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DEPARTMENT OF FINANCE AND PERSONNEL

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					            Department of Finance and Personnel




                          Fraud Prevention Policy

                                       And

                              Fraud Response Plan




                              October 2009 (Revised)




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   Section                                Title                  Page

        1         Introduction                                   3
        2         Definition of Fraud                            3
        3         Departmental Responsibilities                  5
        4         Line Manager Responsibilities                  6
        5         Internal Audit                                 8
        6         Staff Responsibilities                         8
        7         Fraud Investigation                            10
        8         DARD Central Investigation Service             11
        9         DFP Fraud Working Group                        12
       10         Fraud Risk Assessment                          13
       11         Disciplinary Action                            15
       12         Malicious Allegations                          15
       13         Conclusion                                     15

                  Fraud Response Plan                            17

                  Appendix 1 – Reporting Suspected Fraud          23
                  Appendix 2 – Fraud Indicators                   24
                  Appendix 3 – Common Methods and Types of Fraud 26
                  Appendix 4 – Good Management Practices          27
                  Appendix 5– Best Practice for Reporting Fraud   29
                  Appendix 6 - Whistleblowing                     30
                  Appendix 7 – Contact Details                    31
                  Appendix 8 – Gifts and Hospitality Guidance     32
                  Appendix 9 – Fraud Risk Assessment              73
                  Appendix 10 – Service Level Agreement with DARD 74
                  CIS
                  Appendix 11 – Memorandum of Understanding      87




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1.0    INTRODUCTION
1.1    There is a continuing need to raise staff awareness of their responsibility to
       safeguard public resources against the risk of fraud. The overall purpose of this
       statement, the Fraud Prevention Policy and Response Plan, is to detail
       responsibilities regarding the prevention of fraud and the procedures to be
       followed in the event of a fraud being detected or suspected. This document
       relates to fraud and loss within the Department and its Agencies (tailored as
       appropriate within each Agency to reflect their individual organisational structures
       and reporting lines). Reporting arrangements also apply to monies for which the
       Department is accountable but expended outside the Department. This includes
       the Special EU Programmes Body and the Superannuation and Other Allowances
       Resource Account.


1.2    The Department requires all staff, at all times, to act honestly and with integrity, and
       to safeguard the public resources for which they are responsible. Fraud is an ever-
       present threat to these resources and must be a concern to all members of staff.
       The Department will not tolerate any level of fraud or corruption; consequently,
       Departmental policy is to thoroughly investigate all suspected frauds and allegations
       (anonymous or otherwise) and where appropriate, refer to the police at the earliest
       juncture. The Department is also committed to ensuring that opportunities for fraud
       and corruption are reduced to the lowest possible level of risk.


1.3    Guidance on staff conduct regarding the acceptance of gifts, rewards and
       hospitality, and whistleblowing (Appendix 6) is included.




2.0    DEFINITION OF FRAUD
2.1    Fraud is the obtaining of financial advantage or causing of loss by implicit or explicit
       deception. It is the mechanism through which the fraudster gains unlawful
       advantage or cause unlawful loss.




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2.2    Fraud is not a victimless crime and is generally used to describe such acts as
       deception, bribery, forgery, extortion, corruption, theft, conspiracy, embezzlement,
       misappropriation, false representation, concealment of material facts and collusion.


2.3    Computer fraud is where information technology (IT) equipment has been used to
       manipulate computer programs or data dishonestly (for example by altering or
       substituting records, destroying or suppressing records, duplicating or creating
       spurious records), or where the existence of an IT system was a material factor in
       the perpetration of fraud (i.e. where the fraud was unlikely to have occurred if there
       had been no IT system). Theft or fraudulent use of computer facilities, computer
       programs and the Internet is included in this definition. The suspicion that any of
       these acts have taken place should be regarded as potentially fraudulent.


2.4    The Fraud Act 2006 came into effect on 15th January 2007. The Act states that a
       person is guilty of fraud if he is in breach of any of the following:

              Fraud by false representation, ie if he dishonestly makes a false
               representation and intends by making the representation to make a
               gain for himself or another, or to cause loss to another or expose
               another to risk of loss;

              Fraud by failing to disclose information, ie if he dishonestly fails to disclose to
               another person information which he is under a legal to duty to disclose and
               intends, by means of abuse of that position, to make a gain for himself or
               another, or to cause loss to another or expose another to risk of loss; and

              Fraud by abuse of position, ie if he occupies a position in which he is
               expected to safeguard, or not to act against, the financial interests of another
               person, and he dishonestly abuses that position, and intends, by means of
               the abuse of that position, to make a gain for himself or another, or to cause
               loss to another or to expose another to a risk of loss.




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3.0    DEPARTMENT’S RESPONSIBILITIES

3.1    The Department’s responsibilities are set out in Annex 4.7 of “Managing Public
       Money Northern Ireland” (MPMNI). All managers and staff should also make
       themselves familiar with various guidance contained on the Accountability and
       Accountancy Service Division (AASD) website: (www.aasdni.gov.uk). AASD also
       publish the NICS Annual Fraud Report and the minutes of the NICS Fraud Forum
       meetings.


3.2    The Department’s Accounting Officer is responsible for establishing and maintaining
       a sound system of internal control that supports the achievement of departmental
       policies, aims and objectives. The system of internal control is designed to respond
       to and manage the whole range of risks that a department 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 will be seen in the context of the management of
       this wider range of risks.


3.3    Overall responsibility for managing the risk of fraud has been delegated to the
       Director of Corporate Services Group (CSG). His responsibilities include:

       (a)     Developing a fraud risk profile and undertaking a regular review of the fraud
               risks associated with each of the key organisational objectives in order to
               keep the profile current;

       (b)     Establishing an effective anti-fraud policy and fraud response plan,
               commensurate to the level of fraud risk identified in the fraud risk profile;

       (c)     Designing an effective control environment to prevent fraud commensurate
               with the fraud risk profile;

       (d)     Operating appropriate pre-employment screening measures;

       (e)     Establishing appropriate mechanisms for:

                  Reporting fraud risk issues;

                  Reporting significant incidents of fraud to the Accounting Officer;




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                  Reporting to DFP and the Comptroller and Auditor General in accordance
                   with MPMNI Annex 4.7; and

                  Coordinating assurances about the effectiveness of fraud prevention
                   policy and fraud response plan      to support the Statement on Internal
                   Control;

       (f)     Liaising with the Departmental Audit and Risk Committee;

       (g)     Making sure that all staff are aware of the organisation’s anti-fraud policy and
               know what their responsibilities are in relation to combating fraud;

       (h)     Ensuring fraud awareness training is provided as appropriate and, if
               necessary, more specific anti-fraud training and development is provided to
               relevant staff;

       (i)     Ensuring that vigorous and prompt investigations are carried out if fraud
               occurs, is attempted or is suspected;

       (j)     Ensuring, where appropriate, legal and/or disciplinary action against
               perpetrators of fraud;

       (k)     Ensuring, where appropriate, disciplinary action against supervisors where
               supervisory failures have contributed to the commission of fraud;

       (l)     Ensuring, where appropriate, disciplinary action against staff who fail to
               report fraud;

       (m)     Taking appropriate action to recover assets and losses; and

       (n)     Ensuring that appropriate action is taken to minimise the risk of similar frauds
               occurring in future.




4.0    LINE MANAGER’S RESPONSIBILITIES

4.1    Line managers are responsible for ensuring that an adequate system of internal
       control exists within their areas of responsibility and that controls operate
       effectively. Responsibility for the prevention and detection of fraud, therefore, rests
       primarily with managers.




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4.2    A major element of good corporate governance is a sound assessment of the
       organisation’s business risks. Managers need to ensure that:

       (a)     Fraud risks have been identified within Risk and Control Frameworks
               encompassing all operations for which they are responsible;

       (b)     Each risk has been assessed for likelihood and potential impact;

       (c)     Adequate and effective controls have been identified for each risk;

       (d)     Controls are being complied with, through regular review and testing of
               control systems;

       (e)     Risks are reassessed as result of the introduction of new systems or
               amendments to existing systems;

       (f)     Where a fraud has occurred, or has been attempted, controls are reviewed
               and new controls implemented, as necessary, to reduce the risk of fraud
               recurring; and

       (g)     Fraud occurrences are quantified on an annual basis and Risk Registers/
               Risk and Control Frameworks updated to reflect the quantum of fraud within
               the Business Area.      Where appropriate, strategies should be devised to
               combat recurrence of fraud and targets set to reduce the level of fraud.


4.3    In terms of establishing and maintaining effective controls, it is generally desirable
       that:

       (a)     There is a regular rotation of staff, particularly in key posts;

       (b)     Wherever possible, there is a separation of duties so that control of a key
               function is not vested in one individual;

       (c)     Backlogs are not allowed to accumulate; and

       (d)     In designing any new system, consideration is given to building in safeguards
               to prevent and/or detect internal and external fraud.


4.4    As fraud prevention is the ultimate aim, anti-fraud measures should be considered
       and incorporated in every system and programme at the design stage, eg the
       design of application forms, the statement of accountability in respect of the content


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       in completed applications, regular monitoring of expenditure etc. Internal Audit is
       available to offer advice to managers on risk and control issues in respect of
       existing and developing systems/programmes.




5.0    INTERNAL AUDIT

5.1    Internal Audit is responsible for the provision of an independent and objective
       opinion to the Accounting Officer on risk management, control and governance.
       The adequacy of arrangements for managing the risk of fraud and ensuring the
       Department promotes an anti-fraud culture is a fundamental element in arriving at
       an overall opinion.


5.2    Internal Audit has no responsibility for the prevention or detection of fraud.
       However, internal auditors are alert in all their work to risks and exposures that
       could allow fraud.        Individual audit assignments, therefore, are planned and
       prioritised to assist in deterring and preventing fraud by examining and evaluating
       the effectiveness of control commensurate with the extent of the potential
       exposure/risk. Risk and Control Frameworks are also reviewed as a constituent
       part of each audit assignment to ensure that management have reviewed their risk
       exposures and, where appropriate, identified the possibility of fraud as a business
       risk.


6.0    STAFF RESPONSIBILITES

6.1    Every member of staff has a duty to ensure that public funds are safeguarded and
       therefore, everyone is responsible for:

       (a)     Acting with propriety in the use of official resources and the handling and use
               of public funds in all instances. This includes cash and/or payment systems,
               receipts and dealing with suppliers;

       (b)     Conducting themselves in accordance with the seven principles of public life
               detailed in the first report of the Nolan Committee ‘Standards in Public Life’,
               ie selflessness, integrity, objectivity, accountability, openness, honesty and
               leadership; and

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       (c)     Being vigilant to the possibility that unusual events or transactions could be
               indicators of fraud and alerting their line manager where they believe the
               opportunity for fraud exists (Appendix 1). Appendix 2 provides examples of
               Fraud Indicators. In addition, Common Methods and Types of Fraud are
               included in Appendix 3, with examples of Good Management Practices which
               may assist in combating fraud detailed in Appendix 4.


6.2    In addition, it is the responsibility of every member of staff to report details
       immediately to their line manager or the Departmental Establishment Officer (DEO)
       if they suspect that a fraud has been attempted or committed, or see any suspicious
       acts or events. The Public Interest Disclosure (NI) Order 1998 – see CSC 04/03
       Guidance on Public Interest Disclosure (‘whistleblowing’) – protects the rights of
       staff who report wrongdoing. As detailed in paragraph 9 of the Circular, if you are in
       any doubt, you should speak to a senior officer, or your DEO.                 A DFP
       Whistleblowing Policy has been developed and can be found on the DFP Intranet.


6.3    A description of the constitutional position of civil servants and the values they are
       expected to uphold is given in the NICS code of Ethics. (See NICS Staff Handbook
       – HRConnect Portal).


6.4    Advice is also available through the independent charity Public Concern at Work on
       020 7404 6609.         Their lawyers can give free confidential advice at any stage
       regarding a concern about serious malpractice at work.          An employee can, of
       course, also seek advice from a lawyer of their own choice, at their own expense.
       Additionally, a hotline facility is available on 0808 271 6100. The Hotline operates
       24/7 and all information received is treated in strictest confidence.


6.5    Section 5 of the Criminal Law Act (Northern Ireland) 1967 (Withholding Information)
       also places the onus on individuals to report/pass evidence to the Police. The
       involvement of the Police Service of Northern Ireland (PSNI) is dealt with in the
       Fraud Response Plan.




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6.6    Staff must also assist any investigations by making available all relevant
       information, by co-operating in interviews and if appropriate provide a witness
       statement.


6.7    As stewards of public funds, civil servants must have, and be seen to have, high
       standards of personal integrity. Staff should not accept gifts, hospitality or benefits
       of any kind from a third party, which might be seen to compromise their integrity.
       DAO 10/06 (revised September 2009) and the NICS Guidance on Offer and
       Acceptance of Gifts and Hospitality can be found in the DFP Document        Database,
       CSG, CSG - Departmental Personnel (see Appendix 8).




6.8    It is also essential that staff understand and adhere to laid down systems and
       procedures including those of a personnel/management nature such as submission
       of expenses claims and records of absence, flexi and annual leave.




7.0    FRAUD INVESTIGATION
7.1    Line managers should be alert to the possibility that unusual events or transactions
       can be symptoms of fraud or attempted fraud. Fraud may also be highlighted as a
       result of specific management checks or be brought to management’s attention by a
       third party. It is Departmental policy that there will be consistent handling of all
       suspected fraud cases without regard to position held or length of service.


7.2    Investigators should have free access to all staff, records and premises in order to
       carry out investigations. Irrespective of the source of suspicion, it is for the
       appropriate line management to undertake an initial examination to ascertain the
       facts (normally the Head of Branch) and to confirm or repudiate the suspicions,
       which have arisen so that, if necessary, further investigation may be instigated.
       After suspicion has been roused, prompt action is essential. However, as detailed
       in the Fraud Response Plan, It is imperative that such enquiries should not
       prejudice subsequent investigations or corrupt evidence, therefore,


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                              IF IN DOUBT, ASK FOR ADVICE.


7.3     A Service Level Agreement (Appendix 10) has been established with the
       Department of Agriculture and Rural Development (DARD) Central Investigation
       Service (CIS) for the completion of investigations in accordance with the
       requirements of the Police and Criminal Evidence (Northern Ireland) Order 1989.


7.4    If an initial examination confirms the suspicion that a fraud has been perpetrated or
       attempted, management should follow the procedures provided in the DFP Fraud
       Response Plan (Page 15).




8.0    CENTRAL INVESTIGATION SERVICE (CIS)


8.1    CIS is a counter fraud unit of experienced investigation staff within DARD. The CIS
       is located in rooms 118a – 121a Dundonald House, Belfast. Contact details are at
       Appendix 7.


8.2    The Service has five main Counter Fraud functions:


          It provides specialist investigative services to the Department for the
           investigation of cases of suspected internal and external fraud. All
           investigations conducted by the CIS are carried out in strict compliance with
           relevant law and procedure. The team of experienced staff are fully trained to
           conduct investigations so that they act as a deterrent and prevent others from
           committing fraud by uncovering quality evidence that will ensure that legal
           proceedings and/or disciplinary charges can be taken, resulting in more certain
           and severe penalties;


          The CIS has responsibility for coordinating the effective delivery of the DARD
           Counter Fraud Strategy and is responsible for implementing many of the targets
           contained within the Strategy;



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          The Service has a vital role in deterring and preventing fraud by enhancing fraud
           awareness and promoting a culture of anti-fraud consciousness across the
           Department, its Agencies and NDPBs. The Service has developed and delivers
           a range of fraud awareness training programmes, publicity campaigns and other
           promotional activity; and


          The CIS has responsibility for consultations on behalf of the Department with the
           Police Service of Northern Ireland PSNI.


          The CIS is available to offer advice and assistance on all matters relating to
           fraud.




9.0    DFP FRAUD WORKING GROUP

9.1    The Department of Finance and Personnel (DFP) has established a Fraud Working
       Group to provide a strategic overview of counter fraud activities within the
       Department and its Agencies. In particular the Group has the following ambit:

          Monitor and review, and disseminate as necessary, outputs of the NICS Fraud
           Forum;
          Coordinate the work being done in the Department on tackling fraud and provide
           a forum for the exchange of information/sharing of experience for mutual benefit;
          Periodically review the DFP Fraud Policy and Fraud Response Plan for
           relevance and currency;
          Identify Departmental training needs and assist in the coordination of training to
           meet needs;
          Share best practice and examples of anti-fraud measures and procedures; and
          Monitor trends/occurrences of fraud both within and outside the Department and
           disseminate, as necessary, lessons learned.


9.2    The Group is chaired by the DFP Finance Director and is attended by the Head of
       Fraud and Internal Audit Policy Unit and the Head of Internal Audit. The


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       membership of the Group includes a representative from each of DFP’s
       Directorates and Agencies, a representative from the NIAO and DARD Central
       Investigation Service. The DFP representative on the NICS Fraud Forum will
       also have membership to facilitate dissemination of information from the Fraud
       Forum and provide a conduit for feedback. Membership is flexible and may
       include other interested parties as the occasion demands.


9.3    The Fraud Working Group meets at least twice per year and is scheduled to follow
       the NICS Fraud Forum meetings. The Group provides reports to the Departmental
       Audit and Risk Committee to advise of progress and completed actions.




10.0   FRAUD RISK ASSESSMENTS

10.1   A major element of good corporate governance is a sound assessment of the
       organisation’s business risks. The key to managing the risk of fraud is the same in
       principle as managing any other business risk and should be approached
       systematically at both the organisational and the operational level. The assessment
       of risk should be part of a continuous cycle rather than a one-off event: as systems
       and the environment change, so do the risks to which departments will be exposed.
       Figure below sets out the key stages of a risk management cycle to help deal with
       fraud. Please see Appendix 9 - Guidance on Performing an Assessment of Fraud
       Risks




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                              RISK ASSESSMENT CYCLE




                                Identify risk
                                   areas




         Evaluate
                                                        Assess scale of
     effectiveness of
                                                             risk
         controls




         Monitor                                      Allocate responsibility
    implementation of                                         for risk
         controls




   Implement revised                                    Identify need for
        controls                                        revised controls




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11.0   DISCIPLINARY ACTION

11.1   After full investigation the Department will take legal and/or disciplinary action in all
       cases where it is considered appropriate. Any member of staff found guilty of a
       criminal act will be considered to have committed a serious disciplinary offence and
       is likely to be dismissed from the Department on the grounds of gross misconduct.


11.2   Where supervisory negligence is found to be a contributory factor, disciplinary
       action may also be initiated against those managers/supervisors responsible.


11.3   It is Departmental policy that in all cases of fraud, whether perpetrated or attempted
       by a member of staff or by external organisations or persons, the case will be
       referred to the PSNI at the earliest possible juncture.


11.4   Losses resulting from fraud should be recovered, subject to the policy on write-offs,
       if necessary through civil action.




12.0   MALICIOUS ALLEGATIONS

12.1   If an allegation is made frivolously, in bad faith, maliciously or for personal gain,
       disciplinary action may be taken against the person making the allegation.




13.0   CONCLUSION

13.1   It is appreciated that the circumstances of individual frauds will vary.            The
       Department takes fraud very seriously and will ensure that all cases of actual or
       suspected fraud, including attempted fraud, are vigorously and promptly
       investigated and that appropriate remedial action is taken. Managers should be
       fully aware of their responsibility to protect public funds and as such, should always
       be alert to the potential for fraud.


13.2   Any queries in connection with this policy document should be directed to the
       Departmental Establishment Officer.

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       Internal Audit is available to offer advice and assistance on risk management/
       internal control issues.


13.3. Current contact details are provided in Appendix 7.




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               DEPARTMENT OF FINANCE AND PERSONNEL

                               FRAUD RESPONSE PLAN
       Introduction

1.     The Department has prepared this Fraud Response Plan to act as a procedural
       guide and provide a checklist of the required actions, which MUST be followed, in
       the event of a fraud, attempted fraud or irregular activity being suspected.


2.     Adherence to the Fraud Response Plan will enable the Department and its
       Agencies to:


              Take timely and effective action to prevent further losses: and
              Help to recover losses;
              Establish and secure evidence necessary for possible criminal and
               disciplinary action;
              Notify DFP and NIAO of such instances as per Managing Public Money and;
              Highlight areas of weakness in the operating systems to prevent future
               losses.


3.     The overarching theme of this plan is


                              ‘IF IN DOUBT, ASK FOR ADVICE’.


       This applies at any point in an investigation. Details of contacts are provided in
       paragraphs 17, 20 and 21 below.


4.     A Service Level Agreement (SLA) has been agreed with the Department of
       Agriculture and Rural Development (DARD) Central Investigation Service (CIS).
       This will ensure the completion of investigations in accordance with the
       requirements of the Police and Criminal Evidence (Northern Ireland) Order 1989.
       The SLA is attached at Appendix 10. Full details of roles and responsibilities are
       contained in the document.


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5.     A Memorandum of Understanding (MoU) has also been agreed with the Police
       Service of Northern Ireland (PSNI) Fraud Unit, Strandtown for the Public Sector.
       The MoU provides a basic framework for the working relationships between the NI
       Public Sector and the PSNI in respect of the investigation and prosecution of
       suspected fraud cases and is attached at Appendix 11.


       Preliminary Stage (the chart contained in Appendix 1 refers)

6.     In the event of a fraud, attempted fraud or other illegal act being suspected, the
       officer should immediately report the matter to their line manager/Head of Branch.
       If there is concern that line management may be involved, the matter should be
       reported to the next appropriate level. Additionally, the Departmental Establishment
       Officer (DEO), Mr Ryan Dobson, should be contacted.          Where confidentiality is
       sought, staff may report their suspicions direct to the CIS through the Hotline,
       (telephone no 08000 271 6100 or on-line via the internet, www.dardni.gov.uk.
       The Hotline operates 24/7 and all information received is treated in strictest
       confidence.


7.     It is for line management to undertake an initial fact-finding exercise. This discreet
       preliminary enquiry should be carried out as speedily as possible and certainly
       within 24 hours of the suspicion being raised.


8.     The purpose of the initial fact-finding exercise is to determine the factors that gave
       rise to suspicion and to clarify whether a genuine mistake has been made or if it is
       likely that a fraud has been attempted or occurred.       This may involve discreet
       enquiries with staff or the examination of documents. It is imperative that such
       enquiries should not prejudice subsequent investigations or corrupt
       evidence, therefore,


                              IF IN DOUBT, ASK FOR ADVICE.


       The Head CIS or Head of Internal Audit can be contacted for advice on how to
       correctly proceed at the preliminarily enquiry stage and on what further enquiries
       are necessary. Appendix 7 contains contact details.

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9.     If the preliminary enquiry confirms that a fraud has not been attempted nor
       perpetrated but internal controls were deficient, management should review their
       control systems with a view to ensuring they are adequate and effective. A robust
       review of the Branch/Divisional Risk and Control Framework should be conducted
       and where appropriate the Directorate/Agency/Corporate Risk Register should also
       be reviewed. Internal Audit is available to offer advice and assistance on matters
       relating to internal control, if required.


       Formal Reporting Stage

10.    If the preliminary enquiry confirms the suspicion that a fraud has been
       attempted     or    perpetrated,    management           must   ensure    that   all   original
       documentation is preserved in a safe place for further investigation. This is to
       prevent the loss of evidence, which may be essential to support subsequent
       disciplinary action or prosecution. The facts should be reported immediately to
       the Head of Division, Head of Branch concerned, the DEO and the Head of Internal
       Audit. The Head of Accounting and Accountability Branch (AAB) should also be
       notified to allow compliance with reporting arrangements (paragraphs 17 to 19
       below refer), in particular to the Comptroller and Auditor General and to Fraud
       and Internal Audit Policy Unit, DFP.


11.    To remove any threat of further fraud or loss, management should immediately
       change/strengthen procedures and if appropriate, suspend any further payments
       pending full investigation.        Where the fraud has been perpetrated externally
       management         should   consider     the      need    to    inform   other   government
       Departments/Bodies.


12.    The DEO will decide on the appropriate course of action including the full formal
       investigation arrangements. The scope of the investigation should be determined
       by DARD CIS, in line with the terms of the SLA. Should DARD CIS advise that
       further expertise is required, eg Solicitors, Forensic Accountants/Engineers, the
       DEO will engage the appropriate assistance.



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13.    Reporting arrangements also apply to monies for which the Department is
       accountable but expended outside the Department. This includes the Special EU
       Programmes Body Account and the Superannuation and Other Allowances
       Resource Account.


       Liaison with the Police Service of Northern Ireland

14.    The DEO should ensure that legal and/or police advice is sought where necessary.
       DARD CIS, on behalf of the DEO, will lead on liaisons with the Police Service of
       Northern Ireland Fraud Unit, based at Strandtown PSNI Station, Belfast, in line with
       the agreed terms contained in the MOU. PSNI is available to give advice and/or
       guidance in cases where fraud is suspected (contact details are available in the
       Annex B of the MoU; Appendix 11 refers). Where actual or attempted fraud is
       confirmed and is of a large or complex nature, the Fraud Squad is capable of
       carrying out investigations. Smaller cases may be referred to the local police.


       Post Event Action

15.    Where a fraud, or attempted fraud, has occurred, management must make any
       necessary changes to systems and procedures to ensure that similar frauds or
       attempted frauds will not recur.       Additionally, if a Departmental employee is
       suspected of involvement, the DEO will consider the appropriate course of action.
       This may range from close monitoring/supervision to precautionary suspension,
       however, it should be noted that suspension does not in any way imply guilt.
       Paragraphs 11 and 12 of the DFP Fraud Prevention Policy also refer.


16.    Internal Audit is available to offer advice and assistance on matters relating to
       internal control, if considered appropriate.


       Communication

17.    The following communications should be observed in all cases:
          The Departmental Audit and Risk Committee should be kept informed of
           developments during the investigation;
          A lessons-learned document should be circulated throughout the Department, if
           appropriate;

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          This Departmental Fraud Response Plan should be reviewed to determine
           whether it needs to be updated and if so, changes should be circulated
           throughout the organisation;
          Consideration should be given to informing other public sector organisations, eg
           other Government Departments, NIAO, grant paying organisations; and
          At the appropriate time, inform the DFP Fraud Working Group and the NICS
           Fraud Forum of outcomes and lessons learned.


       Reporting Arrangements

18.    The Head of Accounting and Accountability Branch (AAB) is responsible for
       notifications to Fraud and Internal Audit Policy (FIAP, DFP) and the Comptroller
       and Auditor General about all discovered fraud, proven or suspected, including
       attempted fraud, within or against the Department, its Agencies and NDPBs. This
       arrangement extends to frauds (proven or suspected) including attempted fraud in
       organisations/companies supported with public funds from Voluntary Bodies and
       other agents such as Intermediary Funding Bodies/third party organisations funded
       by the Department. Therefore, the Head of AAB should be notified immediately of
       all such frauds.


19.    Additionally, the Head of AAB will complete the annual fraud return to Fraud and
       Internal Audit Policy (FIAP) (by the end of May each year). Annex 4.7 of Managing
       Public Money Northern Ireland (MPMNI) defines requirements.


20.    Also, the Head of AAB will ensure that relevant parties are apprised of progress
       regarding the completion of the investigation. Care will be taken in making such
       reports that potential future legal proceedings are not jeopardised.


       Conclusion

21.    Any queries in connection with this response plan should be made to the DEO.


22.    Advice and assistance on risk management/internal control issues can be sought
       from the Head of Internal Audit.



Fraud Hotline 0808 271 6100
                                             21
23.    Current contact details for officers referred to above are provided in Appendix 7.




       STEPHEN PEOVER
       Permanent Secretary




Fraud Hotline 0808 271 6100
                                             22
                                                                                            Appendix 1

                                Reporting Fraud/Suspected Fraud

                                     You suspect a fraud, attempted fraud or other
                                   illegal act by an employee of the Department or
                                      an external organisation/person against the
  It is imperative that such
                                                      Department.
     enquiries should not
    prejudice subsequent
  investigations or corrupt
  evidence, therefore, IF IN         * Report to line management/Head of Branch         Preliminary
 DOUBT, ASK FOR ADVICE                  who will undertake an initial fact-finding
                                                                                          Stage
                                    exercise to determine whether it is likely that a
                                    fraud has occurred. Notify the Departmental
                                                Establishment Officer.


 No case to answer – Review
     internal controls, as
                                                          Either/or
         appropriate.




                                      Suspicions appear well grounded – Confirm
                                        with the Departmental Establishment
 Head of AAB notifies Head            Officer and notify Head of Accounting and
of Internal Audit, Fraud and                Accountability Branch (AAB).
  Internal Audit Policy and
the Comptroller and Auditor
           General.                  Ensure all original documentation is preserved
                                          in a safe place and update Head of
                                              Branch/Division immediately.


                                                                                            Formal
                                       Head of Branch/Division takes action to end        Reporting
                                      loss and correct any weakness in controls or
                                                                                             Stage
                                                      supervision.

                                     DEO to initiate and oversee full investigation –
                                    investigation to be conducted by DARD Central
                                      Investigation Service, who are appropriately
                                           trained in investigative techniques.




  * If you are concerned that line management may be involved in the suspected
  fraud, you should report it to the next appropriate level, ie Head of Branch, Head of
  Division, Director. Alternatively, at any stage in the process, you can contact the
  DEO, Head of AAB or Head of Internal Audit for advice.




  Fraud Hotline 0808 271 6100
                                                     23
                                                                                           Appendix 2




                                       Indicators of Fraud


      Missing     expenditure      vouchers   and       Offices with excessively flamboyant
       unavailable official records                       characteristics
      Crisis management coupled with a                  Employees          suffering        financial
       pressured business climate                         hardships
      Profitability declining                           Placing undated/post-dated personal
      Excessive variations to budgets or                 cheques in petty cash
       contracts                                         Employees apparently living beyond
      Refusals to produce files, minutes or              their means
       other records                                     Heavy gambling debts
      Related party transactions                        Signs of drinking or drug abuse
      Increased employee absences                        problems
      Borrowing from fellow employees                   Conflicts of interest
      An easily led personality                         Lowest tenders or quotes passed
      Covering up inefficiencies                         over       with    scant        explanations
      Lack of Board oversight                            recorded
      No supervision                                    Employees         with     an     apparently
      Staff turnover is excessive                        excessive work situation for their

      Figures, trends or results which do not            position

       accord with expectations                          Managers bypassing subordinates

      Bank reconciliations are not maintained           Subordinates bypassing managers
       or can’t be balanced                              Excessive generosity
      Excessive movement of cash funds                  Large sums of unclaimed money
      Multiple cash collection points                   Large sums held in petty cash
      Remote locations                                  Lack of clear financial delegations
      Unauthorised changes to systems or                Secretiveness
       work practices                                    Apparent personal problems
      Employees       with      outside   business      Marked character changes
       interests or other jobs                           Excessive ambition
      Large outstanding bad or doubtful debts           Apparent lack of ambition


Fraud Hotline 0808 271 6100
                                                24
                                                                                  Appendix 2

                              Indicators of Fraud (Continued)

      Poor morale                                    Unwarranted organisation structure
      Excessive control of all records by one        Absence of controls and audit trails.
       officer                                        Socialising with clients – meals,
      Poor security checking processes over           drinks, holidays
       staff being hired                              Seeking work for clients
      Unusual working hours on a regular             Favourable treatment of clients – eg
       basis                                           allocation of work
      Refusal to comply with normal rules and        Altering contract specifications
       practices                                      Contract        not   completed      to
      Personal creditors appearing at the             specification
       workplace                                      Contractor paid for work not done.
      Non taking of leave                            Grants not used for specified purpose
      Excessive overtime                              – eg Leasing capital equipment
      Large backlogs in high risk areas               instead of purchasing them
      Lost assets


   Corporate Fraud
      Lack of thorough investigations of alleged wrongdoing
      Pecuniary gain to organisation – but no personal gain




Fraud Hotline 0808 271 6100
                                            25
                                                                                        Appendix 3

                              Common Methods and Types of Fraud


      Payment for work not performed                    False official identification used
      Forged endorsements                               Damaging/destroying documentation
      Altering    amounts       and   details   on      Using copies of records and receipts
       documents                                         Using      imaging      and      desktop
      Collusive bidding                                  publishing technology to produce
      Overcharging                                       apparent original invoices
      Writing off recoverable assets or debts           Charging    incorrect   amounts      with
      Unauthorised transactions                          amounts stolen
      Selling information                               Transferring      amounts       between
      Altering stock records                             accounts frequently

      Altering sales records                            Delayed terminations from payroll
      Cheques made out to false persons                 Bribes
      False persons on payroll                          Over claiming expenses
      Theft of official purchasing authorities          Skimming odd pence and rounding
       such as order books                               Running a private business with
      Unrecorded transactions                            official assets
      Transactions                                      Using facsimile signatures
       (expenditure/receipts/deposits) recorded          False compensation and insurance
       for incorrect sums                                 claims
      Cash stolen                                       Stealing of discounts
      Supplies not recorded at all                      Selling waste and scrap.
      Stolen equipment and supplies




Fraud Hotline 0808 271 6100
                                                 26
                                                                                    Appendix 4



    Examples of Good Management Practices Which May Assist in Combating Fraud


    All income is promptly entered in the accounting records with the immediate
     endorsement of all cheques
    Regulations governing contracts and the supply of goods and services are properly
     enforced
    Accounting records provide a reliable basis for the preparation of financial statements
    Controls operate which ensure that errors and irregularities become apparent during
     the processing of accounting information
    A strong internal audit presence
    Management encourages sound working practices
    All assets are properly recorded and provision is made known for expected losses
    Accounting instructions and financial regulations are available to all staff and are kept
     up to date
    Effective segregation of duties exists, particularly in financial accounting and
     cash/securities handling areas
    Close relatives do not work together, particularly in financial, accounting and
     cash/securities handling areas
    Creation of an agency climate to promote ethical behaviour
    Act immediately on internal/external auditor’s report to rectify control weaknesses
    Review, where possible, the financial risks of employees
    Issue accounts payable promptly and follow-up any non-payments
    Set standards of conduct for suppliers and contractors
    Maintain effective security of physical assets; accountable documents (such as cheque
     books, order books); information, payment and purchasing systems
    Review large and unusual payments
    Perpetrators should be suspended from duties pending investigation
    Proven perpetrators should be dismissed without a reference and prosecuted
    Query mutilation of cheque stubs or cancelled cheques
    Store cheque stubs in numerical order
    Undertake test checks and institute confirmation procedures



Fraud Hotline 0808 271 6100
                                                27
                                                                                     Appendix 4

    Examples of Good Management Practices Which May Assist in Combating Fraud
                                          (Continued)


    Develop well defined procedures for reporting fraud, investigating fraud and dealing
     with perpetrators
    Maintain good physical security of all premises
    Randomly change security locks and rotate shifts at times (if feasible and economical)
    Conduct regular staff appraisals
    Review work practices open to collusion or manipulation
    Develop and routinely review and reset data processing controls
    Regularly review accounting and administrative controls
    Set achievable targets and budgets, and stringently review results
    Ensure staff take regular leave
    Rotate staff
    Ensure all expenditure is authorised
    Conduct periodic analytical reviews to highlight variations to norms
    Take swift and decisive action on all fraud situations
    Ensure staff are fully aware of their rights and obligations in all matters concerned with
     fraud




Fraud Hotline 0808 271 6100
                                               28
                                                                                    Appendix 5

            Best Practice for Reporting Suspicions of Fraud and irregularity


If staff become aware of a suspected fraud or irregularity, write down the concerns
immediately. Make a note of all relevant details, such as what was said in phone or other
conversations, the date, the time and the names of anyone involved. It may necessary to
handover any notes and/or evidence you have gathered to the appropriate investigator.


STAFF MUST NOT DO ANY OF THE FOLLOWING:
      Contact the suspected perpetrator in an effort to determine the facts.
      Discuss the case facts, suspicions, or allegations with anyone outside the
       Department.
      Discuss the case with anyone within the department other than the people detailed
       in the policy and response plan.
      Attempt to personally conduct investigations or interviews or question anyone.


                                   Action by Managers


If Line Management have reason to suspect fraud or corruption in the work area, they
should:
      Listen to the concerns of your staff and treat every report received seriously and
       sensitively;
      Make sure that all staff concerns are given a fair hearing. Line Management should
       also reassure staff that they will not suffer because they have told you of the
       suspicions;
      Get as much information as possible from the member of staff, including any notes
       and any evidence they have that may support the allegation. Do no interfere with
       any evidence and make sure it is kept in safe place; and
      Do not try to carry out an investigation yourself; this may damage any criminal
       enquiry. Seek advice from Head of Central Investigation Service and Head of
       Internal Audit before taking any action.


Report the matter immediately to Line Management, the Head of Central Investigation
Service and/or Head of Internal Audit.


Fraud Hotline 0808 271 6100
                                              29
                                                                                      Appendix 6


                      Whistleblowing arrangements in DFP


All of us at some point may have concerns about what is happening at work. However,

when it is about unlawful conduct, a possible fraud or a danger to the public or the

environment, or other serious malpractice, it can be difficult to know what to do.

You may have worried about raising such a concern and may have though it best to keep

it to yourself, perhaps feeling it was none of your business or that it is only a suspicion.



You may have felt that raising the matter would be disloyal to colleagues, managers or to

DFP. You may have decided to say something but found that you have spoken to the

wrong person or raised the issue in the wrong way and were not sure what to do next.

DFP has now put in place Whistleblowing arrangements to reassure you that it is safe and

acceptable to speak up. They also enable you to raise any concern about malpractice at

an early stage and in the right way. If something is troubling you which you think we should

know about or look into, these arrangements set out the steps you should take and identify

the key contacts, and our assurances to you.

We are committed to making whistleblowing work. If you raise a genuine concern under

these arrangements, you will not be at risk of losing your job or suffering any form of

retribution as a result. Provided you are acting in good faith, it does not matter if you are

mistaken.

While we cannot guarantee that we will respond to all matters in the way that you might

wish, we will strive to handle the matter fairly and properly. By using these whistleblowing

arrangements you will help us to achieve this.

A copy of the Department's Whistleblowing Arrangements is now available on the Intranet.



If you have any queries on whistleblowing, please contact Colin Evans on extension 69033

Fraud Hotline 0808 271 6100
                                               30
                                                                                   Appendix 7

                                          Contact Details



         Name                                  Designation                   Telephone Number



Mr Ryan Dobson                Departmental Establishment Officer (DEO)       9185 8146 (x68146)




Mrs Kathryn Hill
                              Head of Accounting and Accountability Branch   9185 8052 (x68052)
Miss Brigitte Worth




Mr Michael Matthews           Head of Internal Audit                         9052 6072 (x26072)




Mr Thomas McCauley            Head of DARD Central Investigation Service     9052 4084 (x24084)




                              Senior Investigator, DARD Central
Mr Karl Oakman                                                               9052 5096 (x25096)
                              Investigation Service




Fraud Hotline 0808 271 6100
                                                 31
                                                                   Appendix 8

Treasury Officer of Accounts
David Thomson

Central Finance Group
Rathgael House
Balloo Road
BANGOR BT19 7NA
Tel No: 028 9185 8150 (x 68150)
email: david.thomson@dfpni.gov.uk
and    jill.downie@dfpni.gov.uk



                                                        DAO (DFP) 10/06

(Revised September 2009)                                10 August 2006




Dear Accounting Officer


ACCEPTANCE AND PROVISION OF GIFTS AND HOSPITALITY


Purpose


1.    The purpose of this DAO is to update the guidance on the acceptance
      and provision of gifts and hospitality issued under cover of DAO (DFP)
      14/05. To avoid confusion, DAO (DFP) 14/05 is hereby cancelled.




Provision of gifts/hospitality


2.    The principles previously set out in DAO (DFP) 14/05, for the provision
      of gifts and hospitality by the department remain unchanged and are
      reissued at Appendix 1. The requirement that departments review their
      guidelines to ensure that they remain ‘fit for purpose’ remains.




DF1/09/324021
                                                                      Appendix 8


Acceptance of gifts/hospitality


3.    Departmental guidance based on general principles as set out in
      DAO (DFP) 14/05 has led to some inconsistencies and it is therefore
      considered appropriate to apply a common NICS wide set of guidelines
      on the acceptance of gifts and hospitality.



4.    The latest NICS personnel policy on the acceptance of gifts and
      hospitality by staff is set out at sections 1.9 and 1.10 of the Conduct
      Chapter of the NICS Staff handbook and is reflected in the new NICS-
      wide guidance prepared by Central Personnel Group which is attached
      at Appendix 2. In particular it sets out:


         guidance      on    roles   and     responsibilities   at     all     levels


         guidance on the maintenance of gifts and hospitality registers,
          including registers for SCS Members and each Division


         guidance      on    the     publication    of   hospitality         registers


         guidance on the reporting and approval process to be followed


         monitoring arrangements


         standard forms to be used to record offers of gifts/hospitality and
          update hospitality registers


         rules to be applied in specific circumstances


         a summary checklist covering the various types of hospitality, the
          approvals required and cross references to the relevant part of the
          guidance


DF1/09/324021
                                                                  Appendix 8



      Action


5.     Departments and agencies should:


        adopt the NICS guidance prepared by DFP’s Central Personnel
          Group on the acceptance of gifts and hospitality with immediate
          effect (see appendix 2). This should replace any existing guidance
          currently used by departments/agencies.


        ensure that their guidance on the provision of gifts and
          hospitality remains ‘fit for purpose’. (Note: there is no requirement
          to change existing guidance as long as it is deemed to be ‘fit for
          purpose’).


      Sponsored bodies


6.     Departmental Accounting Officers should ensure that guidance on the
       acceptance of gifts and hospitality, with appropriate adjustments if
       necessary, is in place in their sponsored bodies.           Appropriate
       adjustments refers only to the distinct reporting, approval and
       monitoring arrangements relevant to a sponsored body, and not the
       rules and principles applicable. Guidance on the provision of gifts and
       hospitality should already be in place in each sponsored body.


     Revision to Guidance


7.     Departments, agencies and sponsored bodies should ensure that their
       practices reflect any agreed NICS guidance updates prepared by
       Central Personnel Group in relation to the acceptance of gifts and
       hospitality. They should also periodically review their guidance on the
       provision of gifts and hospitality to ensure that it remains ‘fit for
       purpose’.


DF1/09/324021
                                                                Appendix 8



 Queries


8.    Any queries on the content of the guidance on the acceptance of gifts
      and hospitality should be directed to Barry Mulligan in Corporate HR
      Tel         02890     572349        (network       83349)       email
      (barry.mulligan@dfpni.gov.uk). Any queries on the content of the
      guidance on the provision of gifts and hospitality should be addressed
      to Jim Drennan in Central Finance Group, Tel 028 91277687 (network
      69087), email (jim.drennan@dfpni.gov.uk).


Yours sincerely




DAVID THOMSON




                                                            APPENDIX 1



DF1/09/324021
                                                                     Appendix 8


THE PROVISION OF GIFTS AND HOSPITALITY BY THE
    DEPARTMENT



General Principles
           As with all public expenditure, hospitality expenditure should
            be value for money and incurred in accordance with the
            principles of regularity and propriety.


           Any hospitality offered should further the Government or
            taxpayers interest and involve no reasonable suspicion that
            personal judgement or integrity had been compromised (i.e. a
            common sense test).


           Consideration should be given to the central importance of
            propriety and correctness in line with Nolan principles.



Departmental guidance should at least cover:

         A list of groups to whom the Department might provide
          entertainment/ hospitality or gifts.


         Potentially a range of circumstances in which expenditure on
          hospitality might be expected to arise within the Department.


         Gifts (consider delegations to particular offices e.g. international
          duty).


         Quality and extent of any official entertainment, hospitality or gifts
          being provided should depend on the status and numbers of those
          being provided for.




DF1/09/324021
                                                                   Appendix 8


         Particular caution should be exercised when hospitality is provided
          largely for departmental staff.
         Set out clearly when prior approval by Director or other Senior
          Officer is required.

         Delegations below Director level and relevant DFP Supply approval
          limits.

         Distinction between minor catering and major catering may be
          relevant.

         Official hospitality should be contained within approved budgets.

         Staff should not use public resources for personal benefit.




DF1/09/324021
                                          Appendix 8


                                        APPENDIX 2




         NORTHERN IRELAND CIVIL
               SERVICE



  GUIDANCE ON OFFERS AND THE
        ACCEPTANCE OF

                GIFTS AND HOSPITALITY




DF1/09/324021
                                                                    Appendix 8


GUIDANCE ON OFFERS AND THE ACCEPTANCE OF GIFTS AND
HOSPITALITY




Introduction

Section 1


1.1   The Northern Ireland Civil Service (NICS) recognises that contractors
      and other customers of our services may extend from time to time
      offers of gifts and hospitality to staff. The NICS also recognises that its
      employees have a responsibility, in the interests of public confidence, to
      exhibit high standards of propriety, and carry out their role with
      dedication and a commitment to the Civil Service and its core values:
      integrity, honesty, objectivity and impartiality.


1.2   Section 2 of this guidance sets out the principles governing the
      acceptance of gifts and hospitality by staff and provides some specific
      advice on how these principles should be interpreted across the
      NICS. The guidance is designed to remind staff of their responsibility
      to exercise judgement and propriety regarding offers of gifts and
      hospitality.   The guidance is effective immediately but will be
      subject to review when required.


1.3   The NICS Staff Handbook indicates that civil servants should conduct
      themselves with honesty and impartiality in the exercise of their
      duties. As a consequence, they should never receive benefits of any
      kind from a third party which might reasonably be thought to
      compromise their personal judgement or integrity. In this field,
      perception is as important as reality.


1.4   The fundamental principle is that no member of staff should do
      anything which might give rise to the impression that he or she


DF1/09/324021
                                                                    Appendix 8


      has been or might be influenced by a gift or hospitality or other
      consideration to show bias for or against any person or
      organisation while carrying out official duties.


1.5   Section 3 of this guidance sets out the monitoring arrangements that
      departments must put in place to ensure that the arrangements are
      operating effectively and that they can be seen to be operating
      effectively.


Section 2


2.1   This guidance sets out good practice concerning the acceptance or
      rejection of gifts or hospitality, and details responsibilities and
      procedures for the authorisation and recording of such instances. As
      Civil Servants our standards of conduct are determined by what the
      Government and the public as taxpayers expect and not by what may
      be a common practice in the private sector.


2.2   External people acting on behalf of the NICS (for example, consultants,
      contracted staff etc) must also abide by the policy. If it is believed that
      an external person may have breached the policy, the matter should be
      reported to the Head of Division or more senior manager, who will take
      the matter forward with the individual or his/her company.            This
      requirement should be notified to external staff before they start
      work within any NICS Department or Agency.


2.3   This guidance should also be seen as applying to spouses, partners
      or other associates if it can be argued or perceived that the gift or
      hospitality is in fact for the benefit of the official.


2.4   Any breach of the rules of conduct can lead to disciplinary
      action and in some circumstances can be a criminal offence.

2.5   The policy governing the acceptance of gifts, hospitality and awards by

DF1/09/324021
                                                                                                  Appendix 8

  Northern Ireland Civil Servants is set out in Sections 1.9 and 1.10 of the Conduct Chapter of the NICS Staff
  Handbook



      This Guidance focuses on the key issues and the specific rules, which all
staff in the NICS should adopt.

         Legal Obligations and Fundamental Principles


2.7      Under the Prevention of Corruption Acts of 1906 and 1916 it
         is an offence for an officer in his/her official capacity:


            to corruptly accept any gift or consideration as an inducement or
             reward for doing, or refraining from doing, anything in that capacity;
             or
            to show favour or disfavour to any person; or
            to receive money, gifts or consideration from a person or
             organisation holding or seeking to obtain a Government contract.


         All of these are deemed by the Courts to have been received corruptly
         unless it is proven otherwise.


Record of gifts, hospitality, invitations, etc


2.8      Departments will maintain Registers of Gifts, Hospitality and
         Awards which will be available for periodic review. The purpose of the
         Registers will be to counter any possible accusations or suspicions of
         breach of the rules of conduct by staff. The registers are subject to
         Freedom of Information (FOI) queries. A template is attached at
         Annex A that should be used to register gifts, hospitality, invitations
         etc.


2.9      It will be the responsibility of each Department to ensure all
         staff are made aware of this guidance and that registers are
         in place and properly maintained and updated.                                         To facilitate

DF1/09/324021
                                                            Appendix 8


      the monitoring arrangements at paragraph 3.1 Departments
      should maintain a register for each Division and a separate
      register for senior civil service.


Publication of Hospitality Registers on Websites


2.10 It is recommended good FOI practice for departments to
   produce “disclosure logs” of gifts and hospitality, although it is
   not mandatory for them to do so. Departments should therefore
   as a minimum, publish gifts and hospitality information for SCS
   staff and note on their websites that records are also kept for
   staff at all other grades Such logs can be published and placed
   on websites at fixed points in the year – for example at the end
   of each financial year (or more frequently if appropriate) – and
   can be a valuable alternative to responding to ad hoc FOI
   requests about gifts and hospitality matters.      .   Departments
   would still have to respond to such ad hoc FOI requests if they
   referred to groups of staff or individuals falling outside those
   included in a department’s disclosure log.      Departments may,
   however, decide to publish the registers for staff at all grades.


Acceptance of Gifts


2.11 The general principle is that all gifts offered should be
   refused. However seasonal, promotional or trivial gifts (such as
   calendars, diaries, pens etc), which bear Company names
   and/or logos of the provider of the gift and have a value of less
   than £50, may be accepted by individuals without the need for
   these to be reported or approved in advance. A token gift may

DF1/09/324021
                                                                    Appendix 8


   be accepted if it is presented by an organisation, however,
   these and the acceptance of any other gifts must have been
   approved by management (see paragraph 2.17) and must be
   declared by the member of staff in their Departmental/Agency
   register


2.12   More expensive or substantial items, valued at £50 or more and gifts
       of lottery tickets, cash, gift vouchers or gift cheques, cannot on any
       account be accepted.        All gifts offered (apart from those which are
       trivial or inexpensive), even if they are declined/returned need to be
       recorded in the register.


Trade, loyalty or Discount Cards


2.13   Trade, loyalty or discount cards by which an officer might personally
       benefit from the purchase of goods or services at a reduced price are
       classified as gifts and should be refused or returned to sender.


2.14   Frequent flyer cards used by airlines can be used by staff to avail of
       special departure lounges and priority booking and check-in.        They
       must NOT make private use of any flights/air miles, which derive
       from flights paid for from the public purse.




Staff involved in the procurement or monitoring of a contract


2.15   Apart from trivial / inexpensive seasonal gifts, such as diaries, no gifts
       or hospitality of ANY kind from any source should be accepted by
       anyone involved in the procurement or monitoring of a contract. This
       will ensure that no criticism can be made regarding bias to a particular
       company or supplier.



DF1/09/324021
                                                                         Appendix 8


Gifts received in recognition of work done


2.16 On no account should a gift or gratuity be solicited or
      requested.     Where gifts by way of gratuities, vouchers or
      book      tokens     etc     for     lectures,    broadcasts       or   similar
      occurrences are offered, then acceptance should be based
      on how much of the preparatory work for the event was done
      in the officer’s own time, how much in official time and the
      extent to which Departmental/Agency resources, other than,
      for example, use of an officially issued lap-top at home, were
      used in the preparation. The following guidelines should be
      applied:


      a) If the preparation was carried out entirely in the individual’s own
         time and the event took place outside normal working hours at no
         expense to the Department/Agency, it would be acceptable for the
         individual officer to retain the whole fee, token or other gift;


      b) If,    however,     the         preparation     was      done   wholly    in
         Departmental/Agency         time     with     use   of   Department/Agency
         resources, no gifts or fee should be accepted unless the event is
         carried out outside of normal working hours when a gift or token to
         the value of up to £50 is acceptable; and


      c) If the preparation was carried out and the lecture etc, delivered in
         an officer’s own time but Departmental/Agency facilities were used
         for typing, preparation of PowerPoint / overheads etc, then a gift or
         token to the value of not more than £75 is acceptable.


2.17 In the case of either b, or c, Departments and Agencies can,
      if they so choose, charge the organisation or body a fee


DF1/09/324021
                                                                                                    Appendix 8


        based on the salary costs of the individual and/or the use of
        resources. If a series of gifts from the same source exceed
        the monetary limits set out above the same rules apply.


Reporting Gifts and Approval Process to be followed


2.18    If gifts (apart from those trivial or inexpensive gifts for which approval is
        not required under Paragraph 2.10 of this Guidance) are received, the
        approval of the Head of Division for staff up to Grade 6/7 and the
        Head of Department/Chief Executive for senior civil service should
        be sought using form A1 which is attached at Annex C. In the case
        of Heads of Departments gifts may be accepted after discussion at the
        Permanent Secretary Group. If the recipient has or will reject the gift,
        they only need to send details to their line manager for inclusion in the
        Departmental/Agency Register.


2.19 In each case submitted to him/her, the approving officer will
        decide in writing or email, whether to:


             a) allow the recipient to keep the gift;
             b) return the gift to the donor with a suitably worded letter
                  explaining why the gift cannot be accepted.                                 A template has
                  been attached at Annex B which should be tailored to suit each
                  individual circumstance;
             c) use or dispose of it, if possible, in or by the Department/Agency;
                  or
             d) donate the gift to a nominated Charity.


  The approving officer will ensure that the details of the case and his/her decision are recorded in the Gifts and
  Hospitality register.



Hospitality




DF1/09/324021
                                                                   Appendix 8


2.20 The handling of offers of hospitality is recognised as being
       much more difficult to regulate but it is an area in which staff
       must exercise careful judgement.                 In exercising this
       judgement it is acknowledged that there can be difficulty in
       distinguishing between a "gift" and "hospitality". It is also
       recognised that it can be as embarrassing to refuse
       hospitality, as it can be to refuse a gift.


2.21   The acceptance of what would be accepted as conventional hospitality,
       for example working lunches, should, in the main, cause no problem
       especially if there is some official means of reciprocity and provided
       that it is limited to isolated occasions and its acceptance is in the
       interests of the Department/Agency. Hospitality, which would not be
       acceptable, would include invitations to frequent or more expensive
       social functions where there is no direct link to official business
       (sporting events, the theatre, opera or ballet etc), particularly where
       these come from the same source, and those which involve travel,
       hotel or other subsistence expenses. For further guidance refer to the
       checklist at Annex D.


2.22   It can be argued that if officers are to achieve the best value for money
       in dealings with suppliers or consultants then they need to build up
       contacts and that it is quite legitimate for them to have a close working
       relationship with organisations or individuals, which may involve a
       degree of hospitality. There may also be instances where staff receive
       invitations to events run by voluntary organisations such as Annual
       Conferences or Dinners. Attendance at such events is considered an
       integral element in building and maintaining relationships with these
       sectors and any hospitality received is likely to be reasonable and
       proportionate, and therefore acceptable. Additionally, very occasional
       acceptance of meals or tickets to public sporting, cultural or social
       events may be accepted if attendance is justified as being in the


DF1/09/324021
                                                                    Appendix 8


       Department’s or Agency’s particular business interest. But it will be for
       the officer and his/her managers to demonstrate clearly that
       acceptance was in the departmental interest.


2.23   The main point is that in accepting hospitality staff need to be
       aware of and guard against, the dangers of misrepresentation or
       perception of favouritism by a competitor of the host.


2.24 To sum up, in deciding whether hospitality can be accepted,
       staff should consider if it:


          a) is likely to help business effectiveness;
          b) places no obligation or perceived obligation on the recipient;
          c) is not frequent, lavish or prolonged;
          d) is unconnected with any decision affecting the organisation or
             the individual offering it;
          e) can be justified; and
          f) provides benefits to the Department or Agency, which outweigh
             the risk of possible misrepresentation of the hospitality.


Reporting Hospitality and Approval Process to be followed


2.25   When in doubt about accepting hospitality or an invitation line
       management or the Establishment Officer should be consulted. In all
       instances where other than conventional hospitality (infrequent
       working lunches) is offered, the approval of the Head of Division for
       staff up to Grade 6/7 and the Head of Department/Chief Executive
       for senior civil service should be sought using form A1 which is
       attached at Annex D.        In the case of Heads of Departments the
       hospitality may be accepted following discussion at the Permanent
       Secretary Group. If the recipient has or will reject the offer of
       hospitality, they only need to send details to their line manager for
       inclusion in the Departmental/Agency Register.          It is particularly


DF1/09/324021
                                                                     Appendix 8


       important to ensure that a Department or Agency is not over-
       represented at an event or function and care should be taken to ensure
       that this does not happen, for example, by enquiring from the host as to
       other staff who have received similar invitations. To guard against the
       multiple acceptance of invitations to the same event, each Department
       should make arrangements to ensure that corporate consideration is
       given to all invitations.



       Awards or Prizes


2.26 Staff should consult with their line management if they are
       offered an award or prize in connection with their official
       duties. They will normally be allowed to keep it provided:


            a) there is no risk of public criticism;
            b) it is offered strictly in accordance with personal achievement;
            c) It is not in the nature of a gift nor can be construed as a gift,
               inducement or payment for a publication or invention to which
               other rules apply.


2.27   A process as outlined in Paragraph 2.17 should be followed.


Section 3

Monitoring arrangements

3.1    Departmental Registers of Gifts, Hospitality and Awards will be
       subject to the following monitoring arrangements.


           Heads of Divisions will be responsible for monitoring the
            Registers of their respective Business Units on an annual
            basis.



DF1/09/324021
                                                               Appendix 8


           Each Head of Department will be responsible for monitoring
            the Registers of Senior Civil Service colleagues within their
            Department on an annual basis.


           The Head of the NI Civil Service will monitor the Registers for
            Permanent Secretaries annually.


Section 4


Enquiries


4.1   Any enquiries about this guidance should be directed to Barry
      Mulligan,       Corporate     HR,      tel.   02890572349;    e-mail
      Barry.Mulligan@dfpni.gov.uk .




DF1/09/324021
                                                                                Appendix 8



                                                                                                                                           Annex A

Directorate:                                                       Division:                                                   Year:



       REGISTER OF GIFTS / HOSPITALITY / AWARDS ETC

Date of Offered to   Ultimate         Offered From   Description of Reason for Offer   Details of    Est. /     Action       Entered   Entered File Ref:
Event                recipient                       Offer                             Contracts -   actual     Taken i.e.   by        Date
or Gift              (if different)                                                    current or    value of   Accepted /
Offered                                                                                potential     offer £    Declined /
                                                                                                                Returned
                                                                         Appendix 8




                                                                              Annex B

Template for Return of Offer of Gift/Hospitality

(The content of this template should be tailored to suit each circumstance)


Contact name                         Name of Business
Name of company                      Manager/Head of Division:
Address of company                   Office Address


                                    Date




Dear

The Northern Ireland Civil Service operates a Gift and Hospitality Policy to ensure
high standards of propriety in the conduct of its business.

On account of public confidence, perception is as important as reality and because of
this I am obliged to return your offer of INSERT: Name of gift / hospitality.

This is not in any way meant to offend or to imply that your [gift/hospitality] was
offered in anything but the utmost good faith, but is designed to protect both
individual members of staff and the Northern Ireland Civil Service. I hope you will
accept our response in that spirit and that we can look forward to continued effective
working relationships.

Yours …………
                                                                                    Appendix 8


                                                                                       Annex C
(Part 1 to be completed by recipient – part 2 overleaf to be completed by approving officer)




GIFT/HOSPITALITY FORM A1 (Part 1)
DETAILS

Offered to:

Name of ultimate recipient
if not as above (ie if gift or
hospitality passed on to
someone else):
Date of event or gift
offered:

Who made the offer:

Description of offer:

Why was the offer made:

Estimated/actual value of
offer:

State whether offer was
declined:
Is there a current/potential
contract with the donor? If
yes provide details:

Signature:                           Signed:
                                     Date:


PLEASE TURN OVER FOR PART 2 TO BE COMPLETED BY THE APPROVING OFFICER
                                                          Appendix 8




GIFT/HOSPITALITY FORM A1 (Part 2)
OUTCOME

Decision:
(Approved/Not Approved)
Reasons why approval
has/has not been granted:

Is gift being returned? If
so, a letter should be
issued (template at Annex
B to be used)
Has the gift been used or
disposed of? If so give
details:

Has the gift been donated
to a nominated charity?

Has     the   Gifts     and
Hospitality register   been
updated?

Signature   of   Approving Signed:
Officer:                   Date:


NB: FORM NOT VALID UNLESS BOTH PARTS 1 AND 2 HAVE BEEN COMPLETED
                                                                                  Appendix 8


                                                                                      Annex D

Offers of Hospitality Checklist

Type of gift/hospitality              Approval required                        Guidance
                                                                               reference
1. Modest conventional                No                                       2.24
   hospitality (eg working
   lunch).

2. More formal lunch or dinner,       Prior approval required from Head of     2.19 to 2.24
   by prior invitation.               Division or Head of Department/Chief
                                      Executive as appropriate.
3. Hospitality for a team             Prior approval required from Head of     2.22
                                      Division or Head of Department/Chief
                                      Executive as appropriate.
4. Commemorative or similar           Prior approval required from Head of     2.19 to 2.24
   occasion       organised     by    Division or Head of Department/Chief
   contractor, consultant or          Executive as appropriate.
   supplier (eg to celebrate an
   anniversary,      opening     or
   handover.
5. Trade promotion on                 Prior approval required from Head of     2.19 to 2.24
   company’s premises with            Division or Head of Department/Chief
   meals or drinks.                   Executive as appropriate.
6. Annual dinner of Professional      Prior approval required from Head of     2.19 to 2.24
   Institute or Association:          Division or Head of Department/Chief
    where the officer is a           Executive as appropriate.
        guest of the Institution or
        Association
    where the officer is a
        guest of a particular
        consultant, contractor or
        supplier.

7. Overseas visits to inspect         Prior approval required from Head of     2.19 to 2.25
   manufacturers’                     Division or Head of Department/Chief
   products/premises.                 Executive/Head of the Civil Service as
                                      appropriate.

Form A1: Gifts and Hospitality Approval Form and Gift and Hospitality Register must be
completed on all occasions.

Examples where hospitality may not be accepted (not a prescriptive list)

*Leisure Events        * Complimentary Tickets

*Sporting Events       *Weekend breaks or holidays, whether paid for or not.

(very occasional acceptance of meals or tickets may be accepted - see paragraph 2.21)
                      Appendix 8




  NORTHERN IRELAND CIVIL
        SERVICE



GUIDANCE ON OFFERS AND THE

      ACCEPTANCE OF

  GIFTS AND HOSPITALITY
                                                                    Appendix 8


GUIDANCE ON OFFERS AND THE ACCEPTANCE OF GIFTS AND
HOSPITALITY


Introduction

Section 1


1.1   The Northern Ireland Civil Service (NICS) recognises that contractors
      and other customers of our services may extend from time to time
      offers of gifts and hospitality to staff. The NICS also recognises that its
      employees have a responsibility, in the interests of public confidence, to
      exhibit high standards of propriety, and carry out their role with
      dedication and a commitment to the Civil Service and its core values:
      integrity, honesty, objectivity and impartiality.


1.2   Section 2 of this guidance sets out the principles governing the
      acceptance of gifts and hospitality by staff and provides some specific
      advice on how these principles should be interpreted across the
      NICS. The guidance is designed to remind staff of their responsibility
      to exercise judgement and propriety regarding offers of gifts and
      hospitality.   The guidance is effective immediately but will be
      subject to review when required.


1.3   The NICS Staff Handbook indicates that civil servants should conduct
      themselves with honesty and impartiality in the exercise of their
      duties. As a consequence, they should never receive benefits of any
      kind from a third party which might reasonably be thought to
      compromise their personal judgement or integrity. In this field,
      perception is as important as reality.


1.4   The fundamental principle is that no member of staff should do
      anything which might give rise to the impression that he or she
      has been or might be influenced by a gift or hospitality or other
                                                                    Appendix 8


      consideration to show bias for or against any person or
      organisation while carrying out official duties.


1.5   Section 3 of this guidance sets out the monitoring arrangements that
      departments must put in place to ensure that the arrangements are
      operating effectively and that they can be seen to be operating
      effectively.


Section 2


2.1   This guidance sets out good practice concerning the acceptance or
      rejection of gifts or hospitality, and details responsibilities and
      procedures for the authorisation and recording of such instances. As
      Civil Servants our standards of conduct are determined by what the
      Government and the public as taxpayers expect and not by what may
      be a common practice in the private sector.


2.2   External people acting on behalf of the NICS (for example, consultants,
      contracted staff etc) must also abide by the policy. If it is believed that
      an external person may have breached the policy, the matter should be
      reported to the Head of Division or more senior manager, who will take
      the matter forward with the individual or his/her company.            This
      requirement should be notified to external staff before they start
      work within any NICS Department or Agency.


2.3   This guidance should also be seen as applying to spouses, partners
      or other associates if it can be argued or perceived that the gift or
      hospitality is in fact for the benefit of the official.


2.4   Any breach of the rules of conduct can lead to disciplinary
      action and in some circumstances can be a criminal offence.

2.5   The policy governing the acceptance of gifts, hospitality and awards by
                                                                                                   Appendix 8

  Northern Ireland Civil Servants is set out in Sections 1.9 and 1.10 of the Conduct Chapter of the NICS Staff
  Handbook



      This Guidance focuses on the key issues and the specific rules, which all
staff in the NICS should adopt.

         Legal Obligations and Fundamental Principles


2.7      Under the Prevention of Corruption Acts of 1906 and 1916 it
         is an offence for an officer in his/her official capacity:


            to corruptly accept any gift or consideration as an inducement or
             reward for doing, or refraining from doing, anything in that capacity;
             or
            to show favour or disfavour to any person; or
            to receive money, gifts or consideration from a person or
             organisation holding or seeking to obtain a Government contract.


         All of these are deemed by the Courts to have been received corruptly
         unless it is proven otherwise.


Record of gifts, hospitality, invitations, etc


2.8      Departments will maintain Registers of Gifts, Hospitality and
         Awards which will be available for periodic review. The purpose of the
         Registers will be to counter any possible accusations or suspicions of
         breach of the rules of conduct by staff. The registers are subject to
         Freedom of Information (FOI) queries. A template is attached at
         Annex A that should be used to register gifts, hospitality, invitations
         etc.


2.9      It will be the responsibility of each Department to ensure all
         staff are made aware of this guidance and that registers are
         in place and properly maintained and updated.                                         To facilitate
                                                                    Appendix 8


       the monitoring arrangements at paragraph 3.1 Departments
       should maintain a register for each Division and a separate
       register for senior civil service.


Acceptance of Gifts


2.10 The general principle is that all gifts offered should be
       refused. However seasonal, promotional or trivial gifts (such
       as calendars, diaries, pens etc), which bear Company names
       and/or logos of the provider of the gift and have a value of
       less than £50, may be accepted by individuals without the
       need for these to be reported or approved in advance. A
       token gift may be accepted if it is presented by an
       organisation, however, these and the acceptance of any
       other gifts must have been approved by management (see
       paragraph 2.17) and must be declared by the member of
       staff in their Departmental/Agency register


2.11   More expensive or substantial items, valued at £50 or more and gifts
       of lottery tickets, cash, gift vouchers or gift cheques, cannot on any
       account be accepted.        All gifts offered (apart from those which are
       trivial or inexpensive), even if they are declined/returned need to be
       recorded in the register.




Trade, loyalty or Discount Cards
                                                                     Appendix 8


2.12   Trade, loyalty or discount cards by which an officer might personally
       benefit from the purchase of goods or services at a reduced price are
       classified as gifts and should be refused or returned to sender.


2.13   Frequent flyer cards used by airlines can be used by staff to avail of
       special departure lounges and priority booking and check-in.        They
       must NOT make private use of any flights/air miles, which derive
       from flights paid for from the public purse.




Staff involved in the procurement or monitoring of a contract


2.14   Apart from trivial / inexpensive seasonal gifts, such as diaries, no gifts
       or hospitality of ANY kind from any source should be accepted by
       anyone involved in the procurement or monitoring of a contract. This
       will ensure that no criticism can be made regarding bias to a particular
       company or supplier.


Gifts received in recognition of work done


2.15 On no account should a gift or gratuity be solicited or
       requested.      Where gifts by way of gratuities, vouchers or
       book    tokens     etc    for   lectures,      broadcasts   or    similar
       occurrences are offered, then acceptance should be based
       on how much of the preparatory work for the event was done
       in the officer’s own time, how much in official time and the
       extent to which Departmental/Agency resources, other than,
       for example, use of an officially issued lap-top at home, were
       used in the preparation. The following guidelines should be
       applied:
                                                                       Appendix 8


       a) If the preparation was carried out entirely in the individual’s own
          time and the event took place outside normal working hours at no
          expense to the Department/Agency, it would be acceptable for the
          individual officer to retain the whole fee, token or other gift;


       b) If,   however,      the    preparation     was      done     wholly     in
          Departmental/Agency       time    with   use   of   Department/Agency
          resources, no gifts or fee should be accepted unless the event is
          carried out outside of normal working hours when a gift or token to
          the value of up to £50 is acceptable; and


       c) If the preparation was carried out and the lecture etc, delivered in
          an officer’s own time but Departmental/Agency facilities were used
          for typing, preparation of PowerPoint / overheads etc, then a gift or
          token to the value of not more than £75 is acceptable.


2.16 In the case of either b, or c, Departments and Agencies can,
       if they so choose, charge the organisation or body a fee
       based on the salary costs of the individual and/or the use of
       resources. If a series of gifts from the same source exceed
       the monetary limits set out above the same rules apply.


Reporting Gifts and Approval Process to be followed


2.17   If gifts (apart from those trivial or inexpensive gifts for which approval is
       not required under Paragraph 2.10 of this Guidance) are received, the
       approval of the Head of Division for staff up to Grade 6/7 and the
       Head of Department/Chief Executive for senior civil service should
       be sought using form A1 which is attached at Annex C. In the case
       of Heads of Departments gifts may be accepted after discussion at the
       Permanent Secretary Group. If the recipient has or will reject the gift,
       they only need to send details to their line manager for inclusion in the
       Departmental/Agency Register.
                                                                                                     Appendix 8



2.18 In each case submitted to him/her, the approving officer will
        decide in writing or email, whether to:


             a) allow the recipient to keep the gift;
             b) return the gift to the donor with a suitably worded letter
                  explaining why the gift cannot be accepted.                                 A template has
                  been attached at Annex B which should be tailored to suit each
                  individual circumstance;
             c) use or dispose of it, if possible, in or by the Department/Agency;
                  or
             d) donate the gift to a nominated Charity.


  The approving officer will ensure that the details of the case and his/her decision are recorded in the Gifts and
  Hospitality register.



Hospitality


2.19 The handling of offers of hospitality is recognised as being
        much more difficult to regulate but it is an area in which staff
        must exercise careful judgement.                                           In exercising this
        judgement it is acknowledged that there can be difficulty in
        distinguishing between a "gift" and "hospitality". It is also
        recognised that it can be as embarrassing to refuse
        hospitality, as it can be to refuse a gift.


2.20    The acceptance of what would be accepted as conventional hospitality,
        for example working lunches, should, in the main, cause no problem
        especially if there is some official means of reciprocity and provided
        that it is limited to isolated occasions and its acceptance is in the
        interests of the Department/Agency. Hospitality, which would not be
        acceptable, would include invitations to frequent or more expensive
        social functions where there is no direct link to official business
                                                                    Appendix 8


       (sporting events, the theatre, opera or ballet etc), particularly where
       these come from the same source, and those which involve travel,
       hotel or other subsistence expenses. For further guidance refer to the
       checklist at Annex D.


2.21   It can be argued that if officers are to achieve the best value for money
       in dealings with suppliers or consultants then they need to build up
       contacts and that it is quite legitimate for them to have a close working
       relationship with organisations or individuals, which may involve a
       degree of hospitality. There may also be instances where staff receive
       invitations to events run by voluntary organisations such as Annual
       Conferences or Dinners. Attendance at such events is considered an
       integral element in building and maintaining relationships with these
       sectors and any hospitality received is likely to be reasonable and
       proportionate, and therefore acceptable. Additionally, very occasional
       acceptance of meals or tickets to public sporting, cultural or social
       events may be accepted if attendance is justified as being in the
       Department’s or Agency’s particular business interest. But it will be for
       the officer and his/her managers to demonstrate clearly that
       acceptance was in the departmental interest.


2.22   The main point is that in accepting hospitality staff need to be
       aware of and guard against, the dangers of misrepresentation or
       perception of favouritism by a competitor of the host.


2.23 To sum up, in deciding whether hospitality can be accepted,
       staff should consider if it:


          a) is likely to help business effectiveness;
          b) places no obligation or perceived obligation on the recipient;
          c) is not frequent, lavish or prolonged;
          d) is unconnected with any decision affecting the organisation or
             the individual offering it;
                                                                      Appendix 8


          e) can be justified; and
          f) provides benefits to the Department or Agency, which outweigh
              the risk of possible misrepresentation of the hospitality.


Reporting Hospitality and Approval Process to be followed


2.24   When in doubt about accepting hospitality or an invitation line
       management or the Establishment Officer should be consulted. In all
       instances where other than conventional hospitality (infrequent
       working lunches) is offered, the approval of the Head of Division for
       staff up to Grade 6/7 and the Head of Department/Chief Executive
       for senior civil service should be sought using form A1 which is
       attached at Annex D.        In the case of Heads of Departments the
       hospitality may be accepted following discussion at the Permanent
       Secretary Group. If the recipient has or will reject the offer of
       hospitality, they only need to send details to their line manager for
       inclusion in the Departmental/Agency Register.           It is particularly
       important to ensure that a Department or Agency is not over-
       represented at an event or function and care should be taken to ensure
       that this does not happen, for example, by enquiring from the host as to
       other staff who have received similar invitations. To guard against the
       multiple acceptance of invitations to the same event, each Department
       should make arrangements to ensure that corporate consideration is
       given to all invitations.



       Awards or Prizes


2.25 Staff should consult with their line management if they are
       offered an award or prize in connection with their official
       duties. They will normally be allowed to keep it provided:


          a) there is no risk of public criticism;
                                                                      Appendix 8


            b) it is offered strictly in accordance with personal achievement;
            c) It is not in the nature of a gift nor can be construed as a gift,
               inducement or payment for a publication or invention to which
               other rules apply.


2.26   A process as outlined in Paragraph 2.17 should be followed.


Section 3

Monitoring arrangements

3.1    Departmental Registers of Gifts, Hospitality and Awards will be
       subject to the following monitoring arrangements.


           Heads of Divisions will be responsible for monitoring the
            Registers of their respective Business Units on an annual
            basis.


           Each Head of Department will be responsible for monitoring
            the Registers of Senior Civil Service colleagues within their
            Department on an annual basis.


           The Head of the NI Civil Service will monitor the Registers for
            Permanent Secretaries annually.


Section 4


Enquiries


4.1    Any enquiries about this guidance should be directed to Barry
       Mulligan,       Corporate      HR,      tel.    02890572349;        e-mail
       Barry.Mulligan@dfpni.gov.uk .
                                                                                                                Appendix 8



                                                                                                                                             Annex A

Directorate:                                                       Division:                                                     Year:



       REGISTER OF GIFTS / HOSPITALITY / AWARDS ETC

Date of Offered to   Ultimate         Offered From   Description of Reason for Offer   Details of    Est. /       Action       Entered   Entered File Ref:
Event                recipient                       Offer                             Contracts -   actual       Taken i.e.   by        Date
or Gift              (if different)                                                    current or    value of     Accepted /
Offered                                                                                potential     offer £      Declined /
                                                                                                                  Returned
                      `                                                                    Appendix 8




                                                                                           Annex B

Template for Return of Offer of Gift/Hospitality

(The content of this template should be tailored to suit each circumstance)


Contact name                          Name of Business
Name of company                       Manager/Head of Division:
Address of company                    Office Address


                                     Date




Dear

The Northern Ireland Civil Service operates a Gift and Hospitality Policy to ensure high
standards of propriety in the conduct of its business.

On account of public confidence, perception is as important as reality and because of this I
am obliged to return your offer of INSERT: Name of gift / hospitality.

This is not in any way meant to offend or to imply that your [gift/hospitality] was offered in
anything but the utmost good faith, but is designed to protect both individual members of
staff and the Northern Ireland Civil Service. I hope you will accept our response in that
spirit and that we can look forward to continued effective working relationships.

Yours …………
                         `                                                                     Appendix 8

                                                                                               Annex C
(Part 1 to be completed by recipient – part 2 overleaf to be completed by approving officer)




GIFT/HOSPITALITY FORM A1 (Part 1)
DETAILS

Offered to:

Name of ultimate recipient
if not as above (ie if gift or
hospitality passed on to
someone else):
Date of event or gift
offered:

Who made the offer:

Description of offer:

Why was the offer made:

Estimated/actual value of
offer:

State whether offer was
declined:
Is there a current/potential
contract with the donor? If
yes provide details:

Signature:                           Signed:
                                     Date:


PLEASE TURN OVER FOR PART 2 TO BE COMPLETED BY THE APPROVING OFFICER
                       `                                           Appendix 8




GIFT/HOSPITALITY FORM A1 (Part 2)
OUTCOME

Decision:
(Approved/Not Approved)
Reasons why approval
has/has not been granted:

Is gift being returned? If
so, a letter should be
issued (template at Annex
B to be used)
Has the gift been used or
disposed of? If so give
details:

Has the gift been donated
to a nominated charity?

Has     the   Gifts         and
Hospitality register       been
updated?

Signature   of   Approving Signed:
Officer:                   Date:


NB: FORM NOT VALID UNLESS BOTH PARTS 1 AND 2 HAVE BEEN COMPLETED
                         `                                                                    Appendix 8

                                                                                              Annex D

Offers of Hospitality Checklist

Type of gift/hospitality              Approval required                        Guidance
                                                                               reference
1. Modest conventional                No                                       2.24
   hospitality (eg working
   lunch).

2. More formal lunch or dinner,       Prior approval required from Head of     2.19 to 2.24
   by prior invitation.               Division or Head of Department/Chief
                                      Executive as appropriate.
3. Hospitality for a team             Prior approval required from Head of     2.22
                                      Division or Head of Department/Chief
                                      Executive as appropriate.
4. Commemorative or similar           Prior approval required from Head of     2.19 to 2.24
   occasion       organised     by    Division or Head of Department/Chief
   contractor, consultant or          Executive as appropriate.
   supplier (eg to celebrate an
   anniversary,      opening     or
   handover.
5. Trade promotion on                 Prior approval required from Head of     2.19 to 2.24
   company’s premises with            Division or Head of Department/Chief
   meals or drinks.                   Executive as appropriate.
6. Annual dinner of Professional      Prior approval required from Head of     2.19 to 2.24
   Institute or Association:          Division or Head of Department/Chief
    where the officer is a           Executive as appropriate.
        guest of the Institution or
        Association
    where the officer is a
        guest of a particular
        consultant, contractor or
        supplier.

7. Overseas visits to inspect         Prior approval required from Head of     2.19 to 2.25
   manufacturers’                     Division or Head of Department/Chief
   products/premises.                 Executive/Head of the Civil Service as
                                      appropriate.

Form A1: Gifts and Hospitality Approval Form and Gift and Hospitality Register must be
completed on all occasions.

Examples where hospitality may not be accepted (not a prescriptive list)

*Leisure Events        * Complimentary Tickets

*Sporting Events       *Weekend breaks or holidays, whether paid for or not.

(very occasional acceptance of meals or tickets may be accepted - see paragraph 2.21)
                                                                                          Appendix 9


            Guidance on Performing An Assessment of Fraud Risks
                        And Completion of Template.

1. Identify the key fraud risks facing your business and detail these in Column 1.


Examples might be:


-   Fraudulent subsidy/grant claims;
-   Payment made on false documentation;
-   Theft of assets;
-   Misappropriation of cash;
-   False accounting;
-   Contract fraud;
-   Procurement fraud;
-   Collusion;
-   Computer fraud;
-   Fraudulent encashment of payable instruments;
-   Travel and subsistence fraud;
-   False claims for hours worked.




2. Assess the impact of the identified fraud risk should it occur – High, Medium or Low
    (Column 2). What damage could be done in relation to achievement of objectives, financial
    loss, reputation etc?




3. Assess the likelihood of the identified fraud risk occurring – High, Medium or Low (Column
    3). High would be probable/likely, low would be improbable/unlikely.
                                                                                       Appendix 9



4. Identify the key controls already in place to address each identified risk (Column 4);


    Examples might be:


-   Segregation of duties;
-   Payment authorisation levels;
-   Payment/lodgement reconciliations;
-   Management checks and reviews;
-   Tendering process;
-   Transparent approval process;
-   Inter-system checks e.g. G&S against APHIS;
-   Physical controls such as safes, key safes etc.;
-   Logical access controls;
-   Physical access controls;
-   Asset register and inventory checks;
-   Audit logs;
-   Project monitoring;
-   Performance monitoring;
-   Independent/unannounced inspections;
-   Post-payment checks;
-   Training;
-   Manuals;
-   Staff rotation;
-   Irregularity recording, investigation and reporting process etc.


5. Determine if any risk still exists after the application of the identified controls (Column 5).
    For example, the original risk detailed in column 1 will probably still be a risk post-control
    although the effective application of the controls detailed in column 4 will reduce the
    likelihood of occurrence.
                                                                                      Appendix 9

6. Detail in Column 6 what further action you are going to take to address the residual risk. It
   may be that control over the risk lies elsewhere and as a consequence you will have to
   accept the risk. If this is the case, justify why you are accepting the risk.


   If you are planning further action to treat the risk, state what this is, who will be responsible
   for the action and when it is to be implemented.


7. Column 7 will be used by you for internal reviews of the risk management framework.


8. Issue completed framework to the Head of Internal Audit annually. Review internally on a
   regular basis – at least every 6 months.
                                                                            Appendix 9


                             FRAUD RISK MANAGEMENT FRAMEWORK


Programme Expenditure


GAE insert year and amount:




    FRAUD RISK   IMPACT       LIKELIHOOD      KEY      RESIDUAL   PLANNED      ACTION
                 (H, L, M)      (H, L, M)   CONTROLS    RISKS      ACTION      TAKEN




                                               74
                                                Appendix 10




            Service Level Agreement


                      For


    Provision of Fraud Investigation Services


                       To


     The Department of Finance Personnel


                       By


Department of Agriculture and Rural Development
          Central Investigation Service



                    2008-2011




                       73
                SLA for the Provision of Fraud Investigation Services


                                       Index



Paragraphs                                 Title                        Page

    1        Introduction                                                1

    2        Objectives                                                  1

   3-4       Client and Service Provider Details                         1

    5        Period of the Agreement                                     1

   6-7       Scope of the Agreement                                      1

    8        The Service Level Requirement                               2

   9-10      Performance Monitoring                                      2

  11-12      Basis of Costs                                              2

  13-19      Confidentiality                                             3

  20-22      Resolution of Complaints or Disputes                        4

  23-25      Review of the Agreement (Variation)                         4

  26-28      Sub-Contracting                                             5

    29       Contacts                                                    5

  30-31      Termination                                                 6

    32       Joint Agreement                                             6


             Appendices


     I       Terms of Reference                                          7

    II       External Referral Document (RD1)                            9

    III      Internal Referral Document (RD1 DFP (I))                    11




                                         74
                  SLA for the Provision of Fraud Investigation Services



     Introduction

1.   The purpose of this Agreement is to set out the basis on which the Service Provider
     will deliver the Service to the Client. It specifies the nature, quality, required outputs
     and monitoring arrangements for the Service to be provided and the basis of costs.
     It also outlines the responsibilities of the Client with regard to the provision of
     information, compliance with procedures etc, in order for the Service Provider to
     deliver an efficient service. Although this Agreement has no legal effect, the Client
     and Service Provider will act in accordance with the Agreement.



     Objectives

2.   The objectives of this Agreement are to formalise the operational requirements, to
     define the obligations of both parties, and to promote a flexible co-operative
     arrangement.



     Client and Service Provider Details

3.   The Client is the Department of Finance and Personnel whose main offices are at
     Rathgael House, Balloo Road, Bangor BT19 7NA. The Client Manager is Mr Jim
     O’Hagan, DFP Director of Finance, of the above address.


4.   The Service Provider is DARD Central Investigation Service, Dundonald House,
     Upper Newtownards Road, Belfast BT4 3SZ. The Service Manager is Mr Tommy
     McCauley (Head of DARD Central Investigation Service) of the above address.



     Period of the Agreement

5.   The term of this Agreement covers the period commencing 1st April 2008 and
     ending 31st March 2011.



     Scope of the Agreement

6.   The provision of the following services are covered by this Agreement:




                                             75
                    SLA for the Provision of Fraud Investigation Services



          Provision of advice and guidance on all instances of fraud or suspected fraud
           and irregularity (Fraud is defined as the use of deception with the intention of
           obtaining an advantage, avoiding an obligation or causing loss to another
           party. Irregularity is defined as intentional distortions of financial statements or
           other records, for whatever purpose);

          Full investigative services in accordance with the requirements of the Police
           and Criminal Evidence (Northern Ireland) Order 1989;

          Consultations on behalf of the Department with the PSNI; and

          Attendance at meeting, as required.


7.    A more detailed description of each service is described in the Terms of Reference
      (ToR) provided by the Service Provider to the Service Manager and attached at
      Appendix I.



      The Service Level Requirement

8.    The Service Provider will provide the service specifically requested by the Client as
      the need arises.



      Performance Monitoring

9.    The level and standard of service to be provided by the Service Provider will be in
      accordance with that specified in the ToR from the Service Provider to the Service
      Manager.


10.   The Service Provider will furnish the Client with reports as agreed in the ToR.



      Basis of Costs

11.   Formal charges will be raised for the services provided. The calculation of costs is
      based on the DARD Ready Reckoner of Staff Costs and accordingly services will
      be charged for the initial period of the agreement at £12,500 per annum. This
      amount is inclusive of direct travel and subsistence costs and is based on a joint
      arrangement with the Special EU Programmes Body (SEUPB), ie SEUPB will be


                                             76
                   SLA for the Provision of Fraud Investigation Services


      charged a further £37,500 per annum.            Actual costs relating to the use of
      consultants will be payable by the Client via the Service Provider.


12.   The Service Provider will monitor costs incurred during the term of the Agreement
      and invoice the Client on a twice yearly, in advance. Charges, frequency of billing
      and the joint arrangement with the SEUPB will also be reviewed annually for
      continued appropriateness and value for money.



      Confidentiality

13.   All data, information and reports will be regarded as strictly confidential to the Client
      and Service Provider.


14.   For the avoidance of doubt, no details whatsoever of the Client’s business obtained
      during the course of investigative work will be divulged to any unauthorised third
      party without the prior permission of the Client Manager or his designated officer.


15.   In the event of a material breach of the confidentiality provisions the Client will have
      the right to terminate the Agreement on giving written notice to that effect.


16.   The Service Provider will however be able to use and quote from any data that has
      been published or is held in the public domain, eg Audited Annual Accounts,
      statistics and other sources of publicly available information.


17.   All investigative files, working papers, reports, and other documents specific to the
      Client will remain the property of the Client. All archive material will be stored at the
      premises of the Service Provider unless otherwise specified by the Client.


18.   All current investigative files, working papers, reports and other documents specific
      to a Client will be held securely by the Service Provider in designated
      accommodation.


19.   Access to all current documents will be restricted to the Service Provider and Client,
      or other staff specifically authorised by the Client.


                                              77
                  SLA for the Provision of Fraud Investigation Services



      Resolution of Complaints or Disputes

20.   Should the Client have cause to complain about deficient quality, quantity or
      standards of service or other customer care issues such as courtesy of staff, the
      matter will be resolved by the following procedures:

      a) Minor problems with the service should be resolved informally following
         discussion between the appropriate managers; and

      b) Any major or persistent problems should be reported as follows:

            The Client Manager or other representative will communicate the complaint
             in writing to the Service Manager no later than 5 working days after
             identification of the complaint; and

            In all cases, the Service Manager will investigate, take appropriate corrective
             action, and report to the Client Manager or other representative within 5
             working days of the complaint being notified. A record of all complaints and
             references to their resolution must be kept by both Client Manager and
             Service Manager.


21.   Any dispute, difference or question arising between the Service Provider and the
      Client, which cannot be satisfactorily resolved, will be considered jointly by the DFP
      Audit and Risk Committee. Any resulting decision will be final.


22.   The Client or the Service Provider will not be liable for delay or failure to perform
      any obligation under this agreement if the performance of such an obligation is
      prevented by a cause, which is beyond the control of either party.



      Review of the Agreement (Variation)

23.   The Agreement will be reviewed annually for the purpose of enabling amendments
      to the service level requirements, standards or method of operation of the service,
      varying the scope of the service to be provided, agreeing adjustments to
      costs/charges, reviewing service achievements and response levels against the
      Agreement targets or undertaking action to improve compliance with the
      Agreement, or reviewing the targets contained.



                                             78
                    SLA for the Provision of Fraud Investigation Services


24.   Any additions or variations to the service required by the Client and agreed by the
      Service Provider, will be identified and appended to this Agreement.


25.   Additionally, the parties may undertake interim reviews for the purpose of
      negotiating the amendments to this Agreement in response to new statutory
      requirements or policy decisions having the effect of varying the scope or level of
      the service required.


      Sub-Contracting

26.   The Service Provider will not sub-contract any of the services defined in Terms of
      Reference without the prior written consent of the Client.


27.   In the event of the Client consenting to services being sub-contracted, the sub-
      contract will be a contract between the Service Provider and the successful
      tenderer.


28.   The Client reserves the right to withdraw its consent to any sub-contractor where it
      has reasonable grounds to no longer approve of the sub-contractor or the sub-
      contracting arrangement.      The contract with the external provider will then be
      terminated.


      Contacts

29.   All communications between the Client and the Service Provider in respect of the
      Agreement must be conducted through agreed representatives, who will be:




                                             79
                     SLA for the Provision of Fraud Investigation Services



Client                                  (1)                                      (2)
Name                           Mr Ryan Dobson                          Mrs Bertha McWhinney
Title/Grade              Departmental Establishment                         Deputy DEO
                                   Officer (DEO)
Telephone                   9185 8146 (or x 68146)                     9185 8072 (or x 68072)
Service Provider                        (1)                                      (2)
Name                         Mr Tommy McCauley                            Mr Karl Oakman
Title/Grade                 Head of DARD Central                  Senior Investigator Central
                             Investigation Service                      Investigation Service
Telephone                   9052 4084 (or x 24084)                     9052 5005 (or x 25005)


         Termination

30.      The notice period of terminating the Agreement will be 12 months, or such other
         mutually agreed period.


31.      If another organisation is required to take over the service at the expiry or
         termination of the Agreement, the Service Provider will co-operate in the transfer.
         The transfer will be arranged to reduce to a minimum any interruption in the service.


         Joint Agreement

32.      Both parties signify below their acceptance of the Agreement on the terms and
         conditions documented.
                                                          Signed on Behalf of DARD Central
      Signed on Behalf of the Client (DFP)
                                                                Investigation Service

 Signed:                                                Signed:

 Print Name:            Mr Ryan Dobson                  Print Name:          Mr John Smith

 Designation:             Departmental
                                                        Designation:       Director of Finance
                      Establishment Officer

 Date:                                                  Date:




                                                   80
                                    Terms of Reference

     Description of Service

1.   DARD Central Investigation Service provides a dedicated resource to investigate cases
     of suspected internal and external fraud irregularity and has the authority to conduct
     criminal investigations.


     Roles and Responsibilities

2.   The responsibilities of the DARD Central Investigation Service are as follows:

     a)   Attend case conferences with the Fraud Investigation Oversight Group to discuss
          initial information or preliminary investigation findings in accordance with the DFP
          Fraud Prevention Policy and Fraud Response Plan;

     b)   Assess cases of suspected fraud within 10 working days of receipt to determine if
          investigation action is appropriate;

     c)   Agree a Terms of Reference for the specific assignment with the Departmental
          Establishment Officer within 10 working days;

     d)   Conduct investigations in strict compliance with relevant law and procedure;

     e)   Provide monthly updates (or more frequent if necessary) to the Departmental
          Establishment Officer on all on-going investigations detailing the progress and
          status of investigations and details of calls to the Hotline and subsequent action
          taken;

     f)   Prepare evidence packs and lead all communications with the PSNI;

     g)   Report the outcome of court proceedings to DFP within 1 Day (E-mail);

     h)   Draft a Press Release to publicise prosecution within 1 Day of conviction;

     i)   Provide feedback where appropriate arising from investigations, eg procedural/
          legislative weaknesses;

     j)   Communicate PPS requirements and/or weaknesses in prosecution cases as
          required;

     k)   Provide Fraud Awareness seminars to key staff as required and in agreement with
          the Chair of the DFP Fraud Working Group; and

     l)   Any other services mutually agreed by both parties.




                                             81
                                    Terms of Reference

3.   The responsibilities of DFP are as follows:

     a)   Identify suitable members for the Fraud investigation Oversight Group;

     b)   Arrange case conferences and record minutes of meeting;

     c)   Draft Terms of Reference for each investigation;

     d)   Ensure all cases of suspected fraud and irregularity are referred to the Head
          of Central Investigation Service or deputy immediately suspicion of fraud is
          determined;

     e)   Ensure all cases of suspected fraud are referred to the Head of Central
          Investigation Service or deputy using the appropriate Referral Document, ie
          suspected external fraud in Form RD1 DFP (Appendix II refers) and
          suspected internal fraud on Form RD1 DFP(I) (Appendix III refers);

     f)   Where confidentiality is sought, staff may report their suspicions direct to
          the CIS through the Hotline (telephone number: 080 8100 2716) or on-line via
          the internet www.dardni.gov.uk;

     g)   Ensure that all staff are aware of the correct procedures for reporting fraud and
          irregularity

     h)   Ensure all staff are made aware of the Anti Fraud Policy Statement and
          Fraud Response Plan annually;

     i)   Provide Central Investigation Service with access to records and staff to
          assist in the effective discharge of investigation work; and

     j)   Respond to feedback/recommendations arising from investigations, eg
          procedural/legislative weaknesses, within 10 Days.




                                             82
                                                                                   Appendix I0
                                                          External Referral Document - RD1 DFP

Date Received: __________________


(Part 1) Identity Details of Alleged Offender                                     Date: ________


 Suspect

 Address        ______________________________________                    EU Project Application
                ______________________________________                    No: ________________
                                                                          (if applicable)
                ______________________________________
                ______________________________________
                ______________________________________
                ______________________________________



(Part 2) Other Persons Involved (eg family members or known associates)

             NAME                                           ADDRESS
 1.



 2.



 3.




(Part 3) Details of Allegation/Suspected Offence (attach a separate report if necessary)

  _____________________________________________________________________
  _____________________________________________________________________
  _____________________________________________________________________
  _____________________________________________________________________
  _____________________________________________________________________
  _____________________________________________________________________
  _____________________________________________________________________
  _____________________________________________________________________
  _____________________________________________________________________
  _____________________________________________________________________

Please estimate the financial involvement in this case.               £
(This box must be completed)

                                                                                RD1 (amdt 01/06)

                                                 83
                                                                                  Appendix I0
                                                         External Referral Document - RD1 DFP

(Part 4)       Supporting Documentation (Original documentation should be provided and copies
retained by referring office)
1                                                   6

2                                                   7

3                                                   8

4                                                   9

5                                                   10


Date Detected___________________ Date of Alleged Incident ______________________
*EU Structural Funds only:          Irregularity form completed                    Yes / No
                                    Article 4 Inspection carried out (date): _________________

Reporting Officer ________________ Office/Dept _____________ Tel No/Ext____________
        (PRINT NAME)


Signed _______________________________ Dated: ______________________________

(Part 5) Line Management/Comment/Recommendation




COPY OF REFERRAL FORWARDED TO HEAD OF DIVISION                          YES/NO

Signed ________________________________ Date _____________________________


        (Part 6) Head of Central Investigation Service Comments

    ______________________________________________________________________
    ______________________________________________________________________
    ______________________________________________________________________

        Signed __________________________________Dated



Date Case Recorded on Database: _____________________________________

Signed: ____________________________ Date: ___________________________

                                                                              RD1 (Amdt 01/06)



                                               84
                                                                                   Appendix I0
                                                          External Referral Document - RD1 DFP


Date Received in CIS:

(Part 1) Identity Details of Alleged Offender



Employee Name:                                                      Home Address:
                                                                    _______________________
Office Address:
                                                                    _______________________
                  __________________________________
                                                                    _______________________
                  __________________________________
                                                                    _______________________
                  __________________________________
                  __________________________________                Payroll No: _____________
                  __________________________________


(Part 2) Other Persons Involved (eg known associates)

            NAME:                        ADDRESS (Office)               Payroll No.(if applicable)
 1.



 2.



 3.




(Part 3) Details of Allegation/Suspected Offence (attach a separate report if necessary)

 _____________________________________________________________________
 _____________________________________________________________________
 _____________________________________________________________________
 _____________________________________________________________________
 _____________________________________________________________________
 _____________________________________________________________________

 Please estimate the financial involvement in this case
                                                                       £




                                                 85
                                                                                 Appendix I0
                                                        External Referral Document - RD1 DFP


(Part 4) Supporting Documentation (these should be legible copies)
 1.                                          6

 2.                                          7

 3                                           8

 4                                           9

 5                                           10



Date Detected: _________ Date of Alleged Incident: ___________

Reporting Officer: ________________ Office/Dept: ____________ Tel No/Ext: ___________
       (PRINT NAME)

Signed: ______________________________________ Date: ____________________



                                            CIS USE ONLY

       (Part 5) Head OF Central Investigation Service Comments

 ______________________________________________________________________
 ______________________________________________________________________
 ______________________________________________________________________
 Signed _________________________________ Dated __________________________
 ______________________________________________________________________



Date case recorded on database: ________________

     Signed:            ________________________________                               Date:
___________________________


                                                                                     RD1 (I)




                                                 86
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