Fraud Prevention and Response Policy

1. Purpose

Parent & Carer Alliance C.I.C. is committed to conducting its activities with honesty, integrity, transparency and accountability.

We recognise our responsibility to protect the funds, assets, information and resources entrusted to us by families, funders, commissioners, partners and other organisations.

This policy sets out our approach to preventing, identifying and responding to fraud and other financial irregularities.

We have a zero-tolerance approach to deliberate fraud, theft, corruption and financial dishonesty.

2. Scope

This policy applies to everyone working for or on behalf of Parent & Carer Alliance C.I.C., including:

• Directors;

• employees and sessional workers;

• volunteers;

• contractors and consultants;

• suppliers and service providers; and

• anyone else acting on behalf of the organisation.

We expect organisations and individuals who work with us to act honestly and responsibly and to comply with applicable legal and contractual requirements.

3. What is fraud?

Fraud involves deliberately deceiving another person or organisation to obtain a financial or other benefit, or to cause a loss.

Fraud can take many forms, including:

• false or misleading statements;

• falsifying documents or records;

• false expense claims;

• theft or misuse of organisational funds or property;

• unauthorised or fraudulent payments;

• submitting false invoices;

• deliberately providing inaccurate information to funders or commissioners;

• falsifying attendance, monitoring or evaluation information;

• procurement fraud or conflicts of interest that are deliberately concealed;

• misuse of organisational bank accounts or payment cards;

• identity theft or impersonation;

• phishing and other cyber-enabled fraud; and

• deliberately assisting or concealing fraudulent activity.

This list is not exhaustive.

4. Our approach to preventing fraud

Parent & Carer Alliance C.I.C. maintains proportionate financial and organisational controls designed to reduce the risk of fraud.

These include, where appropriate:

• appropriate authorisation of financial transactions;

• financial monitoring and reconciliation;

• appropriate separation of financial responsibilities;

• checking invoices and payments;

• maintaining accurate financial records;

• appropriate procurement and purchasing procedures;

• monitoring grant and commissioned expenditure;

• protecting access to financial and information systems;

• verifying changes to supplier or contractor payment details;

• managing conflicts of interest; and

• reviewing fraud risks as part of our wider organisational risk management.

We will also take reasonable steps to ensure that people working on behalf of the organisation understand their responsibilities in relation to fraud prevention.

5. Funding and grant fraud

We are committed to ensuring that funding provided to Parent & Carer Alliance C.I.C. is used for its intended purpose.

We will maintain appropriate records relating to grant and commissioned activity and will provide accurate information to funders and commissioners.

We will not knowingly:

• make false funding claims;

• falsify expenditure;

• deliberately overstate attendance or activity;

• provide misleading monitoring information; or

• use restricted funding for purposes for which it was not provided.

Where suspected fraud may affect a funder or commissioner, we will consider our contractual and reporting obligations and take appropriate action.

6. Conflicts of interest

People acting on behalf of Parent & Carer Alliance C.I.C. must act in the best interests of the organisation and the communities it serves.

Actual, potential or perceived conflicts of interest should be declared and appropriately managed.

No person should use their position within the organisation to obtain an improper personal or financial benefit.

7. Gifts and hospitality

Gifts and hospitality must not be accepted where they could improperly influence, or reasonably appear to influence, a decision made on behalf of the organisation.

Cash gifts or equivalent financial benefits must not be accepted.

Any potential conflict arising from gifts or hospitality should be declared and managed appropriately.

8. Reporting concerns

Anyone who has a genuine concern about suspected or actual fraud involving Parent & Carer Alliance C.I.C. is encouraged to report it as soon as possible.

Concerns can be reported to:

Parent & Carer Alliance C.I.C.
Email: admin@parentandcareralliance.org.uk

Where a concern relates to the person who would normally receive or manage the report, it should be raised with another Director of the organisation.

A person does not need to prove that fraud has occurred before raising a concern. We ask that concerns are raised honestly and in good faith so that they can be appropriately considered.

9. Handling allegations

All concerns about suspected fraud will be taken seriously and assessed appropriately.

Depending on the circumstances, this may involve:

• reviewing financial or organisational records;

• carrying out an internal investigation;

• taking steps to protect organisational funds, assets or information;

• seeking professional advice;

• notifying a funder, commissioner or insurer;

• reporting the matter to the police or another appropriate authority; or

• taking action to recover financial losses.

Investigations will be handled fairly and, where appropriate, confidentially.

An allegation will not be treated as proof that fraud has occurred.

10. Protection for people raising concerns

Parent & Carer Alliance C.I.C. encourages people to raise genuine concerns about fraud or financial irregularity.

We will not tolerate victimisation or retaliation against anyone who raises a genuine concern in good faith.

Where a concern falls within the scope of whistleblowing legislation, our Whistleblowing Policy will also apply.

11. Cyber and payment fraud

We recognise that fraud can occur through email, online banking and other digital systems.

Particular care will be taken with:

• requests to change bank details;

• unexpected or unusual payment requests;

• requests for urgent payments;

• emails appearing to come from Directors or senior staff;

• suspicious invoices;

• requests for passwords or confidential information;

• phishing emails and links; and

• other attempts to impersonate staff, suppliers or organisations.

Appropriate verification will be undertaken before unusual payment or financial requests are actioned.

12. Legal and regulatory framework

Parent & Carer Alliance C.I.C. will have regard to relevant legislation and guidance relating to fraud, financial crime, bribery, company governance, information security and data protection.

This includes, where applicable:

• Fraud Act 2006

• Bribery Act 2010

• Economic Crime and Corporate Transparency Act 2023

• Companies Act 2006

• Criminal Finances Act 2017

• Proceeds of Crime Act 2002

• Theft Act 1968

• Computer Misuse Act 1990

• Data Protection Act 2018

• UK General Data Protection Regulation (UK GDPR)

We will also have regard to relevant government guidance and recognised good practice concerning fraud prevention and financial controls.

13. Economic Crime and Corporate Transparency Act 2023

The Economic Crime and Corporate Transparency Act 2023 introduced a new corporate offence of failure to prevent fraud, which came into force on 1 September 2025.

The statutory offence applies to organisations meeting the relevant legal definition of a large organisation. Although Parent & Carer Alliance C.I.C. may not fall within the statutory definition, we recognise the importance of maintaining proportionate procedures to prevent fraud and of promoting a culture of honesty and accountability.

14. Review and monitoring

This policy will be reviewed at least annually and may be reviewed sooner where there are:

• significant changes to legislation or guidance;

• changes to the organisation's activities or financial arrangements;

• significant changes to funding or contractual requirements; or

• a significant fraud or attempted fraud.

Where fraud or attempted fraud is identified, we will consider whether improvements to our policies, procedures or financial controls are required.

15. Related policies

This policy should be read alongside other relevant Parent & Carer Alliance C.I.C. policies and procedures, including:

• Financial Procedures;

• Conflict of Interest Policy;

• Whistleblowing Policy;

• Data Protection and Privacy Policy;

• Information Security procedures;

• Safeguarding Policy;

• Complaints Policy; and

• relevant grant and procurement procedures.

 

 

Changes to this policy

 

We may update this fraud prevention and response policy from time to time to ensure that it remains accurate. Please check back regularly so you are fully aware of any changes.​​​​