Company:Harwick Group — road freight and warehousing, 820 employees, £42M turnover, Birmingham
Context:Three years in. Performance review in two weeks. Line manager: Marcus Webb (11 years at Harwick).
Thursday, 14 November 2024. In ten months, the ECCTA failure to prevent fraud offence comes into force — but the fraud is already happening.
Harwick Group processed 3,200 supplier invoices last quarter. Procurement is a four-person team.
The Fraud and Ethics Policy was last updated in 2019. Annual compliance training: a 12-minute video.
As a large organisation under ECCTA, Harwick faces unlimited criminal fines if an employee commits fraud for its benefit — unless it proves it had reasonable prevention procedures.
Your inbox has four unread emails.
Before You Start
How This Works
This is a choose-your-own-adventure investigation. You’ll make real decisions that a Head of Finance encounters when fraud signals appear — your choices determine whether Harwick Group can prove it had reasonable prevention procedures.
Case Quality Score
+3Best practice — what a fraud prevention specialist would recommend
+1Reasonable but incomplete — on the right track
−1Risky or non-compliant — exposes the company to ECCTA liability
Case File Panel
The sidebar tracks evidence and legal references as you build the case. Click any entry to review it. The progress bar shows your investigation quality in real time.
Your Verdict
Your final score determines your verdict: Compliant, Partial, or At Risk. Every decision is explained regardless of which path you take.
Thursday, 14 November 2024, 08:47
Your Inbox
Four unread emails. Read each one. Which requires your most urgent attention?
Alex — Sunridge INV-2024-1847 is going out today. Before you submit it to AP, I need you to update the delivery quantity on line 3 from 240 units to 380 units…
Hi team, Finance is running a spot check on 5% of Q3 supplier invoices as part of our standard quarterly review. If your name is on the attached list…
Thursday, 14 November 2024, 08:53
You Read the Other Emails First
You spend six minutes on emails that required no immediate action. A remittance advice. A performance review reminder. A routine spot-check notification.
Accounts Payable — Invoice Queue Alert
INV-2024-1847 (Sunridge Logistics) has been flagged as pending coordinator sign-off. AP processing deadline: 11:00 AM today. If sign-off is not received by 10:30 AM, the invoice will be escalated to your line manager for direct submission.
While you were reading routine emails, Marcus’s invoice moved closer to the deadline. AP has now flagged it. If you don’t act soon, Marcus may submit it himself — with the altered quantities. You’ve lost the window to catch this early. Now open Marcus’s email.
Signal vs. Noise
Fraud instructions rarely arrive marked “URGENT: FRAUD.” They are buried in routine email traffic — sandwiched between remittance advices and HR reminders. The ability to triage your inbox and identify the instruction that doesn’t belong is the first line of defence. You missed the signal. The clock is now shorter.
Thursday, 14 November 2024, 08:47
The Email from Marcus
You open Marcus’s email first. Sunridge Logistics is one of Harwick’s tier-2 suppliers. The instruction is buried in the second paragraph, written in the same tone Marcus uses to ask you to book meeting rooms.
Alex,
Sunridge INV-2024-1847 is going out to the client today. Before you
submit it to AP, I need you to update the delivery quantity on line 3
from 240 units to 380 units. The price per unit stays the same at
£47.50, so the line total moves from £11,400 to £18,050.
Background: the original delivery run came in under schedule because
of the M6 closure on the 8th. We absorb those margin hits but the
client contract allows for recovery on volume variances. This is
standard reconciliation — it happens every quarter.
No need to loop anyone else in. Just make the change and submit.
I’ll handle the client side.
Marcus
The arithmetic is clear. 240 units actually delivered. 380 units on the invoice. The difference: 140 units × £47.50 = £6,650 that Harwick would charge the client for deliveries that never happened. Marcus has been at Harwick for 11 years. Your performance review is in two weeks.
Thursday, 14 November 2024, 08:52
Reading Between the Lines
Marcus’s email reads as a routine request. But buried in the language are five classic fraud rationalisations — phrases designed to make a dishonest instruction sound like normal business. Read the email again. Click the phrases that should raise your concern.
Alex,
Sunridge INV-2024-1847 is going out to the client today. Before you submit it to AP, I need you to update the delivery quantity on line 3 from 240 units to 380 units. The price per unit stays the same at £47.50, so the line total moves from £11,400 to £18,050.
Background: the original delivery run came in under schedule because of the M6 closure on the 8th. We absorb those margin hits but the client contract allows for recovery on volume variances. This is standard reconciliation — it happens every quarter.
No need to loop anyone else in. Just make the change and submit. I’ll handle the client side.
Marcus
Phrases flagged: 0
Thursday, 14 November 2024, 09:05
Risk Ranking
Before you respond to Marcus, you pause. Something about the instruction does not sit right — but you cannot immediately name why. Rank the five actions below from highest legal risk (1) to lowest legal risk (5).
Each rank must be unique — two items share the same number.
Case Briefing — Legal Context
The Law: ECCTA Section 199
Before you decide how to respond, you need to understand the law that changed the stakes. Since 1 September 2025, the Economic Crime and Corporate Transparency Act 2023 has introduced a new corporate offence:
Failure to Prevent Fraud — s.199
If an employee commits fraud intending to benefit the organisation, the company itself is criminally liable — unless it can prove it had “reasonable fraud prevention procedures” in place.
This is not about individual guilt alone. The company faces an unlimited fine. The only defence is proving that reasonable procedures existed before the fraud occurred.
The 6 Home Office Principles for Reasonable Procedures
1.Risk Assessment
Identify and assess the nature and extent of fraud risks.
2.Top-Level Commitment
Senior management must foster a culture of fraud prevention.
3.Due Diligence
Apply due diligence to persons associated with the organisation.
4.Communication & Training
Ensure fraud prevention policies are embedded through training.
5.Monitoring & Review
Regularly review and improve prevention procedures.
6.Proportionality
Procedures must be proportionate to the risks faced.
Key point: A 2019 policy document and a 12-minute annual video will not satisfy these principles. The question you are about to face is not just “did someone commit fraud?” — it is “did the company do enough to prevent it?”
Thursday, 14 November 2024, 09:22
Your Response to Marcus
⚖
Investigation DecisionDecision 1 of 3
The Sunridge invoice is due to Accounts Payable by 11:00 AM. If it is late, Marcus will know you held it. You re-read the email. 240 units actually delivered. Marcus wants 380 on the invoice. The difference — 140 units at £47.50 — is £6,650 Harwick would charge the client for deliveries that never happened. Marcus has been at Harwick 11 years. Your performance review is in two weeks. He has signed off your last two pay increases. Under Fraud Act 2006 s.1, making a false representation on a document — knowing it is untrue, intending gain — is a criminal offence. The ECCTA 2023 s.199 offence means Harwick Group would also be criminally liable. You would be the person who made the false representation.
What do you do with Marcus’s instruction?
Your choice
📄
Make the change and submit the invoice
Marcus is your line manager. He says this is standard reconciliation. You make the change and submit INV-2024-1847 with 380 units on line 3.
Your choice
✉
Reply asking Marcus to confirm in writing
You reply to Marcus saying you want written authorisation before changing a submitted quantity. You ask him to confirm the client contract clause.
Your choice
📞
Hold the invoice and call the fraud reporting line
You do not submit the invoice. You call Harwick’s confidential fraud and ethics reporting line and report Marcus’s instruction with the full email chain.
Thursday, 14 November 2024, 10:58 AM — and the months that follow
−8 Exposed
The Invoice Goes Out
Marcus Webb
Procurement Manager
Good. Invoice confirmed received by AP. Client won’t query it — they never check the line detail on freight volumes. You did the right thing.
Alex Drummond
Procurement Coordinator
Right. Standard reconciliation.
Case File
Investigation Record
INV-2024-1847 was submitted at 10:58 AM on 14 November 2024. Line 3 stated 380 units delivered. Actual delivery: 240 units. Difference: £6,650. The client — Meridian Retail Ltd — paid in full on 29 November 2024.
You submitted a document you knew to be false. The quantity was wrong. You knew it was wrong. Manager instruction is not a defence.
Three months later, Finance’s Q3 spot-check catches an anomaly in Sunridge’s invoice history. Four invoices with the same pattern. Total overcharge: £23,800. The Finance Director refers the matter to the Board. An external forensic accountant is appointed. Marcus is suspended. Alex is also suspended — because Alex’s name is on every amended invoice.
Harwick self-reports to the SFO. The investigation reveals the 2019 policy and 12-minute annual video do not meet the Home Office’s six-principle standard. Alex is interviewed under caution.
Three Weeks Later — 5 December 2024
FROM: Marcus Webb (m.webb@harwickgroup.co.uk)
TO: Alex Drummond (a.drummond@harwickgroup.co.uk)
SUBJ: Kestrel Haulage — same as last time
DATE: Thursday, 5 December 2024, 09:12
Alex,
Kestrel INV-2024-2103. Line 2 — change 180 pallets to 260.
Same arrangement as Sunridge. Standard reconciliation.
Marcus
It was not a one-off. It was never a one-off. Marcus has sent the same instruction again — different supplier, same pattern. You are now expected to falsify a second invoice. And you cannot claim you didn’t know what you were doing.
Why Following the Instruction Was Not a Defence
Fraud Act 2006 s.1 makes it a criminal offence to make a false representation knowing it is untrue, intending gain. Maximum sentence: 10 years’ imprisonment. The instruction came from Marcus. The false document was created by Alex. Both are exposed. Under ECCTA 2023 s.199, Harwick Group is also criminally liable. Harwick’s 2019 policy will not satisfy the Home Office six-principle test for reasonable prevention procedures.
Thursday, 14 November 2024, 09:31 AM
+0 Cautious
You Ask for Written Authorisation
Alex Drummond
Procurement Coordinator
Marcus — before I make the quantity change on the Sunridge invoice, can you send me the specific clause in the client contract that authorises a volume recovery adjustment? I want to attach it to the amendment record.
Marcus Webb
Procurement Manager
Alex, I’ve been doing this for 11 years. It’s standard. Just make the change.
Alex Drummond
Procurement Coordinator
I understand. I’d just feel more comfortable with the documentation. Can you forward the contract section?
Marcus Webb
Procurement Manager
I’ll find it. Hold the invoice for now.
Case File
Investigation Record
Marcus Webb did not send the contract clause. He called Alex at 11:34 AM and said the invoice would go out the following Monday “when the paperwork is sorted”. The documentation was never provided.
Asking for written authorisation was the right instinct — and it bought you time. Marcus could not produce the contract clause because no such clause exists.
However, by asking Marcus rather than escalating, you placed yourself in an uncomfortable position. Marcus knows you noticed something. The invoice has been delayed — but not stopped. Marcus finds a workaround and submits it himself the following Monday. The Q3 spot-check still catches the pattern. When investigators review the email chain, they find your request for documentation. You are interviewed as a witness, not a suspect. But the question asked will be: “When you suspected it was fraudulent, why did you not report it?”
Why This Was Partial — But Not Sufficient
Requesting written authorisation means you did not make a false representation — you are not personally criminally liable under Fraud Act 2006 s.1. However, one of the Home Office’s six principles for reasonable prevention procedures is communication and training: employees must understand not just what fraud is, but what they are required to do when they see it — including reporting it. Your email chain requesting documentation is a significant distinction. But it is not the same as reporting.
Thursday, 14 November 2024, 09:28 AM
+10 Fraud Aware
You Hold the Invoice and Report
Alex Drummond
Procurement Coordinator
Hi — I’m calling to report a concern about a supplier invoice. My manager has instructed me to change a delivery quantity before submission. The quantity is wrong. I haven’t submitted the invoice and I won’t until this is reviewed.
FL
Fraud Reporting Line — Intake Officer
Confidential Reporting
Thank you. I’m logging this now. Can you confirm your name and the invoice reference number? Your report is confidential. No action will be taken against you for making this report.
Alex Drummond
Procurement Coordinator
Alex Drummond. INV-2024-1847. I’m forwarding the email chain now.
Case File
Investigation Record
Report logged 09:28 AM, 14 November 2024. INV-2024-1847 withheld from submission. Email chain preserved. Finance Director notified same day. Forensic review commenced.
Harwick Group — Confidential Fraud Report — Intake Record
Report ID:FR-2024-0047
Date/Time:14 November 2024, 09:28 AM
Reporter:Alex Drummond, Procurement Coordinator
Subject:Marcus Webb — instruction to falsify supplier invoice
Invoice:INV-2024-1847 (Sunridge Logistics)
Amount:£6,650 discrepancy (240 vs 380 units)
Evidence:Email chain forwarded; invoice withheld
STATUS: RECEIVED — Finance Director notified — No action against reporter
You did the hardest thing. Not because it was dangerous — the reporting line is confidential and protected — but because it was uncomfortable. Marcus has been your manager for three years. Your performance review is in two weeks. You reported anyway.
The forensic review finds Marcus Webb has been adjusting Sunridge Logistics invoices since Q1 2023. Across seven invoices, Harwick Group overbilled Meridian Retail Ltd by £47,300. Marcus is suspended within 48 hours. Harwick self-reports to the SFO. Because Harwick self-reported promptly — triggered by your escalation — the SFO agrees to DPA terms rather than criminal prosecution. Harwick pays a financial penalty and funds an enhanced fraud prevention programme.
Why This Was the Defensible Choice
Under Fraud Act 2006 s.1, you would have committed fraud the moment you submitted the invoice knowing the quantity was wrong — regardless of who instructed you. Under ECCTA 2023 s.199, Harwick Group would have been criminally liable the moment an associated person committed fraud for its benefit. Your report triggered an internal investigation before that moment was reached. The Home Office’s six principles include communication and training: employees must understand what they are required to do when they see fraud. You acted on that obligation. The DPA framework (Crime and Courts Act 2013) rewards prompt self-disclosure — it does not reward waiting to be caught.
Thursday, 14 November 2024, 10:15 AM
Marcus Comes to Your Desk
Forty-five minutes after the email. The invoice deadline is 11:00 AM. Marcus walks over to your desk. He doesn’t sit down. His tone is calm, but he’s not smiling.
Marcus Webb
Procurement Manager
I noticed the Sunridge invoice hasn’t gone through yet. Look — I know it’s your first time seeing one of these adjustments. But this is how the Sunridge account works. Volume recovery is built into the relationship. I wouldn’t ask you to do anything I haven’t done dozens of times myself.
Case File
Investigation Record
Marcus Webb is standing at your desk. He has not produced written authorisation. He has not forwarded the contract clause. He has not CC’d anyone. He is now making the request in person rather than in writing. These are not the behaviours of someone requesting a routine invoice adjustment.
His tone is reassuring. His body language says this is completely normal. But he hasn’t shown you a contract clause. He hasn’t CC’d anyone. And he’s now at your desk rather than putting it in writing.
Thursday, 14 November 2024, 10:18 AM
Marcus Is Standing Over You
⚖
Investigation DecisionDecision 2 of 3
Invoice Due — Accounts Payable
10:18 AM — 42 min remaining
Marcus is waiting. The invoice is due in 42 minutes. He has been at Harwick for 11 years. Your performance review is in two weeks. He signed off your last two pay increases. He is standing at your desk, watching your screen.
Marcus is watching your screen...
What do you do?
Your choice
📄
Submit the invoice now
Marcus is standing over you. You make the change and submit. He’s your manager — he says this is normal.
Your choice
⏲
Tell Marcus you need until end of day
You ask for more time. You’re not refusing — but you’re not submitting either. You want space to think.
Your choice
🚨
Tell Marcus you’ve flagged it with Compliance
You tell Marcus directly that you’ve raised a concern with the compliance team. He will know. But you’ve reported.
Thursday, 14 November 2024, 10:47 AM
−15 Complicit
You Submit Under Pressure
Marcus Webb
Procurement Manager
See? Nothing to worry about. I’ll buy you a coffee later.
Case File
Investigation Record
INV-2024-1847 submitted at 10:47 AM. Marcus Webb left Alex Drummond’s desk 3 minutes later. CCTV timestamp confirms he was standing at the desk during submission. The invoice is now in the payment pipeline.
Manager pressure is the single most common rationalisation in fraud cases. “My boss told me to” is not a criminal defence under the Fraud Act. You are now personally exposed.
Pressure Is Not a Defence
Under Fraud Act 2006 s.1, the offence requires (a) a dishonest representation, (b) knowledge that it is false, and (c) intent to gain or cause loss. Manager instruction does not negate any of those elements. The ECCTA 2023 six principles require organisations to have proportionate procedures — including procedures that protect junior employees from being pressured by senior staff. Harwick’s failure to protect you is a corporate liability. Your submission of the invoice is a personal one.
Thursday, 14 November 2024, 10:22 AM
+0 Stalling
You Buy Yourself Time
Alex Drummond
Procurement Coordinator
Marcus, I’m in the middle of the Q3 reconciliation batch. Can I come back to this by end of day? I want to make sure the numbers are right.
Marcus Webb
Procurement Manager
End of day. Fine. But it needs to go out today, Alex. No later.
Case File
Investigation Record
Marcus Webb returned to his office at 10:23 AM. Alex Drummond did not submit the invoice. The question remains: what will Alex do with the remaining 6 hours?
Stalling is not the same as refusing. You have not submitted the invoice — but you also have not reported the concern. Marcus has walked away, but the deadline is still today. You have time. The question is whether you use it to escalate or to avoid.
Delay Without Action Is Still a Risk
The ECCTA 2023 reasonable procedures defence requires organisations to show that employees were equipped and empowered to act on suspicion of fraud. Stalling without reporting does not trigger that defence. Under Home Office Principle 5 (Monitoring & Review), a credible procedure requires active reporting channels — not passive avoidance. If the fraud is later discovered, a delayed or absent report will be scrutinised.
Thursday, 14 November 2024, 10:20 AM
+15 Escalated
You Tell Marcus You’ve Reported
Alex Drummond
Procurement Coordinator
Marcus — I’ve raised a concern about this invoice with the compliance team. I’m not comfortable making the change without a formal review.
Marcus Webb
Procurement Manager
You’ve flagged it? … Right. OK.
Case File
Investigation Record
Marcus Webb returned to his office at 10:21 AM without further comment. HR confirmed receipt of the compliance report at 10:33 AM. Marcus Webb was asked to attend a meeting at 2:00 PM. He did not submit the Sunridge invoice himself.
Marcus’s expression changed. The twelve-year veteran who called this “standard reconciliation” went quiet the moment he heard the word compliance. That silence tells you everything you need to know about whether this was really standard.
Escalation Activates the Reasonable Procedures Defence
By reporting to the compliance team before submitting the invoice, you triggered ECCTA 2023 s.199’s reasonable procedures framework. Home Office Principle 3 (Due Diligence) requires organisations to have working escalation channels — and your use of that channel is evidence it functions. Under the Employment Rights Act 1996 s.47B, reporting a suspected fraud internally is a protected disclosure. You cannot lawfully be subject to detriment for doing so.
Investigation Activity
The Evidence File
Before the final stage of the investigation, connect the dots. Each red flag below violates a specific ECCTA Home Office principle for reasonable fraud prevention. Match each failure to the principle it undermines.
Thursday, 14 November 2024, 4:30 PM
The Compliance Decision
⚖
Investigation DecisionDecision 3 of 3
You have reviewed the evidence. The delivery note says 240 units. Marcus wants 380 on the invoice. There is no contract clause authorising volume recovery. Marcus has been doing this since Q1 2023 — this is not the first time. The question is no longer whether this is fraud. The question is what you do about it.
What is your final action?
Your choice
📜
File a formal whistleblower report
You contact the SFO’s reporting line and file a formal disclosure under the Public Interest Disclosure Act 1998. Maximum accountability. Maximum legal protection for you.
Your choice
📧
Report internally to the Finance Director
You email the Finance Director with the email chain and your concerns. An internal investigation will follow — but you’re relying on Harwick to investigate its own procurement manager.
Your choice
⏳
Wait — the quarterly spot-check will catch it
You know what you’ve seen. But you decide to wait. The Q3 reconciliation will flag the discrepancy. Someone else will deal with it.
Monday, 18 November 2024
+20 Protected
Formal Disclosure Filed
You contact the SFO’s reporting line. Under the Public Interest Disclosure Act 1998, you are a protected whistleblower. Harwick cannot dismiss you, demote you, or subject you to any detriment for making this disclosure. Your report includes Marcus’s email, the original delivery note, and the invoice with the altered quantity.
The SFO opens a preliminary assessment within 14 days. Harwick’s legal team is notified. Marcus Webb is suspended on full pay pending investigation. The Sunridge invoice pattern is flagged for forensic review across the entire supplier ledger.
Why Formal Disclosure Is the Strongest Position
The Public Interest Disclosure Act 1998 (as amended) protects workers who report criminal offences, including fraud. A qualifying disclosure to the SFO is a “prescribed person” disclosure — it carries the highest statutory protection. Under ECCTA 2023 s.199, Harwick’s ability to demonstrate “reasonable prevention procedures” depends partly on having effective reporting channels. Your use of those channels is evidence that the system worked.
Thursday, 14 November 2024, 5:10 PM
+5 Internal
Internal Report Filed
You email the Finance Director with the email chain and your concerns. She replies within two hours: “Thank you for flagging this. I’ve forwarded to General Counsel. Do not submit the invoice. Do not discuss this with Marcus.”
An internal investigation is launched the following week. This is appropriate — but you’re relying on Harwick to investigate its own procurement manager. If the investigation is thorough, Marcus is caught. If it isn’t — if politics or reputation management interfere — the pattern may continue.
Internal Reporting: Necessary but Not Sufficient?
Internal reporting is a valid first step under the Home Office six principles. But it relies on the organisation acting on the report. The ECCTA 2023 defence requires “reasonable procedures” — if Harwick’s internal investigation is inadequate, the company cannot claim the defence. For the employee, internal reporting offers less statutory protection than a formal disclosure to a prescribed person (the SFO). The PIDA 1998 protects internal disclosures, but the evidentiary burden is lower for prescribed-person disclosures.
February 2025
−15 Complicit by Silence
You Wait. Three Months Pass.
You decide not to report. The Q3 spot-check will catch it. Someone else will deal with it.
Between November and February, Marcus submits three more adjusted invoices to different suppliers. Total fraudulent overbilling: £47,300. When the Q3 reconciliation finally flags the Sunridge anomaly in late January, forensic accountants are appointed. They reconstruct the timeline.
When they interview you in February, the first question is: “When did you first become aware of the discrepancy on INV-2024-1847?” You answer honestly: November. The second question: “Why did you not report it?”
Knowledge Without Action
You did not submit the fraudulent invoice yourself. But you had knowledge of a suspected fraud and chose not to report it. Under the Home Office six principles, “communication and training” requires employees to understand their obligation to report. Failure to report is not the same as committing fraud — but it undermines Harwick’s ability to claim it had reasonable prevention procedures. And for the three invoices Marcus submitted between November and February, the question of whether earlier reporting would have prevented £47,300 in losses will be asked by the SFO, the Board, and potentially a court.
Outcome
CASE COLD
0
Score — Investigation Rating
Suspended Pending Investigation
You are suspended. Your name is on four fraudulent invoices as the approving coordinator. Your solicitor has explained that “Marcus told me to” is not a criminal defence under Fraud Act 2006 s.1. Harwick Group is under SFO investigation. The company cannot demonstrate reasonable prevention procedures under ECCTA. Marcus Webb is also suspended. Meridian Retail Ltd is seeking recovery of £23,800. Your performance review has been postponed indefinitely.
Six Months Later — May 2025
The Aftermath
⚠
Criminal Proceedings
You are charged under Fraud Act 2006 s.1. Your solicitor advises you that “my manager told me to” is not a defence. The maximum sentence is 10 years.
💼
Career
Dismissed for gross misconduct. The fraud appears on your DBS check. Three recruitment agencies have declined to represent you. Your LinkedIn says “Open to Work.”
🏢
Harwick Group
Fined £180,000 under ECCTA s.199. Board-mandated compliance overhaul. The 12-minute video has been replaced with 16 hours of scenario training. Too late for you.
Outcome
CASE COMPROMISED
0
Score — Investigation Rating
Witness, Not Suspect
You did not commit fraud. That matters. But you also did not report a suspected fraud when you had the opportunity — and when investigators reconstruct the timeline, they will ask why. You are a witness in an SFO investigation, not a suspect. But you will spend the next six months fielding calls from forensic accountants. The email you sent Marcus — asking for documentation he could not provide — is exhibit 14.
Six Months Later — May 2025
The Aftermath
📝
Witness Interviews
You have attended four interviews with forensic accountants and two with SFO investigators. Your email requesting documentation is Exhibit 14. Each interview begins the same way: “When you suspected fraud, why did you not report it?”
💼
Career
Still employed. Performance review: “Satisfactory.” Your manager is now Rachel Thorn, Head of Finance. She has not mentioned the investigation. But every time you open an email from Procurement, your chest tightens.
🏢
Harwick Group
Fined £180,000. Compliance overhaul underway. Marcus Webb was dismissed in December. The invoice pattern was identified across seven suppliers. You knew about the first one. The investigators know you knew.
Outcome
CASE CLOSED
0
Score — Investigation Rating
Stopped Before It Started
You identified a fraud instruction and reported it before the invoice was submitted. Marcus Webb’s seven-quarter scheme was uncovered. Harwick self-reported to the SFO, agreed a Deferred Prosecution Agreement, and launched a substantive fraud prevention programme. Meridian Retail Ltd was made whole. Your performance review, when it finally happened, was conducted by the Finance Director. Marcus was gone.
Six Months Later — May 2025
The Aftermath
✅
Cleared
The SFO confirmed you are not under investigation. Your report was the trigger that stopped the scheme. The forensic accountants described your action as “exactly the response a reasonable prevention framework is designed to produce.”
💼
Career
Promoted to Senior Procurement Coordinator. Your performance review, conducted by the Finance Director, noted “exceptional judgement under pressure.” Marcus’s name is no longer on the organisation chart.
🏢
Harwick Group
Agreed a DPA with the SFO. Financial penalty: £180,000 — but no criminal prosecution, because the company self-reported promptly. Launched a substantive fraud prevention programme. The 12-minute video is gone. You helped design the replacement.
