Guidance

Fraud, Bribery and Corruption Policy

Published 27 October 2026

Policy Statement

NWS has a zero-tolerance approach to fraud, bribery and corruption and will take all appropriate measures to prevent and detect it.  The facilitation of tax evasion, and money laundering are also strictly prohibited.  

Failure to comply with this Policy will be a disciplinary matter which will be considered under the NWS Disciplinary Policy. The leadership of NWS is determined that the culture and tone of the organisation is one of honesty and an intolerance of fraud, bribery, and corruption.

We are committed to:

• developing a strong culture of integrity across the organisation.
• having ‘adequate procedures’, including effective systems, processes and controls in place to prevent fraud, bribery and corruption and other financial crimes.
• the proper use of funds, both public and private.
• taking all reports of fraud, bribery and corruption and other financial crimes seriously and investigating them proportionally and appropriately.
• seeking the appropriate disciplinary, regulatory, civil and criminal sanctions against those who commit fraud, bribery and corruption and, where applicable, recovering losses.

In line with the NWS Code of Conduct and reflecting the Nolan Principles of Public life all staff have a responsibility to assist in preventing fraud, bribery and corruption.

We recognise that fraud, bribery and corruption can:

• Undermine the standards of public service that NWS seeks to achieve.
• Reduce the resources available to NWS to achieve our strategic objectives.
• Have major consequences which reduce public confidence and affect the reputation of NWS.

This Policy applies to all NWS staff, regardless of position held and employment type, including non-executive directors, executive directors, permanent and interim workers (ASW’s and CSW’s) and secondees, as well as consultants and contractors.  We also expect all suppliers and any other party who has a professional or business relationship with us to align to these principles.

Our approach to protecting NWS from the risk of fraud, bribery and corruption is a multi-faceted, risk-based approach, which includes risk assessment, prevention, deterrence, detection, measurement, investigation, and sanctions.  This Policy is underpinned by a Fraud, Bribery and Corruption Strategy which sets out what actions NWS takes to continue to develop its resilience to fraud, bribery, and corruption.

1. Context

The purpose of this Policy is to set out key elements of our approach to managing the risk of fraud, bribery or corruption and other related unethical behaviour risks, in line with our Fraud, Bribery and Corruption Strategy. It also sets out the key roles and responsibilities, as well as specifically what is required of all employees. 

This Policy is prepared in accordance with Government Functional Standard GovS 013: Counter Frauda and relates to all forms of fraud, bribery, and corruption, as defined in Section 2 below.  The Standard sets the expectations for the management of fraud, bribery, and corruption activity in government organisations, and includes the requirement to undertake risk assessments for our exposure to fraud as a business, and at a programme and project level.

The aim of the Policy is to ensure all concerns raised are captured, considered, and dealt with appropriately. It will also help us to learn from the matters that are raised so that we can improve how the NDA Group operates as part of our vision to create great places to work. It is not contractual; we will review it regularly and may change it.

The NDA as a Group entity is required to report to DESNZ annually our compliance against GovS 013 at the Group level; NWS data is consolidated within this submission. A subsequent annual action plan is developed to address any weaknesses in our processes, identified either through the compliance self-assessment, assurance activities or lessons learnt exercises following investigations. Progress against this action plan is monitored by the Audit and Risk Assurance Committee (ARAC).

2. Definitions and Examples

Fraud essentially involves using deception to dishonestly make a personal gain for oneself and/or create a loss for another. This can include theft, the misuse of funds or other resources, or more complicated crimes such as false accounting and the supply of false information. Definitions are included to provide clarity as to what this Policy is concerned with. Where examples are given, these are not intended to be exhaustive.

Fraud is the intentional use of deception to gain a financial advantage or to deprive, disadvantage or cause loss to another.

This can include the misuse of funds or other resources and/or the supply of false information. The focus is on the dishonest behaviour of the subject and their intent to make a financial gain or cause a financial loss. The gain or loss does not have to succeed if the intent is there.

There are 3 main fraud offences under the Fraud Act 2006:

• Section 2 – Fraud by false representation – for example, falsely making expense claims, or exaggerating hours on timesheets.
• Section 3 – Fraud by failing to disclose – for example, not disclosing unspent criminal convictions to gain employment.
• Section 4 – Fraud by abuse of position – for example, intentionally abusing delegations of authority.

Other examples may include:

• working for another employer whilst on sickness absence,
• suppliers submitting payment claims for goods or services that were not delivered or inferior to what was specified in the order (invoice fraud), or
• requesting a change to staff or supplier payment details to their own (mandate fraud).

Effective from 1 September 2025, the offence of Failure to prevent Fraud also holds organisations to account should they profit from fraud committed by their employees. Under the new offence, NWS will be liable where a specified fraud offence is committed by an employee or agent, for the organisation’s benefit, where we did not have reasonable fraud prevention procedures in place. It does not need to be demonstrated that management or the Board either ordered or knew about the fraud, and prosecution may result in an unlimited fine to the organisation, or to specific employees.

Bribery is the offering, promising, or giving of a financial or other advantage to induce or reward improper performance and/or the request for, or acceptance of such an advantage.

The Bribery Act 2010 sets out four offences:

• Offering a bribe - offering, promising, or giving of a financial reward or other inducement or advantage to another person to perform a relevant function or activity improperly.
• Accepting a bribe - requesting, agreeing to receive, or accepting a financial reward or other inducement or advantage to perform a function or activity improperly, directly, or indirectly, and irrespective of whether it is for the recipient’s benefit.
• Bribing a foreign public official – offering or giving a financial (or other) advantage or inducement to a foreign public official, with the intention of influencing that public official in the carrying out of their duties. Any intent to influence is sufficient – it does not have to be an intent to influence the public official to carry out their duties improperly. The definition of foreign public official may be widely interpreted (for example it may include university employees in some countries).
• Failure of a commercial organisation to prevent bribery – NWS is responsible for acts of bribery carried out by “associated” persons for our benefit. Associated parties may include those who carry out services for or on our behalf such as agents or intermediaries. An organisation can commit an offence under Section 7 of the Bribery Act 2010, which is failing to prevent a bribe, if an employee, subsidiary, or associated person commits bribery within it. The organisation has a defence against this offence if it can demonstrate it has adequate anti-bribery controls and procedures in place.

Inducements or advantages may include, but are not limited to, gifts; favourable commercial arrangements; hospitality, such as meals, hotel stays, tickets, or invitations to sporting or cultural events; favours that are of value to the recipient (such as offers of employment, work experience or internships); and charitable donations. 

These items are not always bribes, but because of the risk that they are bribes or may be perceived as bribes, we have processes and controls in place (such as gifts and hospitality registers) to manage this risk which everyone must comply with.

Facilitation payments (sometimes known as grease payments), whereby unofficial payments or gifts are made to secure, facilitate or speed-up a public official’s performance of a necessary government action or process are bribes (even if they are of low value) and should not be made.

There is a defence to the corporate offence if NWS can show we had “adequate procedures” in place designed to prevent bribery. Guidance issued by the Ministry of Justice sets out six broad management principles to assist organisations to put in place proper anti-bribery procedures. NWS will follow these principles to show that it is committed to eliminating bribery within or on behalf of the business. 

The management principles are:

• Proportionality – anti-bribery policies and procedures should be proportionate to the activities and size of the organisation, the sector in which it operates and the risks it faces.
• Top level commitment – establishing a clear culture within the Organisation which reinforces that bribery is unacceptable.
• Risk assessment – understanding and keeping up to date with the bribery risks it faces by carrying out regular risk assessments using Fraud Impact Assessment tools.
• Due diligence – the Organisation needs to know details about who it does business with, who it is paying money to and why – and make sure those the organisation works with, e.g. associated persons, also have reciprocal anti-bribery agreements in place.

Corruption is the deliberate abuse of a public or private office for personal gain. This can take many forms, such as fraud, extortion, cronyism, bribery, or facilitation payments.

Theft

Theft is broadly included in the definition of fraud. The three main offences in the Theft Act 1968 are:

• Section 1: Theft - dishonestly taking property of another with the intention of permanently depriving the owner of it for example taking company property off the premises without a legitimate reason.
• Section 17: False Accounting - dishonestly destroys, conceals, or falsifies any accounting record or produces a misleading accounting record with a view to reporting misleading financial performance - for example exaggerating financial performance.
• Section 24a: Retaining Wrongful Credit - dishonestly fails to take reasonable steps to ensure that a wrongful credit is cancelled for example taking no action to cancel incorrect salary enhancements received.

Facilitating Tax Evasion means being knowingly concerned in, or taking steps with a view to, the tax evasion of another, and/or aiding and abetting another person’s offence of tax evasion. An example of this is helping another person to evade tax by deliberately wrongly completing the tool used to assess whether an individual is inside or outside IR35 rules.

Facilitating tax evasion is a criminal offence, and the Criminal Finances Act 2017 also makes it an offence for a company to fail to prevent the facilitation of tax evasion by those acting on its behalf.

Money Laundering is the process of concealing the origin of funds that have come from an illegal source. An example of Money Laundering may be if funds were received by NWS from a commercial partner in payment for services we have provided, when those funds are in fact the proceeds of a criminal activity, such as bribery.

3. Key Roles and Responsibilities

The NWS Board has oversight of fraud, bribery and corruption and must ensure it has assurance (including through reports from the Audit, Risk and Assurance Committee) on the management of the associated risks facing NWS, and the measures being taken to mitigate the risks. The Chair of the Audit, Risk and Assurance Committee is the Accountable Board member for fraud, bribery, and corruption, and will provide active leadership and challenge at a strategic level.

The General Counsel/Company Secretary is the Accountable Senior Officer responsible for owning and managing the fraud, bribery, corruption and unethical behaviour risk and approach within NWS. This includes:

• Ensuring the Government Functional Standard Gov013 is met and ensuring the Board (through the NWS ARAC) are aware of where there are gaps.
• Accountability for NWS’s performance in countering fraud, bribery, and corruption.
• Ensuring the Board (through the NWS ARAC) has discussions on the nature of the fraud, bribery and corruption risk facing NWS, and the measures being taken to mitigate this risk.
• Ensuring NWS has the resources, skills, and capability to deliver the Fraud, Bribery and Corruption Strategy.
• Overseeing interactions with any regulatory or enforcement body, including contacting the police where required.

The Head of Enterprise Risk and Assurance is the Functional Lead for the day-to-day management of the fraud, bribery, and corruption. This includes:

• Building an effective and fit for purpose Fraud, Bribery and Corruption (FBC) Framework.
• Overseeing the risk assessment of and maintaining a detailed understanding of the fraud, bribery and corruption risks facing NWS, and communicating these to the ARAC.
• Advising on the implementation of practical and cost-effective standards and controls to mitigate fraud, bribery, and corruption risk.
• Developing capability within NWS and ensuring that staff have the skills and capability to deliver the FBC Framework, ensuring appropriate fraud, bribery and corruption training is available where required.
• Ensuring the annual Fraud, Bribery and Corruption Action Plan is implemented, and monitoring and reporting on progress as appropriate.
• Maintaining a log of all alleged, suspected and reported instances of fraud, bribery, and corruption.
• Overseeing investigations into fraud, bribery and corruption and reporting on outcomes.
• Maintaining dialogue with the wider NDA Group on fraud, bribery, and corruption matters.
• Managing interactions with regulatory and/or enforcement bodies.
• Attending the NDA Group Fraud, Bribery and Corruption Committee on behalf of NWS, where required.

The Enterprise Assurance Team supports the Head of Enterprise Risk and Assurance as Fraud Champions, with responsibility for:

• Proactively raising awareness and understanding of the FBC framework across the business, by providing support to the business on managing fraud, bribery, and corruption risk.
• Assessing effectiveness of the FBC Framework by developing appropriate critical key performance indicators (KPIs), using learning from investigations, trends, and statistics to identify areas for improvement, and managing these through an annual Fraud Action Plan.
• Working collaboratively with key internal and external stakeholders to tackle fraud, bribery and corruption whilst contributing to the sharing of information and best practice within the wider NDA Group through the Group Fraud, Bribery and Corruption Forum and leading the Fraud, Bribery and Corruption Community of Practice.
• Ensure mechanisms are in place for alleged, attempted, or actual instances of fraud, bribery, or corruption to be identified and recorded.
• Ensure all allegations of fraud, bribery, and corruption are effectively and appropriately investigated, working with key partners and subject matter experts where necessary.
• Monitor fraud, bribery and corruption trends, statistics, and reporting these to NWS ARAC and NDA Group.
• Assess compliance with NDA Group fraud requirements and governance standards (Gov013).
• Undertake quality assurance of Initial Fraud Impact Assessments (IFIA) and Fraud Risk Assessments (FRA) in all areas of major spend outside of NWS delegation

The Fraud, Bribery and Corruption Community of Practice, chaired by the Head of Enterprise Risk and Assurance, consists of leaders (or nominated representatives) from each functional area of the business which has been identified as owning a fraud, bribery, corruption, or unethical behaviour risk. This includes, but is not limited to, Finance, Commercial, Information Security, Physical Security and HR. The members meet on a quarterly basis, with the purpose of:

• Reviewing any changes to the NWS fraud, bribery, and corruption risk profile.
• Review and maintenance of the risk register for fraud, bribery, and corruption.
• Discussing, at a high level, any attempted, suspected, alleged or successful instances of fraud, bribery, corruption, or unethical behaviour.
• Discussing any lessons learned following an investigation.
• Receiving feedback from the Group Fraud, Bribery and Corruption Forum on fraud, bribery, and corruption activity from across the Group.

All Managers / Functional Leaders must:

• Instil a zero-tolerance approach to fraud, bribery, and corruption in their teams.
• Ensure they understand how fraud, bribery and corruption risk may happen in their area.
• Assess fraud risks in the areas they are responsible for, in conjunction with the Enterprise Risk team, using Fraud Impact Assessments.
• Ensure that fraud, bribery, corruption, and unethical behaviour controls in their areas are operating effectively, and the controls are regularly tested and reviewed.
• Attend relevant training and awareness activities in order that they can detect fraud.
• Ensure that their teams participate in fraud, bribery, and corruption training to help them recognise and understand these risks.
• Ensure staff are supported in raising any concerns of fraud, bribery, and corruption.
• Satisfy themselves that travel and expense claims, timesheets, and entries into the gifts and hospitality register are valid and accurate before approving.
• Work with the relevant Risk Partner to undertake Initial Fraud Impact Assessments (IFIA) and Fraud Risk Assessments (FRA) for all areas of spend for which the business case will require approval outside of NWS delegation.

All Staff must:

• Act with integrity and honesty at all times.
• Never offer or accept a bribe or participate in any fraud, bribery, corruption, or unethical behaviour with their work at NWS.
• Act with propriety in the handling of public funds, resources, assets, and information.
• Be alert to the possibility of fraud, bribery, corruption and any behaviours or indicators of such.
• Understand they have a part to play in protecting NWS from fraud, bribery, corruption, and unethical behaviour, and comply with NWS processes and controls designed to mitigate these risks.
• Complete expense claims, timesheets, and gifts and hospitality registers honestly and in line with the relevant policies and procedures.
• Undertake counter fraud, bribery, and corruption training appropriate to their role, when required.
• Notify any concerns of fraud, bribery, corruption, and unethical behaviour (which may be red flags or unusual events) in line with the Fraud, Bribery and Corruption Response Plan.

4. Suspected Fraud, Bribery & Corruption

How suspected fraud, bribery and corruption may be discovered.

Suspected fraud, bribery, and corruption may come to light through a variety of means, which may include: -  • routine processes/system checks.

• proactive detection mechanisms, such as data analytics.
• management follow up on areas where there is evidence that controls are not being applied.
• auditor or assurance reviews.
• concerns having been raised to a Line Manager, or to the Head of Enterprise Risk and Assurance and / or the General Counsel/Company Secretary or a report through the NDA Group’s independent whistleblowing hotline, Safecall; or
• other ‘tip offs’ from members of staff or third parties.

How to report suspicions of fraud, bribery, and corruption All employees are responsible for notifying suspected fraud, bribery, and corruption that they become aware of. Any suspected or potential fraud, bribery or corruption should be reported through one (or more) of the following methods, as per the NWS Speak Up Policy and Guidance document. 

Line Manager Where appropriate, suspicions and allegations can be raised with an employee’s line manager. Where appropriate, managers must support employees in raising their concerns in line with the Fraud, Bribery and Corruption Policy and the Response Plan.

Head of Enterprise Risk and Assurance or General Counsel/Company Secretary   Employees may also contact the Head of Enterprise Risk and Assurance and / or the General Counsel/Company Secretary with any allegations or suspicions. 

Safecall  Our confidential whistleblowing reporting service (www.safecall.co.uk / 0800 915 1571) is available for any concern where it is considered that any of the internal methods above is inappropriate, for whatever reason. Any complaints alleging wrongdoing in our workplaces are received by Accountable Senior Officer for Fraud, Bribery, and Corruption (the General Counsel/Company Secretary) will progress the initial response independently and with complete impartiality.

Within the NDA Group If you feel you cannot speak up within NWS, you may do so to via the NDA Ethics & Compliance Team eandc@nda.gov.uk or use Safecall and indicate you wish the concern to be raised as an NDA matter. They will then oversee the resolution of your matter, involving NWS as appropriate.

Reporting other concerns Health, safety and security observations, incidents and allegations should be reported through our dedicated system, OSHENS.

Cyber security concerns, breaches, or incidents should be reported to the Information Security team as soon as possible, using their Reporting Form.

5. Sanctions and Redress

In cases of serious fraud and/or bribery, NWS reserve the right to apply sanctions. These may include;

• Disciplinary action in line with the NWS Disciplinary Policy.
• Civil action to recover lost funds.
• Use of criminal law to apply an appropriate criminal penalty upon the individual(s).
• Referral of information and evidence to external bodies, e.g. professional bodies, if appropriate.

Disciplinary procedures in line with the NWS Disciplinary Policy will be initiated where an employee is suspected of being involved in a fraudulent or illegal act. The Accountable Senior Officer, in conjunction with the HR Department, will be responsible for initiating any necessary disciplinary action.

Arrangements may be made to recover losses via payroll if the subject is still employed by NWS. In all cases, current legislation must be complied with. It should be noted that the duty to follow disciplinary procedures will not override any requirement to take legal action in the case of suspected fraud, bribery or corruption, and legal requirements shall prevail.

The civil recovery route is also available if this is cost-effective and desirable for deterrence purposes. This could involve a number of options such as applying for reimbursement through the Small Claims Court and/or recovery through debt collection agencies. Each case needs to be discussed with the Chief Financial Officer and the General Counsel/Company Secretary, to determine the most appropriate action.

Criminal investigations are primarily used for dealing with any criminal activity. The main purpose is to determine if activity was undertaken with criminal intent. Following such an investigation, it may be necessary to bring this activity to the attention of the criminal courts (magistrates court and Crown court). Outcomes can range from fines to imprisonment.

Redress allows resources that are lost to fraud and bribery to be returned to the public purse use as intended. Depending on the extent of the loss and the proceedings in the case, it may be suitable for the recovery of losses to be considered under the Proceeds of Crime Act 2002 (POCA). This means that a person’s money or assets can be taken away from them if it is believed that they benefited from the crime. It could also include restraining assets during the course of the investigation. When considering seeking redress, recovery may also be sought from ongoing salary payments or pensions.”

6. Lessons Learnt

NWS is committed to ensuring that opportunities for fraud, bribery and corruption are reduced to the lowest possible level of risk. In the event that fraud, bribery, corruption, or unethical behaviour is discovered, NWS will take steps to ensure lessons learnt from the event are applied to existing policies and practices. This might include implementing changes to the existing system of controls, increasing awareness of the risk of fraud and/or bribery, disseminating lessons learnt where there may be implications for the wider organisation.