Description

Fraud and Corruption Policy Template Pack for FSPs

The Fraud and Corruption Policy Template Pack is an editable downloadable document designed for authorised Financial Services Providers that need a practical policy for preventing, detecting, reporting, investigating and responding to fraud, corruption, bribery, dishonesty and unethical conduct.

This Fraud and Corruption Policy pack helps an FSP set clear conduct expectations for directors, Key Individuals, representatives, employees, contractors, consultants and service providers. It also includes practical annexures that support interest declarations, gifts registers, fraud incident reporting, investigation controls and corrective action tracking.

For related compliance templates, you may also view our Conflict of Interest Management Policy Template, FAIS Debarment Policy and Procedure Pack and Representative Appointment Compliance Pack.

For official regulatory information, you can also visit the FSCA regulated entities page.

What Is Included In This Fraud and Corruption Policy Pack?

This template pack is designed to help FSPs document a clear zero-tolerance approach to fraud, corruption, bribery, dishonesty, unethical conduct and abuse of position.

The policy includes sections for:

• Document control and approval details
• Introduction and purpose of the policy
• Legislative and regulatory framework
• Key definitions, including fraud, corruption, conflict of interest and gratification
• Zero-tolerance statement
• Scope of application
• Governance and responsibilities
• Unacceptable conduct
• Fraud, dishonesty and misrepresentation controls
• Theft, abuse or misappropriation of assets
• Premium diversion or client fund abuse
• Bribery and improper benefits
• Conflicts of interest
• Unauthorised outside employment
• Abuse of confidential information
• Declaration of interests
• Registers of interests
• Gifts, incentives and hospitality controls
• Reporting fraud, corruption and irregular conduct
• Protection against retaliation
• What not to do when fraud or corruption is suspected
• Investigation and response process
• Fraud awareness and training
• Recordkeeping requirements
• Consequences of non-compliance
• Policy review and approval

Fraud and Corruption Policy Annexures Included

The Fraud and Corruption Policy Pack includes practical annexures that help the FSP move from policy wording to evidence-based implementation.

The annexures include:

• Annexure A: Policy Acknowledgement and Undertaking
• Annexure B: Disclosure of Interest Form
• Annexure C: Register of Interests Template
• Annexure D: Gifts and Non-Cash Incentives Register
• Annexure E: Fraud and Corruption Incident Report Form
• Annexure F: Fraud and Corruption Incident Register
• Annexure G: Investigation and Evidence Control Checklist
• Annexure H: Corrective Action Register
• Annexure I: Annual Declaration of Interest Form

Why FSPs Need a Fraud and Corruption Policy

Fraud and corruption can create serious harm for an FSP, its clients, product suppliers, employees, representatives and the wider financial services industry. The risk is not limited to direct financial loss. It can also lead to client harm, reputational damage, regulatory scrutiny, litigation, debarment proceedings, criminal complaints and loss of trust.

A written Fraud and Corruption Policy helps the FSP show that it has adopted a clear approach to preventing and responding to dishonest or unethical conduct. It also gives staff and representatives practical guidance on what must be reported, what must be declared and what must not be done when fraud or corruption is suspected.

This template helps address common weaknesses such as:

• No written fraud and corruption prevention policy
• No clear zero-tolerance statement
• No formal interest declaration process
• No gifts and incentives register
• No incident report form for suspected fraud or corruption
• No incident register to track reported matters
• No investigation and evidence control checklist
• No corrective action register after incidents
• No annual declaration of interest form
• No clear guidance on what employees and representatives must not do when fraud is suspected

Interest Declarations and Gifts Registers

The pack includes a disclosure of interest form and register of interests template. These documents help the FSP record business interests, directorships, shareholding, family relationships, intimate relationships, outside employment, supplier relationships, referral arrangements and other interests that may create an actual, potential or perceived conflict.

The gifts and non-cash incentives register helps the FSP record gifts, benefits, hospitality, sponsorships, incentives or other advantages offered, accepted, declined or returned.

Fraud Incident Reporting and Investigation Tools

The Fraud and Corruption Policy Pack includes a fraud and corruption incident report form that can be used for actual, suspected or attempted fraud, corruption, bribery, theft, conflict of interest, misuse of information, premium diversion or other serious irregular conduct.

The investigation and evidence control checklist helps the FSP preserve documents, emails, files, recordings, system logs and other evidence while managing confidentiality and procedural fairness.

Who Should Use This Fraud and Corruption Policy Pack?

• Authorised Financial Services Providers
• Key Individuals responsible for conduct oversight
• FSPs with representatives or employees
• FSPs using consultants, contractors or outsourced service providers
• Compliance officers assisting FSPs
• Managers responsible for ethics, governance or incident response
• FSPs strengthening fraud, corruption and conflict-of-interest controls

Editable and Customisable FSP Policy Template

This Fraud and Corruption Policy Pack is editable and must be customised before use. The FSP must insert its name, FSP number, policy owner, approver, reporting channels, responsible persons, review process and evidence storage location.

The template includes placeholders that should be completed before the final policy is approved and issued to staff, representatives and relevant service providers.

Important Compliance Note

This Fraud and Corruption Policy Pack is a compliance support document. It does not replace legal advice, labour advice, forensic investigation support, disciplinary advice, FIC reporting guidance, FSCA reporting guidance or a case-specific fraud investigation. Each FSP remains responsible for ensuring that the final policy is accurate, implemented, reviewed and aligned with its actual business model, risk exposure and regulatory obligations.