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CLAIMS HANDLING POLICY
Clinical Negligence, Liabilities to Third Parties and Property Expenses Scheme
Claims
(Policy requirement for NHSLA Risk Management Standards)
LEAD DIRECTOR: Alex Horne, Medical Director
POLICY APPROVED BY: Executive Management Team
DATE POLICY APPROVED: December 2008
IMPLEMENTATION DATE: December 2008
REVIEW DATE: May 2010
Equality Impact Assessment carried out on: Dec 2008
Policy No: RM018
Page 1 of 16
Document Control Sheet
Policy Title
The Claims Handling Policy
of Policy
Purpose The NELMHT Health,
The purpose of this policy is to ensure that all
clinical and non-clinical staff are aware of
procedure to be followed in the event of the trust
receiving a claim.
Lead Director
Alex Horne, Medical Director
Lead
Tim Drew, Assistant Director of Integrated
Governance
Version (state if final
or draft) FINAL VERSION
(Version 2)
Date
October 2008
Circulated for Consultation to: Operational Directors, Trust’s Legal Department.
If draft [only complete remaining boxes]
Draft Number
Comments to
Policy No: RM018
Page 2 of 16
Contents Page
Page no
Assurance Statement 4
1 Introduction 4
2 Purpose 4
3 General Issues 4
4 Types of Claims and Cover 5
5 Responsibility of key staff and departments 6
6 Committees and Groups with Responsibility for Claims 7
7 The Claims Handling Process 8
8 Learning from Experience 9
9 Confidentiality 10
10 Support for Staff 10
11 Links with other Policies 10
12 Training 10
13 Equality Statement 10
14 Reviewing the Policy 10
15 Process of Implementation 10
16 Monitoring Compliance 10
17 References 11
Appendix 1: Claimant Letter 12
Appendix 2: Flow Chart 13
Appendix 3: Equality Impact Assessment 14
Policy No: RM018
Page 3 of 16
ASSURANCE STATEMENT
This policy describes the processes to be followed to enable the Trust to handle any
claims made against it, in accordance with the NHS Litigation Authority’s
requirements. Adherence to this policy ensures the trust assesses and controls all
risks arising from, or associated with, claims made against it.
1. INTODUCTION
Litigation claims are a growing cost to the National Health Service. This policy
is designed to ensure a systematic approach to claims management which is in
line with the guidance issued by the National Health Service Litigation Authority
(NHSLA). The Trust endeavours to control the risks it faces and has developed
strategies to continuously improve its approach to risk management. These
involve reliable communication mechanisms with relevant stakeholders, and a
commitment to look at the circumstances of each claim with a view to learning
any lessons, as appropriate, and to prevent a recurrence.
2. PURPOSE
The purpose of this policy is to ensure that all clinical and non-clinical staff are
aware of procedure to be followed in the event of the trust receiving a claim.
As well as advising of the process to be followed, the policy explains which
people should be involved in delivering the policy, and in what capacity.
When a person has been involved in an incident and wishes to complain about
their treatment, or make a legal claim against the Trust, this should not exclude
them from appropriate help, support, care or treatment from the Trust. No-one
should be treated less favourably because they have made a claim against the
trust.
3. GENERAL ISSUES
3.1 Definition of Claim and the role of NHS Litigation Authority
The Trust recognises a claim as:
“An allegation of negligence and/or a demand for monetary compensation
made following an adverse incident which carries a significant risk of litigation
for the Trust”.
3.2 Who can make a Claim
Claims may come from anyone to whom the Trust owes a duty of care. These
include the following:
Staff (Employer’s Liability)
Members of the Public (Pubic Liability)
Service Users (Public Liability)
Service Users (Clinical Negligence)
Service User’s Carers/family/representatives (Clinical Negligence,
Public Liability)
The Trust itself, e.g. following damage to its property.
3.3 Triggers for Invoking the Claims Procedure
3.3.1 Incidents
Many claims occur as a result of damage sustained by an individual
following an incident. In this situation it is likely that an individual will
seek legal advice to establish whether or not they have a reasonable
Policy No: RM018
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case to suggest that the Trust carries full or partial liability for any or
all of the events which led up to the alleged damage. If their legal
adviser feels he/she has sufficient initial information, then he/she may
commence litigation.
It is not always easy to tell at the time of the incident whether it has
the potential to become a claim and, for this reason, it is paramount
that all incidents are fully investigated and reported promptly and
accurately in line with the Trust’s Incident Reporting Procedure.
3.3.2 Complaints
Some claims develop from complaints the Trust has received. A
complaint becomes a potential claim at such time that a formal
request for monetary compensation is received. At this point the
complaint process ceases and the matter is reported to the NHSLA.
4. TYPES OF CLAIM AND COVER
4.1 Clinical Negligence Scheme for Trusts (CNST)
The CNST is a voluntary “mutual” scheme administered by the NHSLA that
deals with claims for clinical negligence arising on or after 1st April 1995. The
Trust will be indemnified for the full cost of clinical negligence claims provided
the CNST guidelines are followed. The NHSLA will appoint a solicitor from
their panel to act on the Trust’s behalf.
4.2 The Existing Liabilities Scheme (ELS)
The ELS is also administered by the NHSLA. It provides funding for clinical
negligence claims arising before 1st April 1995. Unlike under CNST, no
contributions are payable providing the ELS guidelines are followed.
4.3 Liabilities to Third Parties Scheme (LTPS)
The LTPS is administered by the NHSLA and deals with employer/public
liability claims arising on or after the Trust’s membership of the scheme from
1st April 1999. The Trust pays an annual contribution to the scheme as well
as an excess of £10,000 for each employer liability claim and £3,000 for each
public liability claim.
Employer Liability Claims. It is the Trust’s intention to adhere to agreed
Human Resources Policies and Procedures, in the normal way,
notwithstanding any ongoing legal claims from an employee. Human
Resources will, however, need to liaise with the Trust’s Legal Department,
especially where dismissal is required, to establish whether the specific
situation gives rise to any conflict of interest or requires further legal advice.
4.4 Property Expenses (PES)
The PES is administered by the NHS Litigation Authority and deals with
property claims arising on or after the Trust’s membership of the scheme from
1st April 1999. Membership is voluntary. The Trust pays an annual
contribution to the scheme as well as an excess of £20,000 for each PES
claim.
With effect from 1st August 2006 all new Employee Liability claims reported
to the NHSLA must include the following documentation:
1. NHSLA LTPS Report Form
2. Letter of Claim
3. A completed NHSLA Disclosure List, indicating which documents are
enclosed by means of a tick in the appropriate box.
Policy No: RM018
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4. The declaration must be signed by an Executive Director of the Trust,
e.g. Chief Executive or Finance Director.
These claims must be reported to the NHSLA within 21 days of receipt of
the Letter of Claim, with supporting documentation as above. Claims will
not be accepted into the Scheme without the necessary documents.
Where no ‘list’ and documents are attached, the NHSLA will ‘hold’ the
claim pending receipt of these papers. If papers are not forthcoming
within a month of the first receipt of papers, the NHS Litigation Authority
reserves the right to reject the claim.
4.5 Private Insurance Companies
Employer/public liability and property claims prior to 1st April 1999 are likely to
involve the Trust’s private sector insurers.
If the trust’s uses its freedoms as a Foundation Trust to enter into agreements
to take on responsibilities which sit outside its usual NHS work, the NHSLA
will not provide cover. Under these circumstances, the trust will secure
appropriate cover from a private insurance company.
5 RESPONSIBILITIES OF KEY STAFF AND DEPARTMENTS
5.1 The Chief Executive
As the Accountable Officer, the CEO has overall responsibility for ensuring
that appropriate and effective systems of risk management and internal
control are in place throughout the Trust. The Chief Executive must ensure
that these systems enable the Trust to meet all relevant statutory
requirements, and also that the Trust complies with best practice as
described by the Department of Health, Monitor, the Healthcare Commission/
Care Quality Commission, the NHSLA and any other relevant external bodies.
The Chief Executive has overall responsibility for ensuring that claims are
managed in accordance with this policy.
5.2 Designated Board Member
The Medical Director is responsible for service quality, and ensuring clinical
risks are controlled, as appropriate: this includes ensuring systems are in
place to manage the learning from incidents, serious untoward incidents,
claims, and complaints. The Medical Director is also the designated lead,
responsible for ensuring that claims are managed in accordance with this
policy: the post-holder will ensure that reports into claims are prepared and
presented to the IGC as this policy requires, that learning takes place through
the operation of the Risk Assurance Group (RAG), and that the Chief
Executive is kept informed of any matters of concern relating to this areas of
lead responsibility.
5.3 Operational Directors
Operational Directors are responsible for ensuring that any investigations that
need to be undertaken are conducted using Root Cause Analysis
methodology. Operational Directors also support G&A by responding to
requests for any relevant information, available to them, that may be required
in connection with a claim.
5.4 Investigating Manager
The trust may be asked by the Legal Department to appoint an Investigating
Officer to investigate the circumstances of an incident which led to a claim.
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Often the incident will already have been investigated (e.g. as an incident,
SUI or complaint), and this step will not be necessary.
When an Investigating Manager is appointed, they are to look into the
circumstances leading up to and surrounding the incident as described in
section 7.8 Investigating the Claim.
5.4 Assistant Director of Governance
The Assistant Director of Governance manages the functions of the
Governance and Assurance Department (see below), and provides the Risk
Assurance Group and the Integrated Governance Committee with six-monthly
reports addressing claims (the number of claims and any emerging patterns
or themes).
5.5. Governance and Assurance Department (G&A)
The Governance and Assurance Department takes a lead with NELFT in
managing claims
5.5.1 On receipt of a claim, G&A will immediately pass the claim to the
Legal Department, keeping a paper copy within G&A.
5.5.2 G&A enter the details of each claim into the claims module of the
DATIX database.
5.5.3 The appropriate Operational Director will be informed of the claim and
advised that that they may need to provide further information, if
required. G&A will also ask the Operational Director to have the
incident giving rise to the claim investigated, if deemed necessary by
the Legal Department.
5.5.4 G&A co-ordinates the gathering together of all the information required
by the Legal Department in connection with the claim – for example:
pre-existing reports of the incident (e.g. a back injury sustained at
work), relevant training details (e.g. the claimants record of training in
manual handling), employment history (including time off sick etc).
The information is submitted by G&A to the Legal Claims Manager in
the Legal Department who will then respond directly to the claimant, or
their legal representative.
5.5.6 G&A will employ the DATIX to prepare reports of claims activity, to be
made available to the Risk Assurance Group and the Integrated
Governance Committee.
5.6 Role of Legal Department
5.6.1 The Legal Department will inform the Assistant Director of Integrated
Governance of any claims that have come directly to them and are
relevant to the Trust. Once provided with the necessary information
the Legal Dept will manage all claims on behalf of the trust, being the
point of contact for the claimant and their representatives, and the
trust’s point of contact with the NHSLA.
5.6.2 The legal Department will maintain its own database of claims.
5.6.3 The Legal Department will provide the Assistant Director of
Governance with monthly reports, providing details of the all
outstanding claims, and to advise of any new claims received, or
settlements reached, during the reporting period.
6. COMMITTEES AND GROUPS WITH A RESPONSIBILITY FOR CLAIMS
6.1 Trust Board
The Board has overall responsibility for ensuring the trust pursues its
objectives in ways that are safe, legal, and in line with the requirements good
governance. The Board will wish to be assured that claims are handled in
Policy No: RM018
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line with this policy, that any lessons are being learned, and that any identified
risks being appropriately controlled. The Board will receive reports of claims
activity from the Integrated Governance Committee on a six monthly basis.
6.2 Integrated Governance Committee
The Integrated Governance committee is a subcommittee of, and accountable
to, the Trust Board. Its purpose is to monitor Trust progress against the
Annual Health Check standards and assure the Board that sufficient evidence
is in place to demonstrate compliance, with particular emphasis on all issues
relating to the safety and quality of service delivery. The IGC wishes to be
satisfied that all relevant risks have been identified and are being effectively
managed. If necessary, the IGC may ask for items of concern to be placed
on the appropriate Risk Register or the BAF. The Integrated Governance
Committee will receive a report addressing claims every six months.
6.3 Operational Governance Group
The Operational Governance Group (OGG) is a sub-group of, and
accountable to, the Integrated Governance Committee. The OGG is Chaired
by the Chief Operating Officer. The OGG is responsible for the quality of the
operational delivery of all services, and for ensuring that these all meet
acceptable standards. The Operational Governance Group will ensure that
any learning points arising from claims are applied across the trust.
6.4 Risk Assurance Group
The Risk Assurance Group (RAG) is a sub-group of, and accountable to, the
Operational Governance Group (which, itself, is a sub-group of, and
accountable to, the IGC). The RAG is chaired by the Assistant Director of
Governance. The RAG oversees the management of operational risks at a
pan-NELFT tactical level. The responsibilities of the Risk Assurance Group
include ensuring and overseeing organisational learning from incidents,
complaints and claims. The Assistant Director of Governance will take a six-
monthly report on claims to the RAG.
7. THE CLAIMS HANDLING PROCESS
7.1 All Claims. All claims should be submitted to the G&A. If a claim is
received in another Department, it should be forwarded to the G&A straight
away.
7.2 Letters requesting disclosure. The most common route is for the
Trust to receive a letter from Solicitors acting on behalf of a claimant,
requesting disclosure of documents e.g., medical records, occupational health
records, personal files etc. If received elsewhere in the trust, the letter should
be passed immediately to the G&A. A fee may be charged in accordance
with the Data Protection Act 1998 for the supply of copy documents.
7.3 Letters before action. In this case a letter is received from Solicitors
giving notice of a possible claim for clinical negligence or employer/public
liability. As with disclosure requests, if received elsewhere in the trust, any
such letters must be sent immediately to the G&A.
7.4 Solicitors “Letter of Claim” or service of a Claim Form. There are
critical time limits for responding to these documents. All such documents
must be sent to the G&A immediately where they will be logged and
forwarded onto the Legal Department without delay. The Legal Department
will be notified immediately by phone or fax if either is received.
Policy No: RM018
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7.5 Advising the Legal Dept. On receipt of a claim, G&A will
immediately pass the claim to the Legal Department. A paper copy of the
claim will be kept within G&A, and the details entered into the claims module
of the DATIX database.
7.6 Information Gathering. G&A will gather the information necessary,
as required by the Legal Dept. and will send it to the Legal Dept as soon as it
is available.
7.7 Managing the Claim. The Legal Dept will manage all claims on
behalf of the trust, and will be the point of contact for claimants and their
representatives.
7.8 Investigating the Claim. If the Legal Dept finds that the incident that
gave rise to a claim needs to be investigated, they will advise G&A, who will
ask the appropriate Director to appoint an Investigation Manager. The
investigation/analysis will incorporate a full account of the incident, identifying
all the relevant individuals and documentation involved. The Investigating
Officer will use Root Cause Analysis methodology in order to get the heart of
the matter and to establish a full and complete understanding of the issues. A
report of the investigation will be written: this report will describe the process
the investigation followed, reference all sources of information and attach all
statements taken. The report will identify the factors that contributed to the
incident and any root cause that may have been established. As appropriate
to the circumstances, the report may end with recommendations to ensure
proper controls are introduced to prevent a recurrence. On completion of the
investigation the relevant Director will provide the report to G&A, from where it
will be submitted to the Legal Department who will direct all further
investigations and, where appropriate, notify the NHSLA, under the
appropriate scheme: CNST, ELS, LTPS or PES.
7.9. Settlement of Claims. The decision as to whether to defend or settle
a claim will be made by the NHSLA or, where appropriate, by an insurance
company. All decisions whether to settle a claim will be informed by an
assessment of the risk of losing a trial and the cost of continuing to defend the
claim. If a claim is considered to be defensible, it will be defended: it will not
be settled simply for the sake of expediency.
7.10 Requests for Payment. If a claim against the trust proves
successful, the request for payment is sent from the Legal Department. This
is entered against the entry on Datix and sent to the Finance Department to
be authorised for payment.
7.11 Feedback. The Legal Department will provide feedback to G&A on all
claims, drawing attention to any learning points that might have emerged.
8. REPORTING REQUIREMENTS FOR CLAIMS
8.1 Requests for disclosure of health records to be processed within 40 days.
8.2 Check the sufficient initial information has been provided by patient or adviser
and request more if necessary.
8.3 Collect, retain, paginate and index relevant records.
8.4 Undertake preliminary analysis.
8.5 Have system in place for identifying adverse incidents, significant
litigation risks etc.
8.6 Report relevant cases to NHSLA within 2 months of request for records
or sooner if event is serious.
Policy No: RM018
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8.7 All Letters of Claim and Part 36 offers to be notified to NHSLA
immediately.
8.8 Acknowledge Letters of Claim within 14 days.
8.9 Detailed response due within 3 months.
8.10 All legal proceedings to be notified to NHSLA immediately
8.11 Have a system in place for identifying and appropriately investigating
and documenting adverse incidents as soon as they are discovered.
8.12 Report all Letters of Claim to the NHSLA within 21 days of receipt of
the Letter of claim, with a completed LTPS Report Form and all existing
accident records, reports, and related documents.
8.13 Acknowledge all Letters of Claim within 21 days.
8.14 All subsequent letters and in particular all Part 36 offers to be notified
to NHSLA immediately.
8.15 Ensure priority is given to identifying, creating and sending further
documents and information requested by the NHSLA on any claim.
8.16 All legal proceedings to be notified immediately.
Reporting to External Agencies
The Legal Services Manager will identify if there are any reporting
requirements to external organisations and whether such organisations
should be involved in the investigations/root cause analysis. This may
include organisations as detailed within Appendix 4 of this document.
External agencies may need to be involved where for example:
● Police – where a criminal offence has occurred or is suspected
● Professional Regulatory Bodies – where allegations of negligence are
involved.
This list is not exhaustive.
Where claims have initially been investigated as a result of an incident report,
appropriate external agencies will have been involved at that stage. In terms
of new claims where investigations have not yet been carried out, the
circumstances of each individual case will determine which external agencies
should be brought into the investigation and reporting process and when.
9. LEARNING FROM EXPERIENCE
12.1. The information arising from claims is used in the same way as that
obtained from complaints, incidents and serious untoward incidents: that is, to
highlight areas for improvement.
12.2 Investigating Officers may end their report with recommendations to
ensure proper controls are introduced to prevent a recurrence.
12.3 The Legal Department will liaise with the Assistant Director of
Governance on any issues arising from claims affecting clinical
governance/risk management. They will agree if wider follow up action to
prevent a recurrence of the events is required.
12.4 Whilst local action plans will be taken forward with Operational
Directorates, the Assistant Director of Governance will take all overarching
themes, and any opportunity for wider organisational learning, to the Risk
Assurance Group. This setting holds responsibility for ensuring that lessons
Policy No: RM018
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are learned from serious patient safety incidents, claims, and from serious
complaints.
9. CONFIDENTIALITY
The trust will ensure the confidentiality of all information pertaining to claims
in line with their policies.
10. SUPPORT FOR STAFF
It can be very distressing for a staff member to know that a claim has been
lodged in relation to an incident in which they were involved or where they
held a particular responsibility. The trust will treat any staff member involved
in a claim with sensitivity, keep them informed of progress, and ensure they
have sight of any response letters. The trust will support all staff in this
situation in line with the Being Open Policy and the trust’s HR practice. Any
staff member distressed by a claim can access the trust’s confidential
counselling service.
11. LINKS WITH OTHER POLICIES
Incidents & SUI Reporting Policy
Complaints Policy
Being Open and Honest Policy
Disciplinary Policy
Risk Management Strategy
Post Incident Policy
12. TRAINING
The trust offers training in route cause analysis to support those who may be
called upon to investigate serious incidents and claims.
13. EQUALITY STATEMENT
The Trust’s mission is to help service users to live the life they want and their
vision is to have in place a sustainable people-driven service system of care
which is ‘best of class’. The Trust values empowering people and ensuring
that it does not treat any individuals or groups of people unfairly.
14. REVEWING THIS POLICY
The policy will be reviewed every two years or more often if changes make it
necessary. It is the responsibility of the Lead Director to ensure that the
policy is reviewed and revised in accordance with the NHSLA requirements,
and/or altered circumstances.
15. PROCESS OF IMPLEMENTATION
The policy will be disseminated via email to all the Operational Directors and
Chairs of the Operational Integrated Governance Groups.
General awareness of the policy will be made to all clinical and non-clinical
staff via News in Brief.
16. MONITORING COMPLIANCE
Any difficulties staff experience in following this policy will be brought to the
attention of the Assistant Director of Integrated Governance. As appropriate
Policy No: RM018
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to the issue, these difficulties will either be addressed at the time they are
raised, or when the policy is next reviewed.
The Legal Department and the Director of Integrated Governance will
annually review compliance with the policy, providing feedback to inform the
policy’s revision.
17. REFERENCES
Department of Constitutional Affairs, (1998); Pre-action Protocols for the
Resolution of Clinical Disputes 1998/183 [on line], London: The Stationary
Office. Available from: http://www.justice.gov.uk/
Department for Constitutional Affairs, (1998); Pre-Action Protocol for Personal
Injury Claims [on line]. London, The Stationary Office. Available from
http://www.justice.gov.uk/
The National Health Service Litigation Authority Framework Document.
Available from www.nhsla.com (publication – Claims publication).
Clinical Negligence Reporting Guidelines; Fourth Edition (January 2007);
Available from www.nhsla.com (publications – Claims publication).
Non-clinical Claims Reporting Guidelines. Available from www.nhsla.com
(Publications – Claims publications).
NHSLA Disclosure List. Available from www.nhsla.com (publications –
Claims Publications).
Policy No: RM018
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Appendix 1
Department of Governance and Assurance
Goodmayes Hospital
Ilford
ESSEX
IG3 8XJ
Date
Borough Director
Barking and Dagenham
Havering
Learning Disabilities
Redbridge
Waltham Forest
Dear
Re: Claimants Name
Incident Date
I would like to inform you that the above named have made a claim against the Trust.
You will be required/not required to nominate a manager to investigate this claim, undertake a
root cause analysis and to provide a final report on the incident.
Can you please send me the following information by close of play on (Date):
1. Accident book entry
2. First aider report
3. Copy of Incident Report
4. RIDDOR report to HSE
5. Training Records
6. Care Plan and Risk Assessments
Yours sincerely
Assistant Director of Integrated Governance
Policy No: RM018
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Appendix 2
A Claim is Received by the Governance & Assurance Dept
Governance & Assurance
Collect the information
Appropriate Director advised
Reported Risk Assurance
to the Group
various
groups
Integrated Governance
Appropriate Director maybe asked to Legal Department Committee
Appoint an investigating officer
Manages claim process
with NHSLA
Report Feedback
Policy No: RM018
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Appendix 3
Equality Impact Assessment Screening Tool
(Please include this as part of your policy)
Directorate/Department Governance and Assurance Department
Policy or Procedural Guidelines Title/Service Claims Handling Policy
New or Existing Policy/Service? Existing Policy reviewed
Name and role of Assessor Tim Drew, Assistant Director of Integrated
Governance
th
Date of Assessment 12 December 2008
Please complete the following questions
Yes/No Comments
1 Does the policy/guidance affect one
group less or more favourably than
another on the basis of:
Race, Ethnic origins (including, No
gypsies and travellers) and
Nationality
Gender No
Age No
Religion, Belief or Culture No
Disability – mental and physical No
disability
Sexual orientation including lesbian, No
gay and bisexual people
2 Is there any evidence that some groups No
are affected differently?
3 Is there a need for external or user Yes The policy was consulted on with
consultation? the Legal department solicitors
4 If you have identified potential No
discrimination, are any exceptions valid,
legal and/or justifiable?
5 Is the impact of the policy/guidance likely No
to be negative?
6 If so, can be impact be justifiable?
7 What alternatives are there to achieving
the policy/guidelines without the impact?
8 Can we reduce the impact by taking Yes Developing information leaflets
different actions?
Recommendation
Full Equality Impact Assessment required: NO ■ YES □
Assessor’s Name: Tim Drew Date: 12/12/2008
Name of Director: Alex Horne, Medical Director
Assessment authorised by: Name: Harjit K Bansal Date: 12/12/2008
(member of the Equality and Diversity Group)
Policy No: RM018
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Appendix 4
EXTERNAL ORGANISATIONS TO WHOM INCIDENTS MAY NEED TO BE
REPORTED AND MAY NEED TO BE INVOLVED IN INVESTIGATIONS
Centre for communicable disease control
Health Protection Agency
Healthcare Commission
National Patient Safety Agency
Confidential Inquiries
Coroner
Department of Health
National Clinical Assessment Authority
Environment Agency
Food Standards Agency
Strategic Health Authority
Health & Safety Executive
Medical Devices Agency
Mental Health Act Commission
National Radiological Protection Board
NHS Estates
NHS Litigation Authority
Police
Professional regulatory bodies ( e.g GMC)
Public Health Laboratory Service
Serious Hazards of Transfusion (SHOT)
The Directorate for Counter Fraud Services
(Please note that this list is not exhaustive and aims to serve as a aide
memoir)
Policy No: RM018
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