Fraud and Bribery Prevention Policy

1. Purpose

This Fraud and Bribery Prevention Policy sets out the Architects Registration Board’s (ARB) approach to preventing, detecting and responding to fraud and bribery. It applies to all Board members, employees, contractors, consultants and any third parties acting on ARB’s behalf.

ARB has a zero-tolerance approach to fraud and bribery. Any suspected instances will be investigated and, where appropriate, reported to the relevant authorities and/or pursued through civil or disciplinary processes.

2. Scope

This policy covers all forms of fraud and bribery, including (but not limited to):

• financial fraud
• procurement and supplier fraud
• mandate and payment diversion fraud
• cyber-enabled and computer-based fraud
• bribery and corruption in any form

The policy should be read alongside ARB’s Whistleblowing Policy and staff and Board member Codes of Conduct.

3. Legal and Regulatory Framework

ARB’s approach is informed by the following legislation:

Fraud Act 2006

The Fraud Act 2006 creates offences of fraud by false representation, fraud by failing to disclose information, and fraud by abuse of position.

Bribery Act 2010

The Bribery Act 2010 creates offences of:

• offering, promising or giving a bribe
• requesting, agreeing to receive or accepting a bribe
• bribing a foreign public official
• failure of a commercial organisation to prevent bribery

Organisations are expected to have adequate procedures in place to prevent bribery.

4. Responsibilities

The Board

The Board is responsible for setting ARB’s overall approach to fraud and bribery prevention and for ensuring that appropriate policies, controls and oversight arrangements are in place.

Registrar and Senior Leadership Group (SLG)

The Registrar and SLG are responsible for:

• implementing this policy
• maintaining effective internal controls
• ensuring fraud and bribery risks are identified, managed and reviewed

Staff and Associates

All individuals working for or on behalf of ARB have a personal responsibility to:

• act with integrity
• comply with this policy and related procedures
• report any suspected fraud or bribery promptly

5. ARB’s Approach

ARB recognises that fraud and bribery can occur in any organisation. While ARB’s risk exposure is considered manageable, appropriate preventative and detective controls are essential to safeguard public funds, the integrity of the Register, and public confidence in the organisation.

Any employee found to have engaged in fraud or bribery will be subject to disciplinary action, up to and including dismissal for gross misconduct. Where appropriate, matters will be referred to the police or other enforcement bodies, and ARB will seek to recover any losses through civil proceedings.

6. The Six Principles

ARB applies the six principles set out in the Bribery Act 2010 as a framework for preventing both bribery and fraud.

Principle 1: Proportionate Procedures

ARB’s procedures are proportionate to the nature, scale and complexity of its activities. Fraud and bribery prevention measures are embedded within existing governance, financial, procurement and operational procedures rather than addressed through stand-alone processes.

Principle 2: Top-Level Commitment

The Board demonstrates a clear commitment to preventing fraud and bribery. This policy is approved by the Finance, Risk and Audit Committee, supported by senior management, and reinforced through training and organisational culture.

Principle 3: Risk Assessment

Fraud and bribery risks are considered as part of ARB’s wider risk management framework. Risks are recorded in a fraud specific Risk Register, which is reviewed by the SLG.

Principle 4: Due Diligence

ARB undertakes proportionate due diligence on third parties, including consultants and service providers. Contracts include provisions relating to fraud and bribery prevention and compliance with ARB policies.

Principle 5: Communication and Training

Staff receive information on fraud and bribery risks, their responsibilities, and reporting arrangements as part of induction and ongoing training; Board members receive training as part of their induction and any applicable third-party fraud and bribery bulletins.

Principle 6: Monitoring and Review

ARB monitors the effectiveness of its fraud and bribery prevention arrangements and reviews this policy at least every two years, or sooner if required by legislative or organisational change.