| REMEDIAL MEASURES
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| (i) Measures taken
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| C&AG's Report, para 23
| 32. As soon as the case came to light in 1994, the Administration issued instructions that:
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- pensioners collecting their pensions at Embassies and High Commissions should provide proof of their identity and sign against their name on a monthly acceptance record;
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- pensioners' signatures must be witnessed by a UK-based member of the Embassy or High Commission staff;
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- a second member of staff should periodically witness the pensioners' signatures;
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- no uncollected payable orders should be retained at the post for more than three months;
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- pensioners notifying a change of address must do so at the Embassy or High Commission or provide a signed letter; and
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- only UK-based Embassy or High Commission staff who are not normally directly involved in the issue of payable orders should attest a pensioner's Annual Declaration of Entitlement.
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| C&AG's Report, para 24
| 33. When the scale and mechanics of the deception were realised, additional precautions were taken in Amman to help prevent the recurrence of this type of case. To confirm a pensioner's identity at the time of the annual attestation of existence, or when payable orders are collected, the Embassy now has a photo of all the Administration's pensioners in Jordan. The Administration have not deemed it necessary to introduce this additional safeguard in other countries where pensions are paid through Embassies or High Commissions. To improve controls further, however, they are considering the introduction of other measures-such as a requirement, where pensions are collected by a third party, for the nominee to be registered with them before any payments are released. They are also considering a percentage check of cashed payable orders.
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Q 41
Q 43
| 34. In 1995 the Foreign and Commonwealth Office's Financial Compliance Unit reviewed pension payment arrangements at all the relevant diplomatic missions. The responsibilities of staff were identified so that the proper separation of duties could be determined. In January 1997 the Financial Policy Department carried out a review to ensure that these procedures were working. In addition such checks are a specific task for internal audit. There are now only seven missions which handle pensions on behalf of the Administration.
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Q 90
Q 85
| 35. The Administration told our predecessors that it was now extremely difficult for anyone to impersonate a pensioner because:
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- of the process of attestation;
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- of the fact that attestation takes place annually;
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- their records had been cleaned up and were reliable;
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- they propose to undertake random checks, asking pensioners for details only they could know; and
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- they are targeting their checking on vulnerable posts.
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| Every case of suspected fraud has to be brought to the attention of the head of the pensions branch.
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| Q 48
| 36. In 1995 the Administration issued detailed guidance to staff on measures to protect against fraud. This included the regular rotation of staff, the separation of duties, not accumulating backlogs and care in designing new systems.
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| (ii) Conclusions
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| 37. We note the remedial measures taken by the Administration and the Foreign and Commonwealth Office to guard against a repetition of pensions irregularities such as occurred in Amman. We regard it as important for management to ensure that their controls are not only adequate in design but are effectively implemented.
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