employees participate in unacceptable business practices within your organizations without either detection or question • What are the policies and procedures for obtaining cash flow in your organizations • What are the weakest controls in your organizations • What types of fraud prevention activities has your organization as a whole implemented • What is the level of your organizational ethics • Are employees obviously living beyond these means • At your organization, is there an overriding mentality of fraud or personal gain? • How readily do employees adhere to the code of ethics and other suspicious behavior • Does your organization have adequate policies for screening new employees? • Does your organization experience high staff labor turnover 43. Establish strategic integrity framework • empower employees i. Establish risk driven smart work force to produce human resources and other corporate processes that encourage and enable a transparent and integrity driven work force. • Develop a corruption free work force • Pursue risk management awareness strategy for all business processes • Establish effective communication • Government regulatory frameworks • Increase government accountability and maintaining transparent relationship with processes • All leaders to accept and management change • Cultural integrity 44. Government expectations • Develop ethics and integrity strategy to standardize consistency. To be published in the Uganda gazette • Cooperate with recruitment, rotation and relocation of staff guidelines • Transparency in deployment, rotation and relocation of staff guidelines • Competitive remuneration, work condition and gratuity, independent complaints and appeals mechanism • Effective management of conflict of interest and whistle blowing policy • Strengthen audit and investigations • Fraud free operating environment • Comprehensive risk management policy • Effective communication of integrity initiatives • A comprehensive staff code of conduct • Workable regulatory framework • Good customer partnership • Leadership commitment and effective change management initiatives. 45. Implementation channels • The ministry of education and institutions of higher learning • Ministry of ethics and integrity • Government central and local implementers • Churches • National consultants • International consultants • Heads of divisions • Training specialists • Training institutions • Regional contact persons • Administrative staff • Transport and logistics assistant • Receptionists • Secretaries • Storekeepers • Records assistants Richard Gudoi Gid’Agui Author(rgudoi@yahoo.com) ©