Emigrant Support Programme Counter-Fraud Statement

The Department of Foreign Affairs and Trade has a zero tolerance towards fraud and has in place policies and procedures for prevention, detection and dealing with instances of fraud or suspected fraud. This Emigrant Support Programme counter-fraud statement is drawn from the Department’s counter-fraud policy which is available on request and is the Department’s comprehensive and authoritative Counter Fraud policy.

The Department’s counter-fraud policy extends to recipients of grants awarded by the Department and all organisations in receipt of Emigrant Support Programme funding will be bound by this policy.

It is the Department’s policy to seek to prevent fraud and, as such, it adopts a zero tolerance to fraud and will fully investigate any incidents of fraud or suspected fraud. The key principles underlying the Department’s approach to minimising the risk, and addressing instances, of fraud are:

• A risk management approach to the prevention of fraud is adopted which is incorporated into its business processes, management practices, grant management processes, internal controls and related activities;
• The relevant authorities are notified and prosecution is sought where appropriate, or other suitable sanctions are taken, against those who have committed fraud;
• The recovery of misappropriated funds or assets is sought;
• All cases of fraud will be handled and investigated in a confidential, prompt and professional manner;
• Protecting those who in good faith report instances of suspected fraud;
• Maintain the principles of confidentiality in any investigation of fraud;
• Making available confidential and appropriate reporting mechanisms so that anyone, in good faith, can report genuine concerns;
• Fully respecting the principles of due process and natural justice, pursue perpetrators to the fullest extent of the law.

Where fraud is suspected in an organisation supported by the Emigrant Support Programme it should immediately be reported to:

(a)    The board of the organisation affected; and

(b)   The Irish Embassy, Consulate or Unit that the affected organisation liaises with on the Emigrant Support Programme.

Fraud or suspected fraud affecting an organisation in receipt of Emigrant Support Programme should be reported even if the fraud itself is not directly linked to Emigrant Support Programme funding.

The Department broadly defines fraud as an intentional act of deceit to obtain an unjust/illegal advantage. Fraud shall include but is not limited to:

• Misappropriation, deception, bribery, forgery, extortion, blackmail, corruption, theft, conspiracy, embezzlement, extortion, false representation, alteration of negotiable instruments (such as cheques), falsification of accounting records or financial reports, or concealment of material facts and collusion;
• Theft or misappropriation of assets (including documents and information) owned or managed by the Department;
• Submitting false claims for payments or reimbursements;
• Accepting or offering a bribe or accepting gifts or other favours under circumstances that might lead to the inference that the gift or favour was intended to influence an employee’s decision making while serving the Department;
• Conflicts of interest;
• Abuse of Power;
• “Off the books” accounting, or making false or fictitious entries;
• Knowingly creating and/or distributing false or misleading financial reports;
• Paying of excessive prices or fees where justification thereof is not documented;
• Violation of the Department’s procedures with the aim of personal gain or to the detriment of the Department;
• Wilful negligence intended to cause damage to the material interests of the Department;
• A dishonourable or reckless or deliberate act against the interests of the Department;
• Dishonestly obtaining a benefit or causing a loss, by deception or other means;
• Any acts where improper benefit is gained or loss to the Department arises, both tangible (e.g. misappropriated funds, theft of assets, etc.) and intangible (e.g. falsification of documents, improper use of the Department’s assets, concealment of material facts, false pretence, etc.);
• Any acts or omissions designed to obtain or to seek to obtain any official documents fraudulently or not in accordance with the policy, procedures and rules of the Department or Irish legislation, including but not limited to, passports, visas, other travel documents, consular documents, etc.
• Specific instances of offences as defined in the Passports Act 2008

Irish Abroad Unit

Department of Foreign Affairs and Trade

30 January 2018