Fraud Policy

In line with EirGrid’s¹ core values of being transparent, collaborative, accountable and ambitious, EirGrid Group is committed to conducting its business to the highest standards of integrity, fairness, honesty and in compliance with statutory and regulatory obligations.

EirGrid expects all personnel working on its behalf to maintain the highest standards in this regard and is committed to creating a workplace culture that encourages the reporting of wrongdoings.

In discharging its responsibilities EirGrid is conscious of the trust and confidence of those with whom we deal being one of our most vital corporate resources and the protection of this is of fundamental importance to EirGrid and a key ingredient for success. 

EirGrid does not tolerate fraudulent or attempted fraudulent activity. 

EirGrid commits to investigate all frauds that are discovered or suspected and will take appropriate action against all parties involved in, or assisting with, committing fraudulent activity, including but not limited to, disciplinary processes, recovery and legal action. 

We continually take steps to prevent and detect fraud, increase awareness of fraud amongst employees and other stakeholders, and create a culture where the reporting of suspicions of fraudulent activity is encouraged and expected. 

The Fraud Policy should be read in conjunction with the existing corporate and HR policy framework and related procedures including but not limited to those set out in Appendix A.

¹The terms “EirGrid” and “EirGrid Group” includes EirGrid plc, and all its subsidiaries incorporated in the Republic of Ireland.

The purpose of this policy is to ensure that all persons to which this policy applies understand what constitutes fraud, EirGrid Group’s attitude and approach towards it, and what is expected of them in relation to the prevention and reporting of fraud.  

EirGrid is committed to embedding a strong awareness of fraud risk within the organisation and minimising the opportunity for fraud to occur.

The Fraud Policy applies to any fraud, or suspected fraud in relation to any activity being performed in EirGrid Group and includes:

This policy is intended to provide a safe and secure mechanism for workers who may wish to report any reasonable concerns that they may have about perceived wrongdoing, including Fraud in EirGrid.  

For the purpose of this policy the term ‘worker’ includes all current and past employees and directors of any EirGrid Group company in addition to contractors, casual workers and agency workers while working for or on behalf of an EirGrid Group company.  

For the avoidance of doubt, for the purpose of this policy, a ‘contractor’ is an individual who, personally or through a contract with his or her employer, undertakes with an EirGrid Group company to do or perform work or services for that EirGrid Group company.

Please note that there are no geographical boundaries for the commission of a wrongdoing. Consequently, if the wrongdoing is committed abroad, that is, outside Ireland and Northern Ireland, this policy still applies whether or not the wrongdoing would be regarded in that country as an offence.

All parties to whom this policy applies have a responsibility to assist in the prevention and detection of fraud perpetrated by and/or against EirGrid in line with business ethics as defined within our Employee Code of Conduct.  

This responsibility includes operating and monitoring the systems of internal controls which promote the prevention, detection and investigation of fraud, as well as the management of fraud risk, and reporting all suspicions of fraud and situations that could allow a fraud to be perpetrated. 

The key roles and responsibilities in relation to this policy are as follows:

All Staff

All staff/workers are responsible for the successful implementation of this policy, compliance with its requirements and are expected to familiarise themselves with this policy.  

All staff are required to participate in related training programmes to comply with related policies. 

All new employees must receive specific training as part of their induction process.

Heads of Function

Heads of function are responsible for:

Internal Audit

The Head of Internal Audit provides assurance over the effectiveness of the internal control environment, including anti-fraud measures, independently assessing the governance framework in place for managing and detecting instances of fraud and incorporating fraud assessments into individual audit reviews.

In line with Section 6 below, the Head of Internal Audit is responsible for agreeing the terms of reference of and appointing investigators for, investigating breaches of this policy and for providing independent oversight of all investigations undertaken.

Governance, Risk & Compliance

The Head of Governance, Risk & Compliance maintains oversight of anti-fraud policies and procedures and the associated compliance framework in relation to their application.

Board & Executive Management Team

The Board and Executive Management Team are responsible for:

Fraud Prevention Measures

A number of fraud prevention measures exist and are embedded within working practices throughout our operations.  Further measures in place include:

Fraud Detection Measures

Furthermore, significant fraud detection measures are embedded within our systems and working practices including:

Risk Management Framework

The effective application of the Enterprise Risk Management Framework is a further measure in place to prevent and/or detect fraud, specifically during:

Definition

EirGrid defines fraud as an intentional act of deceit to obtain or attempt to obtain an unjust/illegal advantage, for example to make a gain (financial or otherwise), to avoid an obligation or to cause loss to another party. For the purposes of the Fraud Policy, the term “fraud” includes attempted fraud. 

Reporting Procedures

All persons to whom this policy applies: 

Discovery of a Potential Fraud Incident (Dos and Don’ts)

Protection

EirGrid is committed to ensuring that all parties to whom this policy applies can raise a concern relating to fraud or suspicions of fraud without fear of victimisation and that the strictest confidence will be maintained.  For further information you should consult the Protected Disclosures Policy. 

Investigations Process and Resulting Action

EirGrid commits to investigate all frauds that are discovered or suspected.  Every case of attempted or suspected fraud will be thoroughly investigated and dealt with appropriately without regard to the position held or length of service of the individual(s) concerned, or their relationship to EirGrid. 

The Head of Internal Audit has the primary responsibility for the co-ordination of investigation of all suspected fraudulent acts as defined in the policy.  

The Head of Internal Audit shall seek support from the Chief Finance Officer, Head of Governance, Risk & Compliance and Head of Group Legal Services in advance of an investigation commencing (Fraud Oversight Group).  The investigation will be carried out by appropriately skilled person(s), in line with EirGrid’s Fraud Response Plan.

No person should attempt to conduct their own investigations. 

The Head of Governance, Risk & Compliance reports all incidents of fraud on a quarterly basis to the Audit & Risk Committee. The Fraud Investigation process is presented in the diagram below.

Enforcement 

Any individual who is under investigation for suspected or discovered fraud may be suspended, pending the outcome of the investigation. 

Where the allegations are substantiated, disciplinary action, up to and including termination of employment, may be taken.

Where the allegations are substantiated, any other party to whom this policy applies may have their contract with EirGrid terminated and/or appropriate action may be taken against the individual(s) concerned, and legal redress may be sought.  EirGrid is obliged under statute to report suspected criminal activity to An Garda Síochána.

Implications of non-compliance with the Fraud Policy 

Non-compliance with the Fraud Policy by EirGrid employees may be treated as a disciplinary matter. 

Non-compliance with the Fraud Policy by any other party to whom it applies, may result in a recommendation to terminate their contract with EirGrid or terminate the engagement of the individual(s), within that contracting entity, found to be in breach of the policy. 

Confidentiality 

EirGrid treats all information received confidentially.  Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know.  

This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect EirGrid from civil liability. 

The Head of Governance, Risk & Compliance shall ensure that: 

This policy shall be reviewed by the Head of Governance, Risk & Compliance and the Audit & Risk Committee and approved by the board on an annual basis.

Employee

Cybercrime

Procurement

Accounting

Financial Misstatement