Every nonprofit organisation maintains a significant amount of information. How much is that information worth to your organisation – donor lists, methods of preparing sponsorship proposals or grant proposals.
It is difficult, if not impossible to place a value on these, but if someone was to takes copies, the future reduction in income could be significant. So how do you protect your information? Some examples include:
- Do not allow staff to use external devices such as external hard drives on their computers;
- Only allow those staff who need access to the documents to have access;
- If a staff member resigns, review what they send through their work email;
- When the staff member leaves, if you are concerned, have their computer reviewed for such things as the use of personal emails (eg Hotmail).
Respondents to our new PPB Not-for-Profit Risk Survey were asked if their organisation takes into account a number of different risks, including fraud. Where did fraud rank?
58% of organisations stated that they considered fraud was a risk to their organisation. However, fraud ranked 7th. The order of risks was as follows:
Financial Risk - 89%
Compliance Risk - 77%
Public Liability Risk - 71%
Human Risks - 69%
Security Risk - 65%
Project Risk - 64%
Fraud Risk - 58%
Technological Risk - 56%
Financial literacy of key staff - 46%
Natural hazard / disaster risks - 46%
Risk of Insolvency - 43%
While 58% of respondents take into account fraud as a risk, it was interesting to note that while 89% of organisations consider financial risk, just under half (43%) consider the risk of insolvency.
All organisations will, over time, hold information that is considered sensitive (eg. Information about clients or students, information about donors, grant information). This information needs to be protected. Examples of ways to protect sensitive information include:
- Personal data of employees, volunteers, clients etc should be held in accordance with relevant data protection legislation that is relevant to the organisation’s jurisdiction.
- All data should be stored securely and adequately backed up.
- Audit logs should be maintained so as to know who accessed data and when it occurred. These audit logs needs to be maintained and backed up appropriately also.
- Spot checks should be undertaken to confirm that access to the records were for legitimate reasons.
- Determine who should have access to the data and ensure they are the only ones who have access.
The financial statements of an organisation explain what the organisation has done during the last 12 months so when financial statement fraud occurs, the financial statements do not tell the true or actual picture.
Both the Profit and Loss Statement and the Balance Sheet can be manipulated.
The Profit and Loss Statement can be misstated in the following ways:
Overstated revenue
By overstating revenue, the profit is improved or loss is reduced.
Understated expenses
By understating expenses, the same effect as overstating revenue is achieved.
However, the opposite may also be possible in a nonprofit. For example, if an organisation is required to expend all of a grant and has not done so, increasing expenses would enable the grant to be acquitted as required by the grant provider.
The Balance Sheet can be misstated in the following ways:
Overstated assets
Generally an organisation will want to overstate assets to show the organisation in a better position than it is actually in (for example to ensure the bank is happy with lending criteria). However, again the opposite may occur in a nonprofit organisation as the organisation may want to be seen to have fewer assets to ensure the continued receipt of grants.
Understated liabilities
It is normal in financial statement fraud that liabilities are understated.
Ultimately someone in the organisation has to undertake the falsified transactions and the accounts are then approved with or without knowledge of the fraud. However, if the accounts are then used, significant problems could arise, from fraud charges against an employee, management or a member of the board, reputation risk or loss of funding.
One of the questions I am regularly asked about is how smaller nonprofits keep control of their accounting records when treasurers change so regularly – usually every year.
Issues I have been asked about include:
- The Treasurer uses his/her own accounting software on his/her home computer. In this case how does the board control the security of the information (eg. viruses on the computer), loss of the information (eg. damage to the computer hard drive) or the computer being stolen if the house was broken into? There is also the issue of the organisation potentially not using licensed software.
- The Treasurer does not hand back the accounting records when ceasing in the position. If the only records available are those held by the accountant / auditor it can be difficult to budget for the next year.
- The Treasurer does not give the rest of the board access to the accounting records. This can mean a number of problems from the Treasurer wanting absolute control, to fraud.
How do you resolve a situation like this? The organisation should consider and investigate online accounting software. Some accounting software (some of which is well known and widely used) is now available online. This means that as one Treasurer leaves and a new Treasurer takes over, the data is available. It also mean that it can be accessed (even if it is read only) by other members of the board, the external accountant / auditor and is backed up properly by the software provider.
Have you ever had difficulty finding a new staff member and had another staff member recommend a family member? There are a number of issues that should seriously be considered.
Firstly, the relationship may cause tension in the workplace – either between the two or between them and other employees / volunteers. The other issue is that it potentially makes is easier for them to collude to commit fraud as a result of the close family relationship.
So how can you deal with this issue? A decision needs to be made whether it is appropriate to employ relatives of current employees. The employment policy should clearly set out that family members will not be employed at least, in the same area or allowing one family member to supervise the other family member.
When management or the board of any non profit makes a decision, they need to consider a number of issues - eg. what will it cost the organisation, what benefits will the organisation receive.
However, another issue needs to be considered when making decisions - how would others view your decision if it made the front page of the newspaper? Would you lose donations? Would there be agreement with your decision? Every decision should be considered to this extent. Those decision can very from how do you spend funds raised to should you report fraud to the police.
Of course, some non profits are at greater risk of hitting the front page of a newspaper than other non profits (eg. a charity would be a reasonably high risk as a significant portion of funds are publically raised). However, this one question is a good test of if the decision is in the best interests of the organisation.
How many times have you had questions raised about what percentage of funds donated actually goes directly to the mission of the organisation? It is difficult to achieve and then maintain an appropriate balance between the expectations of donors of funds where they want every cent of every dollar donated to go to the mission of the organisation and having sufficient funds to be able to develop and maintain appropriate controls.
With demands from donors wanting all funds donated going to the mission, how does the organisation pay expenses, such as market rates of salary / wages to employees and having the resources to maintain controls.
If an employee is not paid at market rates and controls are not maintained appropriately, the risk of fraud will increase.
So what is the answer? It is not an easy question to answer considering the amount of media that is regularly given to the percentage of donated funds that are used for the organisation’s mission. Ultimately it is a longer term education process so that donors of funds understand that a reasonable percentage of funds are needed to administer the organisation.
In a previous fraud tip we discussed how it is not the primary role of the auditor to detect fraud. They are engaged to provide an opinion as to the reasonableness of the financial statements. To be able to provide that opinion, one thing that the auditor needs to do is to consider the reasonableness of internal controls.
Issues that the auditor finds, such as weaknesses in internal controls, are provided to the organisation by way of a management letter. The following should be considered in relation to the management letter:
- If there are a number of issues or if the issues are complex in nature, the auditor should meet with the board to discuss the issues;
- The board needs to understand the issues raised;
- The board should consider each of the issues and prioritise the list in order of importance so as to ensure the issues raised are corrected;
- The board should work with management to ensure issues raised are corrected within a reasonable time frame.
It should also be noted by correcting issues raised in the management letter, problems with internal controls can be corrected which should result in a reduced risk of fraud. Correcting the issues may also save funds by reducing the time needed by the auditor to undertake the audit, thus reducing the audit fee.
Policies are an important part of any organisation. One of the policies needed is a Bad Debt Policy which provides details of when a debt should be written off. It also provides details of how the write off process needs to be authorised. So how does this help with fraud prevention?
A common method to hide a fraud is to take funds as they are received and to record them in the accounts as a debtor. As the debtor gets larger and is seen not to be being collected, it is written off, thereby reducing the risk of the fraud being discovered. This is especially a problem for organisations that are regularly owed funds from clients or other customers which do not pay and there is a history of writing off the debt.
When preparing a Bad Debt Policy, you need to clearly set out the criteria of when a debt is to be written off as well as how the write off is to be authorised. It is the authorisation process that should pick up potential fraud.
