Anti-fraud policy

This policy applies to all staff, non-executives (i.e. Board members), contractors, clients or any other person acting on NRW’s behalf.

The Fraud Act 2006

Fraud is a criminal offence and penalties under the act can result in up to 10 years imprisonment. Additional penalties include the possibility of an unlimited fine and confiscation of assets.

Definition of fraud

Fraud is a type of criminal activity. It is an act of deception intended for personal gain or to cause loss to another party. The Fraud Act 2006 describes the main three offences of fraud.

Fraud by false representation

This is when someone makes a false representation, knowing that the representation was or might be untrue or misleading, with the intent to make a gain or cause a loss.

Fraud by failing to disclose information

This is when someone fails to disclose information to a person when they were under a legal duty to disclose that information, with the intention of making a gain or causing a loss.

Fraud by abuse of position

This is when someone who occupies a position in which they were expected to safeguard, or not to act against the financial interests of another person, have abused that position, with the intent to make a gain or cause a loss. The abuse may consist of an omission rather than an act.

Our commitment to you

NRW will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

We are committed to ensuring no one suffers detrimental treatment as a result of refusing to take part in fraudulent activity, or of reporting in good faith their suspicion that an actual or potential fraudulent offence has or may take place.

Deterring or preventing someone reporting in these circumstances will be investigated and dealt with in accordance with NRW’s Managing Misconduct Policy and Procedure.


All staff or persons acting on behalf of NRW are responsible for the success of this policy.

Any breach will be treated as a disciplinary offence and could result in criminal proceedings.

Staff responsibilities

  • Report any concerns or suspicions immediately through your line management chain and directly to the Financial Governance Advisor (if your suspicions include your line manager or the Financial Governance Advisor or you do not feel that your allegation is being dealt with appropriately you must escalate up the line management chain or refer to our whistleblowing policy).

  • Be alert to the possibility that an unusual event or transaction could be an indicator of fraudulent activity.

  • Cooperate fully with whoever is conducting internal checks, reviews or fraud investigations.

  • Complete all mandatory training when instructed.

Line manager responsibilities

In addition to their responsibilities detailed above must:

  • Act as a primary point of contact for their staff to report any concerns of fraudulent activity.

  • Assess the types of risks in relation to their area of responsibility and ensure that controls are proportionate and complied with.

  • Review and test all controls that relate to their area of work on a regular basis proportionate to the level of risk.

  • Ensure all direct reports have read and understood this policy.

  • Ensure all direct reports complete their mandatory training when instructed.

The Executive Director of Finance and Corporate Services and the Financial Governance Advisor will provide advice and guidance to line managers as appropriate.

Financial Governance Advisor responsibilities

  • Act as a primary point of contact for reporting any concerns of fraudulent activity.

  • Liaise with relevant staff in relation to any allegations.

  • Provide advice as necessary to ensure compliance with the Anti-Fraud Policy.

  • Review the Anti-Fraud Policy and associated policies and procedures where changes in legislation occur to ensure NRW meets its legislative requirements.

  • Record and retain an overview of all suspected cases of fraud, ensuring that the Audit and Risk Assurance Committee (ARAC) are kept informed of all cases.

Executive Director of Finance and Corporate Services responsibilities

  • Review all alleged cases of fraud.

  • Approve any work necessary to establish whether a formal investigation is required.

  • Approve the initiation of all formal investigations.

  • Approve the closure of any formal investigations.

Internal Audit responsibilities

Provide the Accounting Officer with an objective evaluation of, and opinion on, the overall adequacy and effectiveness of the organisation’s framework of governance, risk management and control.

Responsibility for the anti-fraud policy

The Accounting Officer is responsible for establishing the internal control system designed to counter the risks faced by the business. They are accountable for the adequacy and effectiveness of these arrangements.

The Executive Director of Finance and Corporate Services is responsible for ensuring this policy complies with our legal and ethical obligations. They are also responsible for the implementation of this policy, for monitoring its effectiveness and to ensure that a point of contact is in place to deal with any queries in relation to the policy’s interpretation.

Reporting suspicions or concerns



Internal Audit Team
Cambria House
29 Newport Road
CF24 0TP 

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