Remote working: Tackling timesheet fraud

With potentially the entire workforce logging on from home, many organisations will worry about timesheet fraud and consider electronic monitoring solutions. But this could be an own goal. More holistic, behavioural approaches may be a better way to both prevent fraud, and support staff.

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I remember when ‘working from home’ was seen as a bit of a jolly, and greeted with wry smiles from colleagues. Now in the wake of COVID-19 it looks set to become the norm, at least for a while. Employers may worry about employees misrepresenting their time, and wonder whether they need to heighten monitoring through computers and smartphones.

There is a place for these kinds of technologies. Certain types of electronic monitoring can be prudent for certain types of work. But for many organisations – especially those new to remote working at scale – this could turn out to be a mistake. There are better ways for organisations to protect productivity and support their teams during crises like this.

Humans, not machines

MotivationThe fraud triangle, based on the work of Donald Cressey, is so robust we’re still using it 70 years after it first appeared. In this model of dishonest behaviour, a key component of fraud is rationalisation – the way that we make ourselves comfortable with what we want to do.

When I open my casebook of internal fraud investigations, a rationalisation that crops up repeatedly is the perpetrator’s sense that the organisation has wronged them – that the fraud would be retribution, justice, rebalancing the scales.

This is important. If an organisation adopts intrusive methods that leave employees feeling devalued and untrusted, then this can open up the possibility of that rationalisation. Combine that with financial or logistical pressure generated by the COVID-19 crisis (motivation) and the clear opportunity, and the fraud triangle is complete.

Instead, we need to think more broadly about the impact of home-working on fraud, and more carefully about human factors, before we jump to thinking about controls.

Start with a new fraud risk assessment

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Sending the workforce home is a major change of circumstances – one big enough to affect your organisation’s internal fraud risk profile. Risks beyond timesheet fraud will be affected. For example:

  • What could be the effect on expenses fraud?
  • Will the rise in e-mail and online communication heighten vulnerability to cyber, data security, and privacy threats?
  • If a health and safety assessment hasn’t been carried out on a person’s home workstation, is there a risk of false claims for which organisations may be unable to defend themselves in some jurisdictions?

It’s time for a new fraud and corruption risk assessment.

Taking a human-centric approach

16404-a-woman-in-a-business-meeting-pvWith the risk assessment providing a clear picture of what could go wrong, there may be places in which technology can help. But there are others in which we need to think about humans.

In a time where our people feel frightened and stretched, it is nurturing, caring leadership that will both support them and help to prevent and detect fraud. It’s not only possible to do both, but vital. Managers are the key controls. In retail, smiling as a customer enters can make them feel welcome – and deter shoplifters by showing they’ve been noticed. The principle is the same here. Good day-to-day remote management of employees leaves them feeling empowered and enabled, but also helps to deter, prevent and detect internal fraud.

For example:

  • Train and develop managers in the potentially new task of supportive remote leadership;
  • Create nurturing, mutually-problem solving relationships within teams, reducing the likelihood that people will feel the need to hide things (which can help to generate the right conditions for fraud);
  • Consider online collaboration platforms. Some have amazing functionality to improve connections between remote workers, which also helps to preserve accountability;
  • Provide managers with clear guidance on fraud red flags.

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At the corporate level, review HR policies from an anti-fraud perspective. For example, flexible working is also about time, not just location. Business closures means that employees may now have to balance caring for children and the elderly, and seizing sudden opportunities to buy essentials, with their work-day. A flexi-time policy is a great way to prevent employees misrepresenting their work hours. Have an anti-fraud specialist examine your policies.

Meanwhile, with your employees now physically disconnected from the social norms, cues and wider internal culture that helps to regulate their behaviour, reassess how you will manage internal culture. How will you shape how employees think, feel and act in line with an anti-fraud culture when they’re not in your building? Now might be the time to step up behaviour-shaping online materials, and anti-fraud communication and awareness initiatives.

volkswagen-569315_1920There are a surprising number of organisations that already embrace remote working, especially in the humanitarian and global development sector. Reach out for advice. How are they managing the risks? What has worked and what hasn’t for them?

Finally, manage your own cognitive errors, biases and heuristics. Fraud and corruption love availability bias, for example, the phenomenon in which we focus on the most visibly present issues and risks. Because fraud hides and masquerades, that bias allows it to shuffle off into the darkness. Don’t let that happen. Fraud is agile and will already be adapting to this new world, you need to think about how your organisational efforts to deter, prevent, detect and respond to it will too.

Towards organisational health

Some employee monitoring solutions – especially those at the leading edge – are exciting, minimally intrusive and potentially very useful. But organisations should take care not to panic-buy. Just as with COVID-19, fighting the virus that is fraud starts with careful, risk-based preparation.

Did you find this article useful? Why not check out Oliver May’s books on tackling fraud and corruption?

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Fraud and corruption: 10 tips for obtaining buy-in from your NGO’s Board

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The Commonwealth corruption conference and anti-corruption summit in London last week saw the full engagement of civil society. Leaders from big household name NGOs were active online and in person, taking the opportunity to challenge a range of related injustices. It was exciting and encouraging, but these events should prompt those NGOs to ask themselves, ‘how effective are our own organisational counter-fraud and corruption frameworks?’ If the question needed underlining, we also learned that the US government is investigating allegations of corruption affecting NGOs in the Syria emergency response.

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US humanitarian aid bound for Syria

What Boards need to do in order to reduce fraud and corruption risk is well-trodden ground. But for international NGOs, one of the great challenges can, in fact, be the Board. As your organisation’s counter-fraud lead, what do you do if members of your Board don’t recognise that fraud and corruption is a problem? Or merely give it lip service, unwilling to invest in meaningful risk reduction efforts? Or worse, are content to turn a blind eye to the risk of physical assets, funds and stock falling into the wrong hands if most aid gets through?

Obtaining the buy-in of an NGO’s Board isn’t about selling them a product – we need their ongoing support and ownership. It’s about changing perspectives; a long haul, not a quick win. So, in helping to generate that ongoing support, I’ve found that these tips (which are not exhaustive and in no particular order) have assisted my colleagues and I; perhaps they might help you too.

1. Educate to effectuate

apple-256261_1920Fraud and corruption has, historically, not been well understood in this sector. Your Board may have a low or rudimentary understanding of the risk and how to respond to it. This means starting at a basic level, making no assumptions, taking the time to address myths and misconceptions and playing a longer game. ‘Educate as you go,’ Willie Oelofse from Deloitte Kenya told NGOs at a conference in January. As we do so, of course, it’s important to remember that counter-fraud is a good news topic – your organisation may be at high risk, but actually there’s a lot that can be done to reduce it. Boardrooms are learning environments too.

2. Keep it simple

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Board members are busy. NGOs (especially humanitarian agencies) are often very responsive, and Board members’ attention is divided between competing thematic risk areas and arising issues. Use your time with them wisely. Proposal documents and assessments, for example, should be short or with executive summaries. Don’t bury key messages in a risk assessment document the size of a telephone directory.

3. Speak from within

people-men-grass-sportCivil society is under attack the world over, and the issue of their fraud and corruption exposure can be something that sends Board members running for their shields and helmets  – especially if it is perceived to come from an out-group rather than in-group. Take charge of how the matter is framed. Don’t let them entrench in defensive positions to ‘fend off’ your ‘attack,’ or sit in a ‘prospective client’ chair to listen to you ‘pitch’. Instead, use their business language, show your understanding of the difficulties they face, and speak from inside their group. Explain the landscape around them, and how you can help them navigate across it.

4. Remember that they’re individuals

colored-pencils-179167_1920People make decisions differently and on the basis of different values. For example, I am a big fan of the MBTI, which is one of a range of models that can help us to understand how we like to work and how best to relate to others. Models like these can really help to improve workplace relationships. So try to understand each member of your Board as a person, and what really drives their decisions. Some will be persuaded by cold, hard data, others by less tangible matters such as how your agenda relates to values, supports people, and so on.

5. Bring the risk to life

DSC06922Fraud and corruption, especially at a strategic level, can be abstract concepts. Help the Board to connect by painting a picture of the risk with case studies. If you don’t have any in your own organisation, then perhaps partners, donors or other organisations have some they will let you use? If not, then find cases in the public space affecting comparable organisations. If you’re really struggling, consider using fictional examples – but remember to state that they’re fictional!

6. Show the benefits

cost-benefit-analysisNGO Boards are often allergic to anything with a whiff of extra expense, especially if it is ‘overhead’ or ‘administration’ flavoured. So explain the benefits of the agenda not just in terms of what it prevents, but also what it gains – efficiency, effectiveness, quality improvement, and so on. Much of counter-fraud work synergises with good management (an example arises from the world of retail – smiling as a customer enters not only deters shoplifting by making the individual feel noticed, but is also good customer service!).

7. Take an evidence-based approach

evidenceNGO Boards manage a lot of risks, only some of which materialize. Using evidence helps them to appreciate how fraud and corruption sits, whether that evidence is perception-based, representative sampled, or from other diverse sources. Cast the evidence net wide – consider staff surveys (especially anonymous surveys), risk assessments, project and programme evaluations, audit reports, security reports, academic research and open source. This may mean that you need to start by improving the detection of incidents, in order to gather enough material. Be cautious with the use of quantification estimates, as these can be inherently open to challenge by those feeling resistant, and with over-stating the case (being debunked seriously damages credibility). Remember to cater for any risks created by the counter-fraud agenda, and to consider any donor or legal obligations.

8. Align with organisational objectives and strategy

marketing-board-strategyJust as is the case with private and public sector organisations, the counter-fraud agenda needs to directly support the organisation’s mission. This needs to be clearly elucidated so that Boards can see that counter-fraud is a mainstream activity, rather than a distraction.

9. Obtain a sponsor

hands-people-woman-meetingIn March’s Charity Finance magazine,  I explained why fraud and corruption needs to be a standing priority for NGO Boards. But in addition to this, the counter-fraud agenda needs a champion at Board level. Benefits of this include how the champion can look out for synergies with other business areas as they’re discussed.

10. Put in the legwork

Startup Stock PhotosA ten-minute agenda item at a Board meeting is not enough to ensure that a Board truly embraces counter-fraud and corruption. Obtain regular meetings with each member to explore their own position and build their buy-in – especially before key decisions are to be made. Similarly, the counter-fraud agenda needs to align not just to the organisation’s mission but to the agendas of those individual Board members. How does countering fraud help, not hinder, the aims of the person in front of you?

11. Bonus tip!

Why not get the members of your Board a copy of Fighting Fraud and Corruption in the Humanitarian and Global Development Sector? It explains the risk, busts myths and misconceptions, and sets out ways for NGOs to minimise the risk. It’s out now with by Routledge, pick up a hardback or e-reader copy via the Routledge website or Amazon!

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