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January 2020: The following information is shared to prepare for implementation in summer 2020

Case study

  • Date:
  • Category:
    Concern about senior management
    Concern involving fraud
    Serious concern requiring Stage 2 investigation


A secretary for a director of a board is concerned that the director has submitted multiple fraudulent expense claims across the course of the year.  The director has been claiming for travel expenses to meetings which they did not attend.

The director has been open about these indiscretions to the secretary, describing them as “their little secret”.  Therefore, the secretary does not feel that they can challenge the director about it.  They are also concerned about blowing the whistle on a senior employee in case there are repercussions.

The secretary considers reporting the issue directly to the Counter Fraud Service (CFS) as they are experienced in investigating reports of suspected fraud from anonymous sources.  However, they realise this won’t entitle them to the protection offered through the whistleblowing standards.  The secretary decides to approach their confidential contact who logs a stage 2 concern and passes on the information to the board's fraud liaison officer, without sharing any of the secretary's details.  The fraud liaison officer then passes it onto the CFS who open an investigation.  The CFS updates the fraud liaison officer on their progress each month, who in turn feeds this back to the confidential contact to share with the secretary.

At the end of the investigation, the CFS report their findings to the board for them to take appropriate action and the secretary is informed of this outcome.  The stage 2 investigation is now closed and the secretary is informed of their right to approach the INWO if they do not think that this concern has been resolved.

Updated: January 9, 2020