Fraud Prevention Policy
Fraud Prevention Policy
1. Policy Statement
This Policy covers the prevention, detection, investigation, and reporting of fraud, corruption, and financial or data-related loss within Datalaw. It applies to all Employees, Contractors, Consultants, Partners, Suppliers, and Members of the Public who engage with Datalaw.
Fraud is an evolving and persistent threat. Increasingly sophisticated methods—including cyber-enabled fraud, identity spoofing, artificial intelligence (AI) manipulation, and data theft—pose significant risks to Datalaw’s operations, finances, data integrity, and reputation.
Datalaw operates a zero-tolerance stance toward fraud in any form. The organisation is committed to:
- Identifying areas vulnerable to fraud
- Implementing controls that prevent fraud
- Detecting fraud that has occurred
- Acting decisively and consistently against perpetrators
- Ensuring systems evolve to counter emerging threats
Management at all levels is responsible for fraud prevention and detection. Any Employee who identifies or suspects fraudulent activity must report it immediately to a member of the Senior Leadership Team (SLT). For concerns raised in confidence, refer to the Whistleblowing Policy, which complies with the UK Whistleblowing Framework 2024.
2. Promoting an Anti-Fraud Culture
Datalaw requires all Employees and Representatives to uphold integrity, honesty, and transparency. Fraud prevention is a shared responsibility.
To reinforce an ethical culture, Datalaw will:
- Maintain clear policies and training relating to anti-fraud, cybersecurity, data protection, bribery, and ethical conduct.
- Ensure annual mandatory training, including updates on AI-enabled fraud and digital impersonation.
- Investigate all allegations—anonymous or identified—with impartiality, confidentiality, and without regard to position, service length, or seniority.
- Review managerial controls following any confirmed fraud to identify whether supervisory failures contributed.
Where Line Managers are negligent in oversight, disciplinary action may apply. Datalaw is committed to continually improving fraud controls and reducing the risk of fraud across all business processes.
3. Definition of Fraud
Under the Fraud Act 2006, fraud may occur through false representation, failure to disclose information, or abuse of position. For the purposes of this Policy, fraud includes any deliberate deception for personal gain or to inflict loss.
Examples include, but are not limited to:
- False expense claims
- Misappropriation of funds
- Deliberate falsification of time records or documents
- Alteration, concealment, or destruction of digital or manual records
- Misuse of IT systems, including unauthorised system access
- AI-generated manipulation (e.g., deepfake audio/video impersonation)
- Cybercrime such as phishing, social engineering, credential theft, or insider data theft
Attempted fraud is treated as seriously as actual fraud.
4. Background and Purpose
The Fraud Prevention Policy supports the development of effective internal controls, transparent reporting systems, a consistent investigative process, and organisational behaviours that deter fraudulent activity. It provides guidance and assigns responsibilities to protect Datalaw, its Employees, and its assets.
5. Scope of the Policy
This Policy applies to all suspected or actual irregularities involving Employees, Shareholders, Contractors and Consultants, Vendors and Suppliers, External agencies, and any individual or organisation with a business relationship with Datalaw. All investigations will be conducted impartially and without regard to seniority or relationship to Datalaw.
6. Role of Management
Each member of Management must understand the types of fraud risks within their operational area; implement robust controls and regularly review them, including IT and data-security measures; respond promptly to any signs of irregularity; and report suspicions immediately to the Managing Director or SLT. All investigations will be coordinated by the SLT in collaboration with Finance, HR, IT Security, and Legal where needed.
7. Actions Constituting Fraud
Fraud, misappropriation, or other fiscal irregularities include, but are not limited to:
- Any dishonest or fraudulent act
- Misappropriation of assets, funds, or property
- Improper handling or reporting of financial transactions
- Profiteering from inside knowledge
- Sharing confidential or proprietary information without authorisation
- Disclosing information about securities or commercial activities
- Accepting or seeking gifts or benefits from external parties (other than those under £50 or approved by Management under the Anti-Bribery Policy)
- Destroying, altering, or inappropriately using Company records or assets
- Cyber-enabled fraud, including access breaches, data theft, ransomware involvement, or unauthorised IT activity
8. Other Irregularities
Issues relating to staff conduct, ethics, or behaviour should be addressed through normal line management and HR procedures. If in doubt about whether an issue constitutes potential fraud, the Managing Director should be consulted.
9. Investigating Responsibilities
The SLT is responsible for investigating suspected fraudulent activity. Where fraud is substantiated, the SLT will produce a formal investigation report, appropriate personnel including the Board will be notified, and Legal counsel will advise on whether to prosecute or refer the matter to external authorities. Investigation conclusions will determine disciplinary, legal, or procedural outcomes.
10. Confidentiality and Data Protection
All reports and investigations will be handled confidentially in accordance with UK GDPR 2024 Reform Guidelines, the Data Protection Act 2018, and Datalaw’s internal Data Protection and Information Security Policies. Employees must not attempt to investigate allegations personally, discuss the matter with colleagues or external parties, or share data or evidence without SLT authorisation. Investigation details will be disclosed strictly on a need-to-know basis.
11. Authority of Investigators
Investigators authorised by the SLT have full access to Company premises and systems; the right to examine, copy, preserve, or secure any documents, files, emails, logs, devices, or records relevant to the investigation; and authority to work with IT Security to secure digital evidence, including logging, timestamping, and preventing data tampering. Such access may occur without prior notice to affected individuals.
12. Reporting Procedure
Employees who suspect fraud must report immediately to a member of the SLT, avoid confronting the suspect, avoid discussing the matter with others, and maintain confidentiality. Anonymous reporting is permitted and protected under the Whistleblowing Policy. All inquiries from suspects, lawyers, or third parties must be directed to the SLT.
13. Termination and Disciplinary Action
Where an investigation leads to a recommendation for disciplinary action or termination, HR and Legal will review the recommendation, Management will make the final employment decision, and if the SLT believes a management decision is inappropriate, the matter will be escalated to Executive Management. Datalaw may also pursue civil recovery of losses, criminal prosecution, or reporting to regulatory bodies or professional authorities.
14. Modern Fraud Risk Controls (2025-2026 Additions)
Datalaw will maintain and regularly update the following measures:
a. Cybersecurity Controls
- Multi-factor authentication (MFA) on all systems
- Regular penetration testing and security audits
- Mandatory cybersecurity awareness training
- Detection and monitoring of unusual activity using AI-assisted security tools
b. AI-Enabled Fraud Safeguards
- Staff training on deepfake risks, spoofed emails/voices, and impersonation
- Verification procedures for unusual or high-value requests
- Secure communication protocols for sensitive operations
c. Data Governance
- Access controls based on least privilege
- Regular review of permissions and audit logs
- Mandatory encryption of sensitive data
d. Financial Controls
- Segregation of duties
- Mandatory dual authorisation for high-risk transactions
- Expense and procurement monitoring
- Vendor due diligence and anti-bribery assessments
15. Policy Review
This Policy will be reviewed annually, or sooner if new fraud risks emerge, legislation or regulatory requirements change, significant incidents occur, or organisational structure changes.
|
Reviewed Date |
04TH December 2025 |
Next Review Due Date |
04TH December 2026 |
|
Reviewed by |
Sarah Parker |
Signature |
Sarah Parker |