DEALING WITH WHITE COLLAR CRIME

ESTABLISHING POLICY FOR DEALING WITH COMMERCIAL CRIME

Every organisation, no matter how big or small, should devise and implement a security policy. Moreover, it is particularly important for each employee within the organisation to be absolutely clear about their duty and responsibility within the security policy.

It is vital that in order to be truly effective, the policy is owned by management and that it is agreed by the Board, or executive management committee, and that is promulgated under the signature of the senior executive, owner or Chairman of the organisation. Emphasis should be placed on the word "follow" as it is essential that management itself should lead the implementation of the policy.

The aim of the policy should be to emphasise the organisation's commitment to rooting out white collar crime, to lay down the organisational framework, guidelines and procedures for dealing with the crime as well as the measures necessary to prevent it.

Large organisations might set up a committee to devise the strategy and draw up the policy but it is our belief that once this is done, a Board member or senior executive should be identified by post as being overall responsible for driving the policy. Individual responsibilities for white collar crime risk management should then be identified throughout the organisation.

Irrespective of the size of the organisation, the following responsibilities need to be recognised and assigned:

• Personnel management need to take responsibility for implementing an effective recruitment policy to prevent white collar criminals entering the organisation. This will be in addition to their responsibility for establishing the necessary remuneration policy', employee rules, disciplinary processes and security of employment policies which will establish the required ethical culture of the organisation.
• The responsibility for monitoring the integrity of key operations such as creditors, debtors, lending, insurance, payments etc, must be assumed by the line management concerned.
• Product design and systems managers will need to take responsibility for delivering secure (as well as attractive and efficient) new products and systems.
• Financial management will need to take responsibility for the broader stewardship of assets, and of course for control over financial accounting, the institution's bank accounts, and the payment of suppliers.
• Branch and departmental management must take responsibility for the security of their own operations, and for white collar crime loss control through the normal setting and achieving of business objectives.
• Support services management must take responsibility for the integrity of their own departmental operations.If a special investigations/security department is justified, it must be given a clear mandate and a set of objectives as any other business function within the organisation. In particular, the relationships with other functions must be defined.
• A structure should be in place for the purpose of enabling all employees a confidential procedure to follow inorder to report suspected commercial crime.
• As well as checking on systems, internal audit must take responsibility for independently checking and reporting upon the organisation's compliance with, and the overall effectiveness of, the strategy.
• As soon as commercial crime is suspected, an urgent crime response procedure should be followed to investigate, secure evidence and undertake internal disciplinary action, which will then be followed by recoveries of losses and criminal prosecution.

The above list is not necessarily comprehensive but it illustrates the importance for the entire management structure of the organisation to be involved in the fight against white collar crime. The Risk responsibilities should be reflected in job descriptions and in the setting and evaluation of annual objectives. Through such an empowered management structure, every member of the organisation must be encouraged to take individual responsibility for the combat of white collar crime.

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