Anti-corruption

The process has been designed on the basis of the Fraud Risk Management Guide, which the Committee of Sponsoring Organizations of the Treadway Commission (COSO) published in September 2016.

THE NDMA’S ANTI-CORRUPTION PROGRAMME

The duty to combat corruption and other financial impropriety, including fraud, is entrenched in the Integrity System’s two components, Core Values and Code of Conduct, as well as the governing document Directive for Corporate Governance.

On the basis of the framework drawn up by the Office of the Auditor General, extensive efforts are made to identify and assess any potential fraud that could affect the NDMA. The risk assessment is performed by an interdisciplinary working group and is documented in writing.

Preventive measures that have been introduced or will be introduced by the NDMA include:

• A register of private interests.
• HR procedures: security clearances, dilemma training and other training schemes, annual employee review meetings and performance reports.
• Public procurement processes.
• Background checks of vendors and purchasers of second-hand materiel.
• Work-sharing and authorisation system.
• Various checks before transactions are undertaken.

Measures to uncover financial impropriety that have been or will be introduced by the NDMA include:

• Various process controls, such as reconciliations, stock-takes and inspections of fixed assets and consumables, irrespective of valuations and analyses.
• Data analyses to contribute to the identification of red flags and actual fraud.

The NDMA has established a reporting channel, operated by the internal auditing department, through which employees and third parties may, via various media, report matters they feel to be a cause for concern. You can read more about how to report wrongdoing and causes for concern here.

Fraud that is uncovered through checks, audits, reports or other mechanisms shall be dealt with in accordance with our system for the management of undesirable incidents. The system is currently under development, and is based on the principle that all types of undesirable incidents shall be dealt with through the same process, and by means of interdisciplinary cooperation.

We have signed a partnership agreement with the Centre for Integrity in the Defence Sector (CIDS) to make our anti-corruption programme as effective as possible.

FRAUD AND CORRUPTION

FRAUD:

COSO defines fraud as “any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain”.

CORRUPTION:

Corruption is a type of financial impropriety that has extremely negative consequences for the defence sector and society at large. In Norway, awareness of corruption and its damaging effects has increased sharply after provisions relating to corruption were included in the General Civil Penal Code in 2003. Norway’s Penal Code (s 387)  defines corruption as:

a) for oneself or others demanding, receiving or accepting an offer of an improper benefit in connection with the exercise of one’s position, office or in the execution of an assignment, or

b) providing or offering someone an improper benefit in connection with the exercise of their position or office, or in the execution of an assignment.

Position, office or assignment in paragraph 1, also means any position, office or assignment abroad.