Rc No: 1146549

FRAUD DETECTION PLAN

AND
STANDARD OF CARE
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CONTENTS
1. ABOUT US 4

2. OUR BUSINESS 4

3. OBJECTIVES 4

4. DEFINITION AND NOTION OF FRAUD 4

5. CURRENT ACTORS, ROLES AND RESPONSIBILITIES 5

6. THE ANTI-FRAUD CYCLE 6

6.1. Risk assessment 6

6.1.1. External risks 6

6.1.2. Internal risks 7

6.2. Prevention 7

6.2.1. Control environment 7

6.2.1.1. Prevention measures in the area of human resource management: 8

6.2.1.2. Prevention measures in the area of financial and procurement management: 8

6.2.1.3. Prevention measures in the area of sensitive functions (Operations): 8

6.2.1.4. Handling of deviations from the regulatory framework 8

6.2.2. Raising staff awareness on fraud risks 8

6.2.3. Rules on the acceptance of gifts, donations and favours are in place in Top Up Africa. 9

6.2.4. Raising awareness among external partners and stakeholders 9

6.3. The Detection Phase 9

6.3.1. Before the implementation of an activity 9

6.3.2. During the implementation of an activity 10

6.3.3. After the implementation of an activity 10

6.4. Investigation 10

6.5. Sanctions and recovery 11

7. RESIDUAL AREAS OF INTERVENTION 11

7.1. Increase Top Up Africa internal efficiency and effectiveness in addressing potential fraud 12

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7.2. Increase level of assurance that potential fraud is prevented and detected 12

ANNEX A –FRAUD PREVENTION MEASURES 13

Financial and procurement management 13

Human resource management 14

Programme management 14

ANNEX B –FRAUD DETECTION MEASURES 15

Financial and procurement management 15

Human resources management 15

Programme management 15

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1. ABOUT US
Top Up Africa Ltd(The Company, us, our, we, TUA, Top Up Africa) operates as a super
agent company based in Nigeria. We have created a well managed agent network
which promotes the electronic trading of goods and service; leveraging on our robust
technology and agents spread to facilitate payments such as bills payments, airtime,
cash withdrawal and deposit, agent mobile payment/banking services, funds
transfers, and other On-demand services.

2. OUR BUSINESS
Top Up Africa is a Nigerian technology company focused on financial services
solutions. Our mission is to make financial services available and affordable to all. We
have built a robust payment application to serve the unbanked and underbanked
areas in Nigeria through our growing Agent Network.
Top Up Africa is a pro-active developer and provider of platforms and constantly aims
to offer in-demand solutions, our technology team is vastly experienced with support
from around the globe. Our goal is the provision of value through technology,
constant accessibility and availability of intangible products and services.

Our specialists help our clients recognize and measure processes that can crystalize
value in their business activities using technology. As a business dedicated to
consistently delivering value to our clients, our management consultancy services
extend to: Business analytics, project management, custom-made application, design
and growth.

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3. OBJECTIVES
The objective of this fraud detection plan is to ensure the prevention and detection of
fraud within Top Up Africa and to identify the residual areas of intervention needed to
strengthen Top Up Africa’s anti-fraud framework. This overall approach contributes to
developing and implementing an anti-fraud culture within Top Up Africa.

4. DEFINITION AND NOTION OF FRAUD

Fraud is a deception deliberately practiced in order to secure unfair or unlawful
gain. It requires two elements: the breach of a rule and the intention. Intention is
the key element, the trigger event which distinguishes fraud from irregularity.

For the purpose of this Strategy it is useful to identify fraud risk areas and to
draw the distinction between External and Internal fraud:
• External fraud refers to situations in which contractors/providers are
under suspicion of committing fraud, but where there is no involvement
of internal staff.

• Internal fraud refers to situations in which Top Up Africa staff would be

involved in committing the fraudulent behaviour or operation, either
alone or in collusion with contractor or other external parties.

Fraud relates to financial and non-financial aspects. Whereas financial gain is

believed to be the key motivator in the majority of fraud cases, nevertheless,
non-financial aspects could also lead to fraud, for example leaking of
confidential or sensitive information.
It is also important to highlight that there is no materiality threshold for fraud,
which, due to its malicious nature, should not be tolerated in any form and will
be sanctioned in all cases where confirmed.

5. CURRENT ACTORS, ROLES AND RESPONSIBILITIES

The following internal and external actors play a role in the various anti-fraud activities
described in this strategy document.
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ACTOR ROLES AND RESPONSIBILITIES

Top Up Africa corporate quality management
● Ensuring the provision to the organisation of an effective
and proportional quality and risk control framework
Head Internal Control (ICC)
based on quality tools and procedures and Internal
Control Standards (ICS)
Top Up Africa risk management and audit coordination
● Designing and implementing Top Up Africa risk
management processes and related activities
Financial management
● Performing centralised ex-ante Financial
Verification function on medium and high-risk
commitments and payments;
● Performing annual ex-post exercise on selected
Finance and Procurement
financial transactions
Procurement management
● Most internal controls and procedures are defined in
rules and guidelines that apply across Top Up Africa
● Supporting the raising awareness activities on ethics
and integrity;
● Implement the Staff Regulations and relevant
HR
financial rights on the basis of original documents;
● Chairmanship of the Promotion Boards and
Recruitment Panels;

Management (senior and middle

● Performing risk based self-assessment exercises;
managers)
● Overall responsible for setting up an effective
Director
internal control system
Top Up Africa SFU Correspondent
Legal Advisor (LA) ● Managing Top Up Africa fraud cases;
● Interfacing with NFIU and SFU

Board Appointed Auditors • Perform audits and risk assessments of Top Up Africa
Internal Control System and Top Up Africa processes

Nigerian financial intelligence Unit Nigerian arm of the global Intelligence Unit and the Nigerian
(NFIU) and The Nigerian police Police
special Fraud Unit ● Conducting internal and external investigations
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6. THE ANTI-FRAUD CYCLE

The anti-fraud cycle is composed of the following phases:
• Risk Assessment;
• Prevention;
• Detection;
• Investigation;
• Sanction and Recovery.

This section provides an overview of how Top Up Africa anti-fraud approach covers all
stages of the anti- fraud cycle.

6.1. Risk assessment

The present Strategy builds on the results of a risk analysis that has been carried out
within Top Up Africa mainly on the basis of the following existing institutional sources
and exercises:

• reports of board appointed auditors and their conclusions on fraud

problematic;
• Top Up Africa’s cases of fraud or suspected fraud in the past;
• the assessment carried out in the context of drafting and regularly reviewing
Top Up Africa policy on sensitive functions;
• the risk assessment carried out in the context of drafting Top Up Africa
overarching guidelines for preventing and managing conflict of interest;
• the annual risk assessment process (macro level & operational level);
• main organisation’s developments and their potential consequences in terms
of new type of frauds;
• the risks of fraud /corruption identified during the quarterly reporting exercise.

Fraud includes both external as well as internal misconduct, as described in the

following sub sections.

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6.2 External risks

The external risks of fraud are defined as those resulting from fraudulent behaviours of
non-staff members adversely impacting Top Up Africa (financial and reputational).
They may be classified into financial and technical risks. A non-exhaustive list of
examples follows below.

Financial risks
• Intentional false declaration (forged document, false costs);
• Misrepresentation of organisational, physical and/or financial situation of an
Agent
• Sub-Agent or beneficiary;
• Double funding;
• Fraudulent bankruptcies;

Technical risks
• Plagiarism of proposals and/or deliverables;
• Selection of agents based on forged documents/false declarations, false CVs;
• Professional misconduct (e.g. falsifications, fabrications of data).

6.3 Internal risks

The internal risks of fraud are defined as those resulting from fraudulent behaviour by
staff of Top Up Africa and correspond mainly to an intentional breach of regulations.
The most common areas where internal fraud risks may occur are recruitment,
procurement and requests for reimbursement of expenses.

Typical examples (non-exhaustive) of potential risks identified within Top Up Africa are:

Conflict of interest of members in selection panels for recruitment, assessment and

approval of Agents and procurement activities with Agents/Trade partners;

Intentional false declaration, for example:

• Recruitment: forged certification, false experience, false place of origin;
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• Mission reimbursements: forged invoices/receipts;

• False declaration of working time;
• Sickness and absences: forged documents, abuse of declarations, work for
external parties during sick leave or other types of special leave;
• Reimbursements in general: forged document, abuse of declarations;

Misappropriation of goods;
• Double funding, e.g. multiple reimbursements of expenses;
• Unethical behaviour in accepting services in return for preferential treatment;
• Pressure by the hierarchy to provide preferential treatment to certain actors;
• Preferential treatment in staff performance assessment (favouritism).

6.4 Prevention

Control environment
The Director of Top Up Africa is responsible for the internal control systems. This
responsibility is exercised through the Head Internal Control, who bears the
responsibility for setting up and supervising the overall control system of Top Up Africa
(16 Internal Control Standards), and the Delegated Authorising Officers who bear
responsibility of setting up of dedicated controls and procedures for the processes
within their area of delegated responsibility.
Particular attention in this section is given to prevention controls and measures in the
area of operations, human resource management, finance and procurement,
sensitive functions, and the handling of deviations from the regulatory framework.

6.1.1.1. Prevention measures in the area of human resource

management:

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Human resource management is governed by the applicable Staff Regulations and

Implementing Rules.

Annex A – fraud prevention measures list the control measures in place at Top
Up Africa preventing fraud risks.

6.1.1.2. Prevention measures in the area of financial and procurement

management:
In the area of control management, the Financial Regulation and Implementing Rules
applicable to Top Up Africa provide a large set of control measures preventing fraud
risks, which where necessary are further reinforced by procedures introduced by Top
Up Africa.

Annex A –Fraud prevention measures lists the control measures in

place at Top Up Africa preventing fraud risks.

6.1.1.3. Prevention measures in the area of sensitive functions

(Operations):
A policy is in place that governs the management of sensitive functions. Sensitive
functions are reviewed at least once every Two years or more often if circumstances
require so.

6.1.1.4. Handling of deviations from the regulatory framework

Deviations from the regulatory framework are governed by the Register of Exceptions
procedure. The overall objective of the procedure is to establish appropriate
arrangements to ensure that Top Up Africa Director(s) and Management register any
exceptional circumstances of significant instances of overriding controls or deviations
from the established and in force Top Up Africa regulatory framework; and report
them to the Governing Board and Discharge Authority in accordance with the
principle of transparency. The exception must be documented and justified. They are
analyzed within the context of Top Up Africa’s Progress Report in order to identify
systemic weaknesses and to put in place adequate preventive controls.

6.1.2. Raising staff awareness on fraud risks

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Top Up Africa Intranet has dedicated sections that inform staff about ethical and
organizational values.

Compulsory raising awareness and training activities take place for staff upon
entrance into functions on financial matters and ethics and integrity principles,
covering issues such as staff’s liability, prevention and reporting of fraud and
irregularities. Regular refreshment activities are available on a voluntary basis. Staff
attendance is registered.
6.1.3. Rules on the acceptance of gifts, donations and favours are in place in
Top Up Africa.
Managers are requested to sign declaration of commitments and interests on an
annual basis. These declarations, complemented with a summary CV, are published
on Top Up Africa website.

6.1.4. Raising awareness among external partners and stakeholders

General conditions of Top Up Africa contracts refer to SFU and include contractual
clauses to protect against fraud and other irregularities. Grounds for termination of
contract include professional misconduct, non-compliance with obligations relating to
commitment of fraud or corruption, submission of false information and any other
illegal activity detrimental to Top Up Africa’s financial interests. They also indicate the
possibility of being submitted to on-site audits e.g. by Top Up Africa and/or SFU.

Governing Board members are requested to sign declaration of commitments and

interests on an annual basis. These declarations, complemented with a summary CV,
are published on Top Up Africa website.

6.2. The Detection Phase

Top Up Africa has put in place systems which give reasonable assurance that major
irregularities and fraud will be detected. This implies that the Agency must
(i) recognize indicators (red flags) that fraud may have been committed,
(ii) identify control weaknesses that could allow fraud to occur, and

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(iii) assess whether a fraud investigation should be conducted by SFU.

Such red flags may also be identified through several processes of data mining of
information available within, SFU and/or on the Internet.

Annex B – Fraud detection measures lists the main control measures in place at Top Up
Africa detecting fraud risks.

Detection of a potential (risk of) fraud can occur during three different phases:

• Before the implementation of an activity;

• During the implementation of an activity;
• After the implementation of an activity.

6.2.1. Before the implementation of an activity

Activities are regularly implemented by means of procurement. Top Up Africa's fraud
risk analysis has identified possible risks that could be addressed before or during the
procurement as follows:
• Check the proposal against possible plagiarism;
• Check eligibility, verify the legal existence of the financial and operational
capacity of agents;
• Verify whether participants are listed in the exclusion database and consider
appropriate risk mitigating measures
• Independent central ex ante verification by Top Up Africa Finance and
Procurement is in place for medium/high risk financial transactions (budgetary
commitments and pre- financing payments).

6.2.2. During the implementation of an activity

During the assessment of the deliverables submitted by the beneficiary’s specific
attention is required from the project officers to detect possible plagiarism, fabrication
of results, underperformance, misrepresentation, etc.

Independent central ex ante verification by Top Up Africa’s Finance and Procurement

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team is in place for medium/high risk financial transactions (top-up of budgetary

commitments and interim and final payments).

In performing controls, the quality and presence of the supporting documents

(invoices, certificate of attendance, supporting travel documents, and declarations) is
carefully assessed.

6.2.3. After the implementation of an activity

Top Up Africa has in place an ex-post audit policy aimed at targeting on an annual
basis its audit resources to those activities that have been identified at risk for their
financial and/or reputational exposure.

Top Up Africa is also subject to regular institutional audits by the Board Appointed
Auditors and the Central Bank of Nigeria. In particular, Top Up Africa’s Financial
statements are subject to the approval of the Board appointed auditors.

The other measures are described in the above-mentioned Annex B – Fraud detection
measures.

6.3. Investigation
For external fraud, once a potential occurrence of fraud has been detected, the case
is brought to the Director for her /his decision on the course of actions to be
undertaken. Where appropriate the following actions are launched:

• Flagging the entity within the Database and notification about the risk of
fraud.
• Transmission of the case to SFU for external investigation by the Top Up Africa
SFU correspondent.

Following the outcome of its pre-analysis, SFU will decide whether it will launch an
investigation. Each case transmitted to SFU is being followed up by the SFU
correspondent.

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For internal fraud, the potential occurrence of fraud by staff members is

addressed to the hierarchical superior or to the Top Up Africa Director or directly
to the SFU. The Top Up Africa SFU Correspondent, in consultation with the
Authorizing Officer, is responsible for liaising with SFU.

6.4. Sanctions and recovery

Agents may be flagged in the Early Warning System (EWS) if they commit an
irregularity in the implementation of the activity; they may also, under certain
conditions, be excluded from further participation in future procurement award
procedures (i.e. listed in the exclusion database which is an integral part of the EWS
system).

Contracts provide clauses for e.g. liquidated damages and financial penalties,
recovery, suspension of payments, possibility to terminate the contract.

These measures contribute to an effective control environment by providing

mechanisms for correction upon detection of errors and provide a dissuasive effect
against overcharging by beneficiaries.

In case of internal fraud, measures will be decided according to the provisions of the
Staff Regulations.

In this context the Top Up Africa intends to draw a disciplinary procedure which inter
alia will address relevant sanctions and recovery. In addition, Top Up Africa intends to
nominate internal staff to be trained as investigators in view of establishing an Inter-
Agency pool of investigators and handling the need for administrative inquiries.

7. RESIDUAL AREAS OF INTERVENTION

As results from the risk analysis, Top Up Africa already has many measures in place that
directly or indirectly provide a safeguard to the risk of fraud and the dealing with
potential occurrences of fraud.
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Nevertheless, Top Up Africa believes that the anti-fraud approach can be

strengthened further, both through strengthening and streamlining internal processes
and procedures, and by ensuring that individual staff members are thinking and
acting with fraud awareness.

Much of the present Anti-Fraud Strategy is therefore placed on communication and

awareness-raising among all staff involved in preparation and implementation of the
Top Up Africa activities, along with the improvement and development of supporting
tools and guidance.

Taking into account the above, the Top Up Africa has decided to concentrate its
efforts on achieving the following strategic areas of intervention.

7.1. Increase Top Up Africa internal efficiency and effectiveness in addressing

potential fraud
The instruments at the disposal of Top Up Africa staff need to be strengthened in order
to allow staff to flag and treat potential fraud cases in a more efficient and effective
manner.

Top Up Africa informs SFU of all cases of suspected fraud or other illegal activities that
are brought to its attention. The existing procedure needs to be strengthened and
further documented to fix clearly the repartition of responsibilities within the Top Up
Africa, the deadlines to respect, the channels of communication, the tools used, the
follow-up required (recovery and potential penalties etc.).

The role of the Top Up Africa SFU Correspondent needs further enhancement, in
particular with respect to ensuring regular feedback to the Director.

In addition, based on experience in other public organizations, it is essential to provide

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formal safeguards and protection to whistleblowers.

7.2. Increase level of assurance that potential fraud is prevented and detected
Fraud is, by definition, malicious and perpetually evolving. Unlike other forms of risks, it
can materialize while staying unnoticed. At a first level, there is therefore a need to
make the identification of fraud risks as proactive as possible.

While training courses on subjects that include aspects of what could constitute
fraudulent behaviour (financial, ethics, internal control standards, etc.) exist and are
provided by Top Up Africa, these need to be reviewed and reinforced to ensure that
they address sufficiently and expressly the issue of potential fraud, how it is evolving,
and how staff is expected to deal with it. As a consequence, the Top Up Africa staff
shall be encouraged to attend training offered on anti-fraud at a horizontal level and
most importantly, they need to be given the tools to recognize what and when they
are dealing with a potential case of fraud.

In addition, information shall be available on the intranet. The information also needs
to be further developed and better organized and documented to allow for easy
access and clear guidelines on how to act in these situations.

Fraud risk assessment shall be a part of the standard process review cycle and macro
risk management processes.

ANNEX A –FRAUD PREVENTION MEASURES

The below list of fraud prevention measures distinguishes between three main areas:
Financial and procurement management, Human resources management, and
Programme management. Many of its components are retrieved from the risk
assessment in the context of sensitive functions.

Financial and procurement management

Compulsory raising awareness and training activities on financial matters and ethics and
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integrity
principles upon entrance in function. Regular refreshment activities available on a voluntary
basis;
Double signature on bank transactions (authorisation on bank accounts only approved by
the Director.
The Director himself has no authorisation on the bank accounts. Only the Director can
open a new bank account.
Financial statements subject to approval of Board appointed Auditors and subject to
opinion of the
Governing Board
Full articulated (sub)delegation of budget implementation powers, responsibility and
authority limits
are clearly defined;
Segregation of duties ensured, between roles, incompatibility of roles, and regarding
subordination:
Segregation and subordination rules between initiation and verification (“4 eyes principle”).
Incompatibility of roles between Authorising officer, Accounting officer and Financial
verifying agent
(FVA),
Financial systems are validated by the Accounting Officer
Segregation of duties ensured by adopted financial circuits (four eyes principle
Signed charters of authorising officer, (sub-) delegated authorising officers’
responsibilities/roles
Operational actors in the financial circuits are nominated by responsible authorising officer
and
nomination forms define responsibilities
All (delegated) authorising officers are requested to sign declaration of commitments and
interests on
an annual basis, which are publicly available on Top Up Africa website
Regular risk-based review of the adequateness of the financial circuits in place at Top Up
Africa
All beneficiaries’ bank account and legal entity data must be validated before proceeding
with the legal/budgetary commitment

All payments are processed on the basis of original invoices/payment requests or

certified copies, other necessary documentation prescribed in the contract, and only
after receipt of certification of
correctness by beneficiary of the services/goods received
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All documentation to finance and procurement transactions is stored

electronically/physically
according to established retention rules
Formal appointment by authorising officer of tender opening and evaluation committees,
members
from different departments/units
Members of opening and evaluation committees provide self-declaration on conflict of
interest (professional-personal) on which basis the authorising officer may decide to
replace the committee
member
Continuous guidance and support are provided by procurement team to committee
members for the
assessment of eligibility, selection and award criteria for all tendering procedures
Revised Register of Exceptions procedure requires prior approval of AO in relation to any
exception

Human resource management

The Director has a limited contractual term. He /she is the Appointing Authority responsible
for
all staff matters;
Staff members can submit a request or a complaint to acts adversely affecting them
Top Up Africa Annual Dialogue (objectives setting and appraisal) procedure in place: each
step is recorded and "countersigned" by both the Job Holder and the Reporting Officer.
The Job Holder always has the "last word" in the appraisal workflow and can appeal to the
Appeal Assessor
Promotion / reclassification: The Promotion Board (composed of 3 members including Staff
Committee
representative), after assessment of comparative merits, presents a recommendation to the
Director;
The Appointing Authority appoints Board members (promotions, selection) and take decision
on
outcome considering the recommendations from the Board members;
Selection & Recruitment: The Selection Assessment Board (composed of 3 members
including Staff Committee representative), after assessment of the candidate’s profiles,
presents a recommendation to the Director;
Members of Selection Assessment Board provide self-declaration on conflict of interest
(professional-

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personal) on which basis the Appointing Authority may decide to replace the Board
member.
Staff financial entitlements are prepared by Top Up Africa HR
Requests for allowances or other payments (staff rights) are processed on the basis of
original
documentation or certified copies.

Programme management
A Clear procedure for programme management has been established in Operations,
Administration,
IT, Customer service and Financial Departments;
All Implementation Plans are endorsed by the management approved by the Director and
published
on the web site;
In the Top Up Africa Operations the Project Team Leaders and Project Team Members are
involved in drafting of Implementation Plans, a quality review step is foreseen by content
Peers and Admin Community before the Head of Department. There is constant monitoring
through quarterly reports.
project management process involves: All teams, peer review, quarterly reports, mission
reports, publicity of all relevant documents related to the country.
Project management decision-making process is articulated in a number of steps,
involving other team members; constant monitoring through quarterly reports. The
possibility of influencing management is more related to technical expertise and should
be considered a natural and positive
attribute to a project manager in a centre of expertise such as the Top Up Africa;

ANNEX B –FRAUD DETECTION MEASURES

The below list of fraud detection measures distinguishes between two main areas:
Financial and procurement management, Human resources management and
Programme management. Many of its components are retrieved from the risk
assessment in the context of sensitive functions.

Financial and procurement management

Annual sampling ex post audits/controls by external chartered auditors.
Top Up Africa and Board appointed independent auditors;
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Ex post transactional and procurement controls by Top Up Africa Finance and Procurement
Reporting to the Governing Board (Annual Activity Report).
Work Programme activities and budget adopted by the Governing Board.

Human resources management

Top Up Africa and Board appointed independent auditors;

Programme management
Top Up Africa and Board appointed independent auditors;
Sampling ex post audit/control by external chartered auditors;

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