Risk: Embedding a Culture of Integrity Ahead of ECCTA

On 1 September 2025, a new piece of legislation will come into effect in the UK: the Economic Crime and Corporate Transparency Act (ECCTA), also known as the “Failure to Prevent Fraud” offence. This landmark legislation introduces a shift in accountability, making companies, not just individuals, liable for fraudulent activity if they fail to take reasonable steps to prevent it.

According to PwC’s 2024 Global Economic Crime Survey, fraud ranks among the top three most disruptive economic crimes globally. The ECCTA recognises this reality and seeks to strengthen corporate resilience by requiring organisations to implement reasonable fraud prevention procedures. But beyond compliance, it offers a deeper call to action: to create workplaces where integrity is the norm and vigilance is a shared responsibility.

OCS is taking this responsibility seriously — and proactively. We have outlined in our Anti-Fraud Statement that we will not tolerate fraud, or anyone involved in it, and are committed to reducing the risk of fraud to the lowest possible level.

Fraud Isn’t Just a Risk. It’s a Cultural Test.

Fraud prevention is not just about protecting the balance sheet. It’s about safeguarding our people, our customers and our reputation. As Martin Lewis, Head of Risk at OCS, explains:

“This legislation introduces two major shifts: companies can now be held liable for fraud, not just individuals, and we must also prevent outgoing fraud, where an organisation may directly or indirectly benefit. That changes the conversation entirely.”

Fraud can take many forms, from overbilling customers to phishing emails targeting frontline colleagues. That’s why our approach goes beyond legal compliance — it’s rooted in our TRUE Values of Trust, Respect, Unity and Empowerment. We’re building a culture where speaking up is encouraged, awareness is constant, and prevention is everyone’s job.

Five Pillars of Stronger Fraud Prevention

In preparation for the ECCTA, OCS based our reasonable fraud prevention framework on five key pillars:

1. Fraud Risk Assessment
   We conducted a group-wide fraud risk assessment to identify the areas in our business most susceptible to fraud. This assessment led to clearly defined controls and actions that are now integrated into our wider risk management framework.
2. Anti-Fraud Policy and Strategy
   We have published a formal anti-fraud policy and developed a long-term strategy to continually strengthen our approach. This framework ensures alignment with our values and Code of Conduct and provides clarity on how fraud risks are managed and mitigated.
3. Training
   Targeted briefing sessions for high-risk roles and business areas are reinforcing awareness and accountability. Our broader Anti-Bribery and Corruption training has also been expanded to include fraud, helping ensure consistent understanding across the group.
4. Communication
   Fraud prevention only works when people are informed and engaged. That’s why our internal campaign focuses on building awareness, promoting escalation routes, and sharing practical guidance. From induction training to posters on-site, the message is clear: if something feels wrong, speak up.
5. Governance Oversight
   Fraud prevention is a board-level issue. Our Executive Committee and Group Audit and Risk Assurance Committee reinforces top-level commitment through accountability and transparency.

Whistleblowing: Speaking Up Is a Shared Responsibility

Central to our anti-fraud culture is creating an environment where people feel safe to raise concerns. That’s why we make it easy — and strongly encouraged — for colleagues, partners and even the public to report anything suspicious.

Our global whistleblowing hotline, Safecall, is available in all local languages and accessible to colleagues, suppliers, customers and third-party partners. It’s one of several escalation routes supported by our comprehensive Code of Conduct, which sets clear expectations of behaviour and responsibility for everyone connected to OCS.

“Colleagues want to know they’re working in a safe, ethical environment,” says Martin Lewis. “Safecall is a critical reporting tool. When people know they can speak up and be heard, that’s when culture becomes your strongest defence.”

Fraud Prevention Is Personal

Fraud isn’t just a corporate concern — it affects individuals too. From phishing scams to identity theft, fraud is a risk in all our lives. That’s why our campaign includes practical tools and advice to help colleagues stay safe outside of work, too. Because real prevention starts with confidence: to pause, question and act.

As Martin notes:

“If you’re more fraud-aware at home, you’re more fraud-aware at work. That’s the level of cultural integration we’re aiming for.”

A Culture of Resilience and Responsibility

For us, our greatest defence against fraud is our people. When colleagues are equipped with knowledge, backed by leadership, and encouraged to speak up, we build more than just compliance — we build trust.

As the ECCTA comes into force, our message is clear: Fraud prevention isn’t a box to tick. It’s a value to live by.