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Accurate records, reporting and accounting

We always maintain accurate records, reports and accounts

What it's all about

We must all ensure our books and records are accurate.  This will help us understand how we are performing and ensure we are doing things right.  If we’re not accurate, we can be accused of fraud. 

Even if it’s unproven, an accusation of trying to commit fraud by misreporting or falsifying records or accounts can destroy our reputation for financial integrity and honesty. 

If that happens, we can lose the trust we depend on to carry on doing business. 

That’s why we have detailed procedures for the recording and reporting of information, and robust financial controls that we must all follow – so there can be no doubt that our books and records always accurately reflect the true state of our business, our costs and our transactions. 

These procedures also ensure that we follow all the applicable laws and regulations that govern financial accounting and how we must report to customers, government agencies, investors, and the public.

Fraud and scams are on the increase and organisations are facing increasing threat on three fronts:

  • Organised crime – cross-border criminal activities are becoming more sophisticated.

  • Cyber fraud – theft of business identity and confidential [digital] information.

  • Its own employees – from petty theft to infringement of intellectual property.

When people set out to defraud companies, they’re almost always trying to get hold of money, goods and trade secrets. 

They can cause terrible harm. A single successful scam can destroy a company, deprive employees of their pensions, or cost investors billions. 

That’s not all. Fraud can damage public services, put less financially stable companies out of business, cause people to lose their jobs – and even undermine society. 

Keeping our books, records and financial reporting complete and accurate is our best defence against fraud.

“If we keep everything up to date and check it’s accurate, that’s the best way to check how we are doing and protect us against unusual or fraudulent activity.”

What we all need to know and do

  • If we are involved in any way in recording and reporting of information (both internally or externally), or performing a financial control, it’s our job to make sure we do it with care and diligence. 

    We do that by knowing our company procedures and always following them.

  • Where we operate controls, we must be able to demonstrate that they are effective and will stand up to scrutiny from any internal or external review.

  • We must ensure that invoices we send to our customers include accurate information, and we have the supporting documentation to support the goods and services which we are billing for.

  • All of us, wherever we work and whatever job we do, must accurately and honestly report our performance, time and expenses.

    We never make false or misleading statements or submit false claims. 

  • If we need to claim travel expenses, we need to keep proper records and receipts so we can submit these with our claim.

  • We never get involved in any activity that is designed to commit fraud or misrepresentation, or that could be reasonably interpreted as an attempt to do so.

  • If we think or just suspect that fraud may be going on, we always Speak Up.

  • Despite our best efforts, we all make mistake sometimes. So if we discover that any of our records aren’t accurate because of an error, it’s so important to report it at once. That way the mistake can be put right hopefully before any damage has been done.

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We had a long-standing contract with a customer. It was a great relationship and very valuable to us too.

We’d been invoicing them in the same for a while. So the check my colleague and I made that day was just routine. What we discovered horrified us both. On a number of key rates we’d been overcharging the client. And we’d been doing it for the past 18 months!

I have to be honest – when we first discovered it, we did have a conversation about whether we should report it or just keep quiet. What we were both particularly concerned about was the damage this might do when we told the client. Overcharging was a serious offence and this had been going on for some time. 

The second thought was that we should have an internal investigation first – before telling the client anything. But in the end we both decided that we just had to be totally transparent and honest, and let them know straight away. So that’s what we did. 

Not surprisingly the client was shocked and pretty angry to begin with. But I think it was because we were so open with them, sharing all the details and all aspects of our investigation, that things quickly calmed down. 

Eventually we discovered that it had been a genuine mistake – we were passing on the old high rates that had been lowered when our contract had been extended. No one on our side or their side had noticed because those involved in doing the invoicing didn’t know about the changes, so to them everything looked just the same as it had always been.

But that was no excuse – we’d failed to communicate properly, and we’d failed to thoroughly check. 

Fortunately, the whole investigation actually helped our relationship in the end. We were awarded more business with them, and our client said that they trusted us even more because we had been so honest and open with them. 

I’m so glad that we chose to do the right thing and report things straight away – I hate to think what might have happened if we hadn’t. 

Despite our best efforts, we all make mistakes sometimes. So if we discover that any of our records aren’t accurate because of an error, it’s so important to report it at once.
 
That way the mistake can be put right hopefully before any damage has been done.

When it all came out, it was like something out of a movie. But it really happened. 

We’d been awarded a very large project, and one of principal reasons was our promise to deliver within a four year period. One of the keys was to ensure we had a lot of skilled labour. This was in a part of the world where you need to take a lot of care in who you appoint, so after an extensive vetting process we went with one supplier. 

From that moment on everything went smoothly and three and half years in we were so far ahead of schedule that we were going to finish with three months to spare.  That was good for us as we’d agreed a bonus for early completion. 

One of our clients was a prominent individual in the government. He was a very wealthy man. He’d often turn up at a moment’s notice in his big chauffeur driven car to check on our progress. So we’d scramble to receive him, he’d ask what were usually very intelligent questions, request to see a particular aspect of the project, and then leave. The last time he’d done it, he’d smiled and said, ‘We shall be delighted to pay you your bonus.’

A couple of weeks after that I thought I’d start to get all the accounts and records in order. I took a look at the paperwork and invoices we’d received for all the labour we’d hired, it all looked in order and had clearly been checked by the supply chain manager. So I don’t really know what made me think, ‘Perhaps I’d just better check that we’ve actually been using this number of workers.’

Well, what I discovered totally surprised me. We hadn’t just been paying for labour we never received, but for a whole raft of services that hadn’t been provided. It amounted to an enormous sum of money. I just couldn’t believe it, particularly not of this supplier who as I say had worked so tirelessly to keep us on track. 

We got him into the office and confronted him. He burst into tears and then the whole story came out. At the start of the project the wealthy individual who visited us in his chauffeur driven car had got hold of him and threatened that unless he did exactly what he was told he and his family would have a nasty accident. So the supplier had been passing on all this extra money. 

We called in the police. For a while it seemed that the individual in question would be supported by the government and was going to get away with it. But then there was a new crackdown on corruption, and they clearly decided to make an example of him. 

Turned out that he was into all sorts of nasty stuff – including prostitution and people smuggling. And the money we had been fraudulently invoiced was paying for some of it. 

If our job involves preparing or maintain accounting records of any kind, then we must know and follow the Group Financial Controls Manual and our other financial processes.

We’d been really stretched. Most of us were working extra hours, but there’d been a lot of sickness, and we just couldn’t do all the things we were supposed to.

So we got together and worked out what we could skip, or do on alternate days, so we could still do the important things. 

I think that went on for around three months. And then Ira – she does all the books – came in wanting to know about something that wasn’t making sense. 

No wonder they didn’t. Gene had been filling in the check lists, and had marked as “done” loads of stuff we weren’t doing. All his reports were just totally fake. ‘It’s just till we’re back to normal,’ he said. ‘You want risk us losing this contract?’

It was an interesting moment. There were some on the team who were really shocked, but there were others who tried to defend Gene, talked about how hard we’d all worked and it wasn’t our fault, we were doing our best and why not just let it go. 

It was Ira who settled things. ‘I am not a dishonest person,’ she said, ‘and I don’t want to work for a dishonest company. Gene, please correct these records and have them on my desk before the end of the day.’ 

With that she went out. Nobody said much, but I think we all knew that if Gene didn’t put things right, Ira would. So of course he did.

I guess that’s the power of one person standing up against something that isn’t right. 

We never get involved in any activity that is designed to commit fraud or misrepresentation, or that could be reasonably interpreted as an attempt to do so.

One of my colleagues asked if she could have a word. We went somewhere quiet, and she told me she’d discovered something and wasn’t sure what to do.

It turned out that she’d found someone she worked with was fiddling his expenses. 

She told me they were quite friendly, and recently he confided to her that he was having a hard time with his father who had vascular dementia, but even so, it was quite a lot of money.
 
‘I know it’s a strange thing to say,’ she said, ‘but if I were to report him, it would feel like a breach of trust.’

I knew exactly what she meant. Sometimes doing the right thing feels wrong. And when you’ve got two loyalties – to the company and to a valued colleague - it can tear you apart. 

Anyway, I said I’d talk to him. I told him that it looked like he’d made a mistake in calculating his expenses, but I was sure he’d take a look and put it right – pay any money back if that’s what was required. 

He burst into tears, said he was sorry, and promised he’d sort it out.

Luckily he did, as I would have had to report him otherwise. 

All of us, wherever we work and whatever job we do, must accurately and honestly report our performance, time and expenses.

We never make false or misleading statements or submit false claims.

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Bribery and corruption

We never take or offer any kind of bribe.

Gifts and hospitality

We always check before giving or receiving any gift or hospitality.

Conflicts of interest

We always declare any potential conflict of interest. If we’re not sure, we ask.

Working with communities

We support and respect the communities we work among.

Political activities and payments

We keep our relationships with government honest.

Competition and antitrust

We always compete fairly and openly.

Working with others

We deal fairly and honestly with suppliers, strategic partners and agents, and expect the same of them. 

Trade sanctions and export controls

We take care to know and follow the rules.

Tax evasion

We never do it, or help anyone else to.

Money laundering

We will not take part in any money laundering activity, and do all we can to stop it.

Insider trading

Never use inside information for insider trading – it’s a serious crime.