Every organisation I’ve ever investigated had a fraud policy. Most had a code of conduct. Many had an ethics hotline. And still, fraud occurred — sometimes for years before discovery.
The policy document is not the problem. The culture is. Specifically, the gap between what the policy says and what leadership actually models.
Tone at the Top — It’s Not a Cliché
When senior management circumvents procurement processes “just this once,” when expenses are submitted that everyone knows push the limits, when the high performer is protected from consequences — the message sent to every employee is louder than any policy.
What Actually Works
- Regular, honest communication about fraud risks — not just compliance tick-boxes.
- Anonymous reporting channels with visible follow-through (people need to see that reports matter).
- Fraud awareness training that uses real case studies, not abstract scenarios.
- Consistent consequence management — the same rules for everyone, regardless of seniority.
- Internal audit that is genuinely independent and empowered to act.
Building fraud resistance is a long-term commitment, not a project. I help organisations develop anti-fraud programmes that are practical, proportionate, and genuinely effective — not just compliant on paper.