4.0 People-related countermeasures

None of the countermeasures will be effective if there is high level insider complicity (as in the involvement of the business owner, management or employees in criminal activity in illegal practices such as covert operations by running out of hours processing known only to a select few). Internal staff have more access to processing facilities than external staff but all individuals can have opportunity if uncontrolled by appropriate guardians or protocols to perpetrate a crime (Table 1).

Table 1. Opportunity to conduct fraudulent activities by internal and external staff / non-workers (CPNI 2013; Leathers, 2014)

Types

Direct Opportunity

Internal

Permanent

Contract

Temporary

High: full, frequent and extensive legitimate access to processing facilities.

External

Contractors / cleaning / maintenance

Suppliers

Distributors / transporters

Medium: legitimate access to parts of premises and trusted status if appropriate personnel security countermeasures are in place.

Non-workers

Low: no legitimate access to processing facilities if appropriate personnel security countermeasures are in place.

Table 1. Opportunity to conduct fraudulent activities by internal and external staff / non-workers (CPNI 2013; Leathers, 2014)

A high number of threats vulnerabilities occur particularly from insider acts. These can be addressed via countermeasures such as pre-employment screening checks, visitor and supplier staff controls, security controls, employee vigilance and social engineering, and empowering employees to tip off or whistleblow.

Figure 2. People-related countermeasures

Pop up notes for Figure 2:   – this will be an interactive feature in the final product

Employee vigilance

Understanding threats and the potential impact (e.g. public health, economic losses were they to lose their own jobs) will encourage and motivate staff to be more vigilant. Staff can be simply complacent and think that they or their organizations are not at risk of food crimes (CPNI, 2015). Education and provision of vigilance guidance is a powerful deterrent for fraudsters.  

 

Social engineering

Social engineering or manipulation occurs when fraudsters build and exploit inappropriate trust relationships with internal staff in order to gain access to sensitive information or restricted areas. All employees are vulnerable to social engineering and can be countermeasure via education and awareness  Employees should be made aware of social engineering and understand the value of information (e.g. product formulation, processing steps, production scheduling and delivery etc.) that they hold (CPNI 2013, 2015).

 

Pre-employment screening checks

Robust checks on previous workplace behavior (via references), any history of fraudulent behavior prior to recruitment (CPNI, 2015).

 

Security control

Accessibility to site and processing facilities limited to certain staff. Adhere to security policies and practices, prevent individual decision maker who may be in a position to manipulate systems or data without needing endorsement from second employee.

 

Supplier / Visitor controls

Individuals should have limited access to critical processing sites. 

Individuals must be registered and abide by site GMP requirements   and be accompanied by staff at all times.

 

Whistleblowing measures

Food crime incidents can be deterred by empowering employees and management to whistleblow anonymously, or by providing confidential hotlines in order to report frauds. Internal proactive mechanisms such as internal audits and employee monitoring programmes were also more effective (higher rate of detection and faster) compared to passive detection methods (e.g. notification by law enforcement, external audit and by accident). In the UK, the Public Interest Disclosure Act 1998 protects workers from unfair treatment or victimisation from their employer if they report wrongdoing in the workplace.

 

The whistleblowing procedures and facilities provided by the National Food Crime Unit, Food Standards Agency UK enabled potential whistleblowers to report to the Food Crime Confidential (FSA, 2016a). This is specifically for food crime which involves dishonesty at any stage within the production or supply of food, drink or animal feed. Members of the public are encouraged to whistleblow or to report suspicions of food fraud to their local authority or the National Food Crime Unit (FSA, 2016b). Individuals can leave an anonymous message via the Food Fraud Hotline or they can speak directly to a member of the Food Fraud Team. All intelligence received is logged on the food fraud database and the identity of the whistleblower is protected at all times. FSA will then contact the relevant local authority to investigate the issue raised at a local level and to report the outcome of their investigation to the FSA. Outcomes are logged on the Food Fraud Database and reported back to the whistleblower (if requested) (FSA, 2016b; IMTA, 2016).

 

However, it is crucial that we understand the potential consequences of whistleblowing. Whistleblowers had suffered negative consequences such as altered responsibilities, refusal of pay increment, lack of peer support, loss of employment, stigmatised (e.g. as a troublemaker), lack of progression, and threats of isolation.  

 

There are some pragmatic steps that can be carried out by the food industry. Food industries whether large or small, should encourage a culture of integrity with an emphasis on food safety and quality. A strong internal ethical organisation and protection of whistleblowers will encourage the likelihood of whistleblowing among food production workers. Food industry should ensure that internal reporting channels are available for staff and should be exhausted before using external channels since it allows companies to rectify the wrongdoing internally (Near and Miceli, 1985). Ultimately, food industry should aim for internal reporting of potential frauds and to resolve the problems internally whilst ensuring confidentiality of the whistleblowers. By resolving potential fraudulent practices internally, this can help to prevent or reduce loss of profit, reputation and trust with customers. Ensuring confidentiality of the whistleblowers are crucial as this can help to mitigate potential retaliation against whistleblowers. Small and medium food companies may not have the resources to carry out food fraud or threat assessment but  with training and education during induction and refreshers’ training, food fraud examples can be shared with staff (as lessons learnt from other food industries) and to demonstrate the correct reporting process (Soon and Manning, 2017).