Managerial or independent oversight

Involve more senior or independent personnel in actions, approvals and decisions to increase transparency and reduce the opportunity for fraud.

This control targets internal fraud risks.

Examples

Examples of this control include: 

  • a manager overseeing employee activities, e.g. work output, timesheets and travel
  • a probity advisor reviewing and signing off procurement milestones
  • a contract manager overseeing contract requirements, e.g. reporting on software development milestones
  • a security advisor overseeing physical security arrangements. 

Risks from control gap

Little or no managerial or independent oversight over employee actions and decisions can: 

  • lead to dysfunctional, inconsistent or obscure processes
  • cloud transparency and visibility of fraud and corruption risks 
  • reduce accountability needed to prevent, detect and respond to fraud and corruption. 

Assessing effectiveness 

Methods to evaluate the effectiveness of this control include:

  • confirming the existence of processes to support transparent actions and decision making
  • confirming that managerial or independent oversight exists for critical actions or decisions
  • reviewing a sample of decisions to confirm managerial or independent advice was obtained
  • reviewing workflows to ensure the involvement or oversight of a manager or independent person
  • reviewing the workload to determine if oversight mechanisms can reasonably keep pace with the volume of actions and decisions
  • reviewing reporting and reconciliation processes
  • undertaking an employee survey that includes questions on the adequacy of supervisor oversight. 

Complementary controls

Other capability, prevention, detection and response controls that can enhance this control’s effectiveness:

Related fraudster personas

Types of behaviour this control is designed to mitigate:

The corrupt

The enabler

The exploiter

 

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