Fraud risk mitigation - Seplat experience
At Seplat, we apply insight from the fraud triangle theory in designing an effective anti-fraud programme to mitigate fraud risk.
The fraud triangle theory postulates that where fraud exists, three elements are always present – pressure/incentive, opportunity and rationalisation. So, our anti-fraud programme is built around the elimination or minimisation of one or two of the elements, knowing that all three must be present for a successful fraud to take place.
As a company operating in Nigeria, we recognise the pressure put on the staff, vendors and our host communities by the macro-economic realities of the time (e.g. inflation rate was 17% as at end of September 2017). Our anti-fraud programme includes a compensation and reward system that is very competitive and is continually benchmarked to peers and the industry at large. Our contracting and procurement processes are designed to guarantee fair and competitive bidding and pricing to curtail acts of inducement and corner-cutting.
Our internal controls framework and system are designed to reduce fraud opportunities by giving priority to preventive and automated/application controls. Core processes are documented and reviewed periodically with focus on the identification and mapping of control-points, which are in turn regularly reviewed and tested for design and operating effectiveness.
We have an effective whistleblowing programme in place as part of our anti-fraud solution. There are two whistleblowing portals – one manned internally and another manned externally by an independent third party, altogether providing staff, vendors and the general public ample avenues to report suspected fraudulent activities. Tips from whistleblowing are thoroughly investigated and consequences handled in accordance with the Company’s policy of zero tolerance to fraud, bribery and corruption.
Finally, strict adherence to corporate governance tenets starting with tone at the top and underpinned by strong Board oversight and executive management’s firm stand on zero tolerance to fraud, bribery and corruption, altogether send the message loud and clear down the cadre that fraud is not allowed in Seplat and cannot be rationalised.