In Dreams Begin Responsibilities:
Delmore Schwartz
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Employee Fraud – Way Forward from
Organizational Perspective
Corporate frauds or white collar
frauds are not committed by professional criminals but well-educated employees
who know that committing frauds can damage their reputation and destroy/limit
career options. While a few recent cases have gained media attention due to the
huge sums, almost all financial services organizations grapple with multiple
incidents of employee fraud.
What Drives Employees to Commit
Fraud?
In the corporate world, fraud occurs
majorly due to false representation or disclosure of wrong information and due
to abuse of position. From an individual’s point of view, there are three
conditions required for employee fraud to occur:
· Pressures due to Dire Necessity: There
could be many reasons for an employee’s overpowering need to commit a fraud,
e.g., medical/family emergency, debt, lavish life style, personal financial
emergencies, expensive habits, gambling, etc.
· Taking Advantage of Opportunity: An act for
personal gain with least chances of getting caught.
· Rationalizing Precedences: An
employee with a strong need and a reasonable window of opportunity to commit
fraud can find ways to rationalize his/her act.
Preventing Employee Fraud
This can be addressed through a three
-pronged approach:
A. Organizational Policy: Having a set of unambiguously drafted and unequivocally articulated
organizational policies relating to employee fraud is a pre-requisite. These
include policies pertaining to fraud:
· Prevention: Employee background checks,
compulsory job rotation, avoiding potential conflicts of interest, access to
sensitive data, etc.
· Detection: Maker-checker-auditor approach,
vigilance squads, compulsory leave, multi-level customer interaction, whistle-blower
protection, etc.
· Management: Internal investigation process,
disciplinary actions including criminal proceedings, etc.
· Communication: Detailed and continuous
communication of these policies is necessary to drive a clear understanding of
expected behaviours.
B. Organizational Incentive
Processes: Rewarding short-term achievement
could end up incentivizing behaviour, which may not be in line with
organization’s long-term goals. Disproportionate focus on the year’s KRAs
against long-term contribution and value creation could result in employees
taking a short-term approach to their work.
· Setting Target at Reasonably Stretched Level: While “stretch” targets are necessary, setting them at
unreasonable levels may tempt employees to take short cuts.
· Fostering Right Management Attitude: While
an over-aggressive attitude of management toward profitability and performance
can lead to an environment that is ripe for fraud, a lax attitude toward
internal controls and valuing ends over means can also result in pitfalls.
· Uniform & Consistent “Zero Tolerance” Policy: As the way an organization responds or reacts to detected fraud
cases plays an important role, a swift, uniform and consistent “zero tolerance”
policy is sine qua non.
· Timely Communication: Timely
communication to all employees without compromising on confidentiality helps in
reducing speculations, building transparency and making employees partners
rather than just recipients of management actions.
C. Organization Culture: Perhaps the most important and least appreciated aspect is the impact of
the prevailing organizational culture on employee fraud.
· Ensuring Daily Observance of Value Statement: A well-articulated organizational value statement/code of ethics/conduct
is the hygiene factor, while actual daily observance by each member within an
organization is the real differentiator.
· Healthy Precedence: The way
leaders/managers are rewarded and the way their careers are affected go a long
way in shaping the personal career strategy of an employee.
· Uniform Philosophy on Integrity – Irrespective of Environment: An organization’s overall philosophy on integrity in the external
environment is also important. An organization that aims to be a model
corporate citizen with a “clean” image is more likely to inspire a high
standard of behaviour among its employees.
Organizations – Victims of Employees
Fraud
· Reebok India: Mr. Shubhinder Singh Prem &
Mr. Vishnu Bhagat (former COO)
· Tata Finance: Mr. Dilip Pendse & his
associates
· United Bank of India: Ms.
Archana Bhargava (Former CMD)
· NSEL: Mr. Anjani Sinha (Former MD
& CEO), Mr. Amit Mukherjee (Former AVP – Business Development) & Mr.
Jai Bahukhandi (Former AVP – Warehousing)
Conclusion
Employee fraud – being a complex
issue – requires a multi-pronged approach, consisting of employee-friendly HR
policies, intelligent organization design and control systems, clear
organizational policies, smart incentives and leadership by example.