ComplyWith’s supporting role in catching a crook
In early 2017 Harrison was jailed for 3 years and 7 months. The fallout included the resignation of the Auditor-General, reputational damage to the Ministry of Transport and lowering the morale of those that work there.
Fraud by staff, particularly by senior staff, is usually hard to detect. The more senior the fraudster the more opportunity they have to influence detection efforts and cover their tracks. This appears to have been a real feature of the Harrison case.
While fraud cases, especially those involving agencies of the Crown, will always grab the headlines, it's often not revealed how the frauds were carried out and how they were discovered and dealt with. And yet it is in this ‘airing of our dirty laundry’ that the most valuable lessons can be learned and applied.
Good on the Ministry of Transport for proactively releasing many of the internal documents relating to the Harrison case. These are here.
These papers make for some fascinating reading about how the frauds were committed, concealed and covered-up over the course of several years. They also show how the frauds were detected, escalated and, eventually, dealt with.
As you read the papers it becomes evident that the real ‘heroes’ of the Harrison story are the staff and managers in the Ministry’s in-house legal and finance teams that identified and escalated irregularities associated with Harrison.
The papers include copies of compliance reports of compliance surveys undertaken with the ComplyWith tool. These reports played a supporting role in highlighting ‘red flags’ associated with Harrison’s frauds.
In the aftermath of the Harrison frauds Deloitte was asked to undertake a review of the Ministry of Transport’s contracting and payments processes. The report is here. A key finding of the report was:
The Ministry takes compliance seriously. The Ministry utilises an annual compliance survey that is completed by managers and budget holders to reinforce the Ministry’s compliance culture.
Even organisations that take compliance seriously are not immune to fraud. The Harrison saga reinforces that good compliance does not happen by accident and there is always more that can be done.
It’s not necessarily going to be a case of compliance monitoring actually detecting criminal behaviour. Compliance monitoring helps build a culture of ‘doing the right thing’ and this is key to maintaining high standards and rooting out criminal behaviour.
If you’d like to find out more about how ComplyWith can help drive a culture of doing the right thing, including how it can be used with internal control policies and procedures, please drop us a line.