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Fraud and Tax Evasion

Our reputation for financial integrity and honesty is essential. Fraud and Tax Evasion are the opposite of honesty. Even when unproven, it can destroy our reputation.

So we leave no room for doubt by applying due diligence and ensuring our books, records and financial reporting accurately reflect the true state of our business, our costs and our transactions.

Fraud - If you deceive someone by misrepresenting or dishonestly reporting facts to gain an advantage, it's fraud. It is also fraud if you get someone else to do it. Fraud is usually carried out for gain, and it is a very serious crime. In some counties the deception doesn't even have to be deliberate - you can face criminal charges just for carelessly allowing it to happen.

Money Laundering - Money laundering involves trying to "launder" the proceeds of criminal activity such as terrorism, drug trafficking and fraud into legitimate funds or assets. Sometimes this also involves using legitimate funds to finance terrorism. Money laundering depends on misrepresentation or creating a false reporting trail. We comply with money laundering and anti-terrorism legislation around the world, and apply due diligence checks on all those we do business with.

Tax Evasion - This is fraud which deprives a Tax Authority of money it is entitled to. Tax Evasion is a criminal offence. In some countries it is also an offence to deliberately and dishonestly take action to help someone else to evade tax.

Time and Expense Reporting - To make sure we are charging our customers properly for our efforts and they are getting what they paid for, it's vital that we maintain accurate timekeeping and expense reporting at all times. Different business units have different ways of doing this. If you have a question, ask for help. Take the time to get it right!

We must all ensure our books, records and financial reporting are complete and accurate.

We do not evade tax and we do not help others to evade tax.

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What you can expect from us:

  • We will report and record accurately, honestly and transparently. We will not falsify records, misrepresent facts or evade the payment of taxes. This could be fraud and can result in civil and criminal liability against individuals and Serco.
  • We have clear, defined and robust controls to ensure all our records, reports and invoices are correct and meet our commercial, legal and regulatory requirements.
  • We will carry out due diligence on anyone we work with.
  • We will monitor financial processes to ensure that the proceeds of crime from fraud by others are not transferred through our activities into legitimate money. Money laundering in any form will not be tolerated.
  • We will properly train everyone responsible for representing us, or for making any record of our status, performance or costs.
  • We will bill, price and cost all our bids and all our work honestly and accurately, never put in false claims, and always keep complete and accurate records.
  • We regard any failure to keep complete and accurate records as a serious violation of Our Code, whether it directly breaks the law or not.
  • We will take appropriate measures, including issuing criminal proceedings, against anyone involved in fraudulent activity.

We expect you to:

  • Follow all procedures for the recording and reporting of information.
  • Ensure our books, records and invoices are accurate, sufficiently detailed and timely.
  • Accurately and honestly report performance and expenses.
  • Adhere to the Group Financial Controls Manual and our other financial processes if you prepare or maintain accounting records of any kind.
  • Never engage in any activity that is designed to commit fraud, misrepresentation or tax evasion, or that could be reasonably interpreted as an attempt to do so.
  • Never make false or misleading statements or submit false claims.
  • Follow our Travel Standard and use Serco Travel when travelling on Serco business, and always keep proper records and receipts for any travel expenses you claim.
  • Speak Up if you think something is not right.

Our reputation for financial integrity and honesty is essential. Fraud is the opposite of honesty. Even when unproven, it can destroy our reputation.

So we leave no room for doubt by applying due diligence and ensuring our books, records and financial reporting accurately reflect the true state of our business, our costs and our transactions.

You need some building materials for private use that are sold by a regular Serco supplier. You say they're for Serco so you get the discount but your pay personally.

Is that okay?

1. It may be taking advantage a bit, but it's hardly fraud

Wrong. Please try again.

2. Absolutely not. That would be fraud

Right answer because:

Our reputation for financial integrity and honesty is essential. Fraud is the opposite of honesty. Even when unproven, it can destroy our reputation.

Our Code defines Fraud as follows:

"If you deceive someone by misrepresenting or dishonestly reporting facts to gain an advantage, it's fraud. It is also fraud if you get someone else to do it. Fraud is usually carried out for gain, and it is a very serious crime. In some counties the deception doesn't even have to be deliberate – you can face criminal charges just for carelessly allowing it to happen."

In this case, you are using a company relationship to secure personal advantage, and by lying to the supplier you are defrauding him of the full price of the materials.

This is not acceptable in its own right. But if you subsequently need to engage with the supplier on a work issue – for example, future discounts or contract renewals - your impartiality could be questioned.

We will take appropriate measures, including issuing criminal proceedings, against anyone involved in fraudulent activity.

Of course if the supplier offers you a discount knowing it's for your personal use, that is probably okay, but it's always best to check something like that out.

3. Yes, so long as you're paying personally

Wrong. Pleasey try again.

A colleague's overstating his personal working hours.

Not your business?

1. It's his business and his lookout

Wrong. Please try again.

2. I'd ask him to rectify his "error". If he doesn't I'd have to report him

Right answer because:

We make a promise to all our customers that we will report and record accurately, honestly and transparently and will not falsify records or misrepresent facts.

Falsifying records is fraud, and is an extremely serious offence. It destroys trust in us, and can ruin our reputation for financial integrity and honesty.

That's why our Code insists that we follow all procedures for the recording and reporting of information; ensure our books, records and invoices are accurate, sufficiently detailed and timely; accurately and honestly report performance and expenses; and never make false or misleading statements or submit false claims.

If this colleague is deliberately overstating his hours then he is committing fraud. Either way, he must rectify what he has done, or it's your duty to raise the issue with your manager, Human Resources, or another senior manager.

If you're not comfortable doing that, then use the Serco Ethics Hotline.

We expect you to Speak Up if you think something is not right.

3. I'd have a word with him and tell him to stop

Wrong. Please try again.

Checking the books, you discover a couple of minor errors.

You know the person responsbile. She has been going through a tough time, and pleads with you not to report the matter.

What would you do?

1. It's not acceptable. I'd fire her

Wrong. Please try again.

2. I would need to report it, but I'd assure her she's not in any trouble

Right answer because:

Reporting and recording accurately, honestly and transparently is vital to the integrity of our business.

That's why we have clear, defined and robust controls to ensure all our records, reports and invoices are correct and meet our commercial, legal and regulatory requirements.

We regard any failure to keep complete and accurate records as a serious violation of our Code, whether it directly breaks the law or not.

But mistakes do happen. When they do, we are not seeking to blame or punish anyone, so long as the errors are reported at the first opportunity so they can be corrected. This must always happen.

In this case your colleague has clearly made a mistake because she is going through a tough time. But her concern that you do not report the matter is unfounded. There won't be repercussions, but the small errors do need to be corrected, and it may be necessary to check the rest of her work too.

You must report her mistakes, but you shouldn't feel bad, and you should try to reassure her. We may be able to help her to cope with her troubles.

 

"We will take care to check the record and activities of those we work with. If we are already working with someone we discover is abusing Human Rights, or has done so in the past, we will end the relationship and report the abuse."

 

3. It's just a mistake. I'd put it right and tell no one

Wrong. Please try again.

A colleague asks you to put through some of his receipts on your expenses as he has had a 'big' month and he has been getting some negative comments about his expenses from his boss.

All the receipts are for genuine business expenses.

Anything wrong with doing this?

1. His boss isn't being fair, so this is fair enough

Wrong. Please try again.

2. They're all genuine, and no one is being defrauded. So it's fine

Wrong, Please try again.

3. Yes, they're his expenses, not mine

Right answer because:

Reporting and recording accurately, honestly and transparently is vital to the integrity of our business.

We will not falsify records or misrepresent facts. So we have clear, defined and robust controls to ensure all our records, reports and invoices are correct and meet our commercial, legal and regulatory requirements. And our Code clearly requires that we:

"Never make false or misleading statements or submit false claims."

In this case, putting these expenses through under your name is making a false statement and submitting a false claim.

The fact that the receipts are genuine does not matter as they refer to expenses incurred by a specific individual who should be the only person to claim them.

So if you agree to do this you are both deliberately performing a deception. Anyone doing this will face disciplinary action.

We must all ensure our books, records and financial reporting are complete and accurate.

Dilemma 1

You need some building materials for private use that are sold by a regular Serco supplier. You say they're for Serco so you get the discount but your pay personally.

Is that okay?

1. It may be taking advantage a bit, but it's hardly fraud

Wrong. Please try again.

2. Absolutely not. That would be fraud

Right answer because:

Our reputation for financial integrity and honesty is essential. Fraud is the opposite of honesty. Even when unproven, it can destroy our reputation.

Our Code defines Fraud as follows:

"If you deceive someone by misrepresenting or dishonestly reporting facts to gain an advantage, it's fraud. It is also fraud if you get someone else to do it. Fraud is usually carried out for gain, and it is a very serious crime. In some counties the deception doesn't even have to be deliberate – you can face criminal charges just for carelessly allowing it to happen."

In this case, you are using a company relationship to secure personal advantage, and by lying to the supplier you are defrauding him of the full price of the materials.

This is not acceptable in its own right. But if you subsequently need to engage with the supplier on a work issue – for example, future discounts or contract renewals - your impartiality could be questioned.

We will take appropriate measures, including issuing criminal proceedings, against anyone involved in fraudulent activity.

Of course if the supplier offers you a discount knowing it's for your personal use, that is probably okay, but it's always best to check something like that out.

3. Yes, so long as you're paying personally

Wrong. Pleasey try again.

Dilemma 2

A colleague's overstating his personal working hours.

Not your business?

1. It's his business and his lookout

Wrong. Please try again.

2. I'd ask him to rectify his "error". If he doesn't I'd have to report him

Right answer because:

We make a promise to all our customers that we will report and record accurately, honestly and transparently and will not falsify records or misrepresent facts.

Falsifying records is fraud, and is an extremely serious offence. It destroys trust in us, and can ruin our reputation for financial integrity and honesty.

That's why our Code insists that we follow all procedures for the recording and reporting of information; ensure our books, records and invoices are accurate, sufficiently detailed and timely; accurately and honestly report performance and expenses; and never make false or misleading statements or submit false claims.

If this colleague is deliberately overstating his hours then he is committing fraud. Either way, he must rectify what he has done, or it's your duty to raise the issue with your manager, Human Resources, or another senior manager.

If you're not comfortable doing that, then use the Serco Ethics Hotline.

We expect you to Speak Up if you think something is not right.

3. I'd have a word with him and tell him to stop

Wrong. Please try again.

Dilemma 3

Checking the books, you discover a couple of minor errors.

You know the person responsbile. She has been going through a tough time, and pleads with you not to report the matter.

What would you do?

1. It's not acceptable. I'd fire her

Wrong. Please try again.

2. I would need to report it, but I'd assure her she's not in any trouble

Right answer because:

Reporting and recording accurately, honestly and transparently is vital to the integrity of our business.

That's why we have clear, defined and robust controls to ensure all our records, reports and invoices are correct and meet our commercial, legal and regulatory requirements.

We regard any failure to keep complete and accurate records as a serious violation of our Code, whether it directly breaks the law or not.

But mistakes do happen. When they do, we are not seeking to blame or punish anyone, so long as the errors are reported at the first opportunity so they can be corrected. This must always happen.

In this case your colleague has clearly made a mistake because she is going through a tough time. But her concern that you do not report the matter is unfounded. There won't be repercussions, but the small errors do need to be corrected, and it may be necessary to check the rest of her work too.

You must report her mistakes, but you shouldn't feel bad, and you should try to reassure her. We may be able to help her to cope with her troubles.

 

"We will take care to check the record and activities of those we work with. If we are already working with someone we discover is abusing Human Rights, or has done so in the past, we will end the relationship and report the abuse."

 

3. It's just a mistake. I'd put it right and tell no one

Wrong. Please try again.

Dilemma 4

A colleague asks you to put through some of his receipts on your expenses as he has had a 'big' month and he has been getting some negative comments about his expenses from his boss.

All the receipts are for genuine business expenses.

Anything wrong with doing this?

1. His boss isn't being fair, so this is fair enough

Wrong. Please try again.

2. They're all genuine, and no one is being defrauded. So it's fine

Wrong, Please try again.

3. Yes, they're his expenses, not mine

Right answer because:

Reporting and recording accurately, honestly and transparently is vital to the integrity of our business.

We will not falsify records or misrepresent facts. So we have clear, defined and robust controls to ensure all our records, reports and invoices are correct and meet our commercial, legal and regulatory requirements. And our Code clearly requires that we:

"Never make false or misleading statements or submit false claims."

In this case, putting these expenses through under your name is making a false statement and submitting a false claim.

The fact that the receipts are genuine does not matter as they refer to expenses incurred by a specific individual who should be the only person to claim them.

So if you agree to do this you are both deliberately performing a deception. Anyone doing this will face disciplinary action.

We must all ensure our books, records and financial reporting are complete and accurate.