Fraud prevention
We always act honestly and never commit fraud
What it’s all about
Fraud is when someone lies, deceives, deliberately misrepresents or is dishonest to make a gain for themselves or someone else or to cause someone else a loss. It’s a serious crime and can lead to criminal liability for individuals and the company.
At Serco, we never engage in any activity that is, or could be seen as, fraud.
There are many types of fraud including misrepresentation, false accounting, falsifying documents, making false statements, theft, greenwashing and abusing your position. Underlying all these is deliberate dishonesty.
Having the right culture, living our Values and acting with integrity in everything we do is important for preventing fraud.
If someone working for Serco (like an employee, director, agent) or providing services for us or on our behalf (for example, a contractor or partner we outsourced services to) commits fraud and we didn’t have proper checks in place to stop it, Serco could also face criminal prosecution for failure to prevent fraud.
That’s why we all need to stay alert, report concerns, and help stop fraud before it happens.
Examples of activities that could be fraud include:
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deliberately over-charging a customer for time, materials or expenses
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falsifying timesheets or inflating hours worked
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dishonestly claiming we have done something that we have not
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knowingly giving false information to a customer, supplier or the market
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hiding your relationship to a person or business employed by Serco and using your position to benefit them
Red Flags to look out for:
Recognising red flags early can help us stop fraud before it causes harm. While the presence of red flags doesn't mean that fraud is being committed, understanding, recognizing and reporting red flags can help us detect fraud and mitigate losses. Below are some examples of behaviours and transactions that could indicate fraud risk.
Behavioural
Certain behaviours or changes in how someone acts can be signs that something may be wrong. Look out for:
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Living beyond their means: Showing signs of wealth that don’t match their role or known income.
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Financial pressure: Struggling with personal money problems, debts or sudden lifestyle changes can drive someone to commit fraud.
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Unusually close relationships with a customer or supplier: This could suggest a conflict of interest or collusion.
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Not willing to share duties: Being overly controlling, secretive, or refusing to delegate tasks.
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Irritable, defensive, or suspicious behaviour: Behavioural changes or aggressive reactions when questioned.
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A “wheeler-dealer” attitude: Acting unethically, pushing ethical boundaries, or treating business dealings like a game.
Transactional
Fraud also leaves clues in how payments, contracts, or financial records are handled. Look out for:
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Changes to bank account details, especially if not explained.
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Requests for payments to unexpected or unfamiliar locations, such as a payment location different to the location where services are provided.
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Invoices or contracts that don’t match work completed or are missing details or supporting documents.
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Duplicate payments or unusually large payments.
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Payments split into smaller amounts to avoid approval thresholds.
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Payments made at the last minute or rushed through.
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Customers, suppliers, or employees refusing to provide proper ID or documentation.
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Claims or expenses that seem too high, or don’t match receipts.
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Assets (like equipment or supplies) going missing or used for personal reasons.
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Doing business with friends or family without approval.
What we all need to know and do
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We comply with all laws prohibiting fraud and our Fraud Prevention Policy.
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Always be honest and accurate in your work – including reporting, record-keeping, claims, payments, and communications.
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We never lie, mislead, or hide information to benefit ourselves, our company, our customer or others.
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We never falsify or manipulate documents – including invoices, timesheets, expenses, reports, or audit trails.
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We never bypass or ignore checks, controls, or approval processes.
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We never accept or approve suspicious transactions without proper evidence.
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We protect company resources – including money, time, data, and materials.
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Follow all processes, policies, approvals, and operating controls that apply to your role.
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Stay alert to fraud risks and red flags – in your own work, and in the behaviour of others – such as irregular transactions, missing documentation, or suspicious behaviour.
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Promptly report to your line manager, HR, Legal, Ethics & Compliance or Speak Up system if you see or suspect fraud, dishonesty, or anything that doesn’t feel right.
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Complete all assigned training in relation to fraud compliance, prevention or detection.
Storybox
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.
He was a brilliant accountant and such a nice guy. He had real expertise in the complexities of international financial laws. If there was something you didn’t understand or any problem you had, and you could go to him and he’d work out a solution. We all felt very lucky that he was on our team. As someone said, ‘He’s such a gentleman.’
For a while we’d all been working around COVID, and were only gradually coming back to the office. Tuesdays was the day I went in. He was there, and a few others. It was one of those days when it’s quiet – people aren’t really talking much, just working. So we all heard the great crashing sound in reception.
A couple of people rushed out to the stairwell to look. Then they were walking backwards through the doors with their hands in the air – and a moment later three armed men came through pointing guns. I thought they were terrorists. But they weren’t – they were police.
The next few hours were frightening. We were all put in vans and take down to the police station. They separated us. I was put in cell that smelt so much of bleach I kept coughing – and wondering what on earth was happening.
After about three hours they came for me. I was taken to an interview room. There was a recorder there, the interviewer and someone in a jacket. They asked me over and over what I knew about our accountant and I just kept telling them that he was great and really good at his job.
He certainly was. It turns out that he’d been moonlighting for a very important client – helping them to evade the tax they owed not just in this country but across the region.
I kept repeating that none of us knew and our company wasn’t involved in anyway. But because he’d used our systems to encrypt and transfer files across borders, we were implicated. I remember the interviewer leaning forward, looking straight into my eyes and saying, ‘If we find anything that tells us a different story, let me make it very clear – you will go to prison, along with your colleagues. And your company will be finished here.’
Fortunately for us the accountant admitted everything, and was very thorough in the way he showed them how he had worked entirely alone. I suppose in that sense at least he was a gentleman - though whether that helped him in prison isn’t something I want to think about.
Evading tax is essentially fraud – it defrauds society.
That’s why it is such a serious criminal offence, and why there are severe penalties for anyone caught trying to evade tax.
We never evade tax at Serco.
We’d just won a new contract. It was big news. So we all went out to celebrate, and some of us went on to a club.
The others were dancing. Nia had had too much to drink. So had I. We were sitting in one of those banquettes – you know, where you don’t have to shout over the music. I was talking about how fantastic it was – at last we had a real foothold in a market we’d struggled to get into, and now there were all sorts of possibilities.
‘Yes,’ she said, ‘and we’ll soon make the money back.’
Then she put her hand over her mouth and giggled. ‘Oops! Shouldn’t have said that.’
I asked her what she meant – it didn’t even occur to me what she’d actually say. Like I said, we’d had too much to drink.
‘You know, Michael made sure we’d win.’
‘How?’
‘How do you think?’ And she held up her fingers and thumb and rubbed them together.
I think it was then that I started to sober up.
‘What are you saying? He … paid someone?’
‘Of course.’
‘How much?’
‘A lot. Enough.’
Everyone came back from the dance floor then. Michael was trying to tell some funny story above the noise. Then he saw me looking at him and glanced at Nia. I think he knew then.
I didn’t do anything. I thought I’d just be making trouble for everyone, and it was best just to forget about it.
But then one of the directors of the government department we’d got the job with was arrested, and in the end it all came tumbling out.
I hadn’t been involved in Michael’s dirty deal, but I had known, and I hadn’t said anything. So that made me part of it.
I lost my job, along with the others. For months I thought that was unfair. But I don’t anymore. If you know there’s a rotten apple in the barrel you have to take it out. Otherwise the rot goes right through.
If any of us are caught giving or taking a bribe, we’ll probably face dismissal, the end of our careers and very possibly a prison sentence.
But we’ll also do so much harm to our colleagues and to Serco.
Discover more...
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.
Accurate records, reporting and accounting
We always maintain accurate records, reports and accounts.
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.