POLICY: FRAUD PREVENTION. October 2017
|
|
- Jemimah Mildred Ramsey
- 5 years ago
- Views:
Transcription
1 POLICY: October 2017
2 CONTENTS 1. PURPOSE P3 2. SCOPE P3 3. LEGISLATION AND CORPORATE GOVERNANCE REQUIREMENTS REFERENCE 4. POLICY STATEMENT AND INTERNAL STANDARDS P3 P4 4.1 Background P4 4.2 Actions constituting fraud P4 5. RESPONSIBILITIES P5 5.1 Senior management P5 5.2 All employees P5 5.3 Lonmin business assurance services (LBAS) fraud and investigations/group Security P5 5.4 LBAS fraud and investigations/group Security 5.5 Social and ethics and transformation committee/audit and risk committee 6. REPORTING RESPONSIBILITIES P5 P6 P6 7. OWNERSHIP P6 8. ADMINISTRATION OF POLICY 9. APPLICABLE BUSINESS GOVERNANCE FORUMS REFERENCE P6 P7 10. NON-COMPLIANCE P7 11. PERIOD OF OPERATION P7 12. DEFINITIONS P7 Appendix A Decision matrix REVISION NUMBER DESCRIPTION DATE ROLE NAME AND SURNAME/COMMITTEE SIGNATURE DATE Originator Reviewed by Approved by Recommended by Approved by Devan Somiah Head of Assurance and Risk Barrie van der Merwe Chief Financial Officer Ben Magara Lonmin Exco Dr Len Konar Lonmin Audit and Risk Committee Brian Beamish Lonmin Board of Directors 8 August August September 2017 nn September 2017 nn September
3 POLICY: PURPOSE 1 The purpose of this Policy is to: Convey the expectations of the Board of Directors and Senior Management with regard to managing fraud risk Establish procedures and assign responsibility for the investigation of fraud and related offences Provide guidance to employees who find themselves having to deal with suspected cases of theft, fraud and corruption Develop awareness of risk and fraud in the organisation SCOPE 2 The policy applies to any fraud or suspected fraud, as defined in this policy, involving directors and employees as well as shareholders, consultants, vendors, contractors, outside agencies and/or any other parties with a business relationship with Lonmin. LEGISLATION AND CORPORATE GOVERNANCE REQUIREMENTS REFERENCE 3 The Fraud Prevention Policy needs to support the current legislative and regulatory framework. Regular reviews of Lonmin s legislative and regulatory framework should be undertaken to ensure that the Fraud Prevention Policy is aligned to this framework at all times. The following main pieces of legislation and guidelines are applicable to the policy: Prevention and Combating of Corrupt Activities Act 12 of 2004 Prevention of Organised Crime Act 121 of 1998 United Kingdom Bribery Act
4 POLICY: continued POLICY STATEMENT AND INTERNAL STANDARDS 4 All employees are responsible for the detection and prevention of fraud, misappropriation and other inappropriate conduct. Each member of the management team should be reasonably familiar with the types of improprieties that may occur within his or her area of responsibility and be alert to any indication of irregularity. Fraud or irregularities detected or suspected should be reported, without delay, to Deloitte Tip-offs Anonymous. 4.1 BACKGROUND Lonmin is committed to ethical behavior, and to the prevention, detection and reporting of fraud in terms of a zero-tolerance approach. All members of staff are expected to share this commitment. The Group will manage fraud risk by: Defining, setting and maintaining cost-effective control procedures to prevent, identify and deter fraud Ensuring implementation of and compliance with key controls Investigating all incidences of actual, attempted or suspected fraud, and all instances of major control breakdowns Encouraging staff to be vigilant and raising fraud awareness at all levels Providing staff with effective confidential reporting mechanisms and encouraging their use Taking action against individuals and organisations perpetrating fraud against the company, its shareholders or its customers Seeking restitution of any asset fraudulently obtained and the recovery of costs Co-operating with law enforcement and other appropriate authorities in the investigation and prosecution of those suspected of fraud. 4.2 ACTIONS CONSTITUTING FRAUD At Lonmin, fraud includes the crimes listed below (as defined under Definitions): Fraud in the broadest sense Forgery Bribery Corruption Insider trading Hacking For the purposes of this policy, the term fraud can be used interchangeably with the crimes reflected above. In this context, actions constituting fraudulent behaviour include, but are not limited to, the following: Any dishonest or fraudulent act Embezzlement or misappropriation Forgery or alteration of any document or account belonging to Lonmin Forgery or alteration of a cheque, bank transfer or any other financial document Theft or misappropriation of funds, securities, supplies or other assets Impropriety in the handling or reporting of money or financial transactions Transacting in securities or financial instruments using insider knowledge of Group or customer activities, irrespective of whether or not a profit or loss is made Unauthorised disclosure or manipulation of sensitive, confidential or proprietary information The offering or taking of inducements, gifts or favours as referred to in the Lonmin Code of Business Ethics, and Conflicts of Interest, Bribery and Anti-Corruption policies, which may influence the action of any persons Wilful destruction, removal or inappropriate use of records or Group assets Engage in any practices or pursue any private activities which conflict in any way with Lonmin s interests Hacking of and unauthorised access to Lonmin s computer systems Making a payment to or on behalf of any official (including government officials) for the purpose of obtaining or retaining business for or with any person or directing business to any person Any similar or related inappropriate conduct as outlined in the Lonmin Code of Business Ethics, and Conflicts of Interest, Bribery and Anti-Corruption policies, which place a fiduciary duty on all employees to disclose such activities, with disciplinary action as a consequence for failure to disclose such conduct Any queries about actions that could constitute fraud should be addressed to the Company Secretary or Head of Assurance and Risk or the Group Manager: Security and Risk. 4
5 POLICY: continued RESPONSIBILITY SENIOR MANAGEMENT Exco Members, General Managers, Heads of Functions, Senior Managers and Managers, at all levels, have a responsibility to: Promote the highest levels of ethical and lawful conduct in accordance with the Lonmin Code of Business Ethics and embrace good corporate governance by reporting any conduct which may be regarded as unethical, unlawful or in breach of good corporate governance, or which has the potential to tarnish the good name and reputation of Lonmin Set the tone at the top by preventing, detecting and deterring fraud through word and deed by management creating a culture that clearly does not tolerate fraud and deals with fraudulent behaviour swiftly and decisively Be familiar with the types of improprieties that might occur within his/her area of responsibility and remain alert to any indication of irregularity Ensure that an adequate system of internal controls exists within their areas of responsibility and that controls operate effectively Ensure that the Lonmin Code of Business Ethics, and Conflicts of Interest, Bribery and Anti-Corruption and Fraud Prevention policies are well communicated to all staff within their areas of responsibility In consultation with Legal and Human Resources, take appropriate legal and/or disciplinary action against perpetrators of fraud Take disciplinary action against employees where employee negligence has contributed to the commission of the fraud Ensure employees comply with this policy and annually declare acknowledgment of and the contents of this policy Confirm that all vendors dealing with Lonmin comply with this policy 5.2 ALL EMPLOYEES All employees have a responsibility to: Ensure that they are familiar with, and comply with, the Lonmin Code of Business Ethics, and Conflicts of Interest and Bribery and Anti-Corruption policies, which should be included in annual induction training for all employees and contractors Ensure they are familiar with, and comply with, controls and procedures in their areas of responsibility, and understand that their job procedures are designed to manage fraud risks and that non-compliance may create an opportunity for fraud to occur or go undetected Have a basic understanding of fraud and be aware of the red flags Recognise specific fraud risks within their own areas of responsibility and understand that they have a duty to ensure that these risks are identified and addressed, and discussed with their line managers and/or Head of Assurance and Risk or Group Security and Risk Manager when they believe that there is an opportunity for fraud because of poor procedures or oversight Report any suspected irregularities in accordance with the Lonmin Code of Business Ethics, and Conflicts of Interest and Fraud Prevention policies Co-operate in investigations Treat information relating to fraud investigations as confidential 5.3 LONMIN BUSINESS ASSURANCE SERVICES (LBAS) FRAUD AND INVESTIGATIONS/GROUP SECURITY LBAS Fraud and Investigations/Group Security is responsible for: Conducting investigations reported to Deloitte Tip-Offs Anonymous or directly to LBAS relating to commercial and white collar crime Identify internal controls once an investigation has been completed to address any weaknesses contributing to fraud and make recommendations for remedial action if necessary Reporting the results of fraud investigations, and actions that have been taken to manage fraud risks, to appropriate management and the Board through the Audit and Risk Committee, and provide an appropriate source of information to management regarding instances of fraud, corruption, unethical behaviour and irregularities Group Security is responsible for: Predominantly investigating syndicated crime, and performing surveillance, intelligence and covert operations relating to all PGM theft 5.4 LBAS FRAUD AND INVESTIGATIONS/GROUP SECURITY Fraud and Investigations and/or Group Security, depending on the merits of each case, are responsible for: Conducting investigations into any matter referred to them directly or reported to Deloitte Tip-Offs Anonymous or the Group Company Secretary 5
6 POLICY: continued RESPONSIBILITY continued 5 Co-ordination of investigations into all suspected fraudulent acts Reporting the results of the investigation to the appropriate person(s) Where applicable, outsourcing certain functions pertaining to investigations to approved service providers and managing such service providers 5.5 SOCIAL AND ETHICS AND TRANSFORMATION COMMITTEE/AUDIT AND RISK COMMITTEE The Social and Ethics and Transformation Committee and/or Audit and Risk Committee shall: Review the appropriateness and effectiveness of policies and procedures for preventing or detecting fraud Direct and supervise investigations into matters within the committee s scope, for example, evaluations of the effectiveness of the Group s internal control to deter/prevent fraudulent acts, cases of employee fraud or supplier fraud, forensic investigations, misconduct or conflict of interest Receive and review reports on the prevention, detection and investigation of fraudulent activity or misconduct within Lonmin Group companies Review significant cases of employee conflicts of interest, misconduct or fraud, or any other unethical activity by employees or the Group REPORTING 6 RESPONSIBILITIES Any employee who suspects dishonest or fraudulent activity should immediately report the matter through Deloitte Tip- Offs Anonymous or directly to the Head of Assurance and Risk and/or Group Security and Risk Manager and/or the Group Company Secretary. OWNERSHIP 7 The Board and Exco are responsible for adopting this policy and taking reasonable steps to ensure that all directors, senior management and employees are aware of the contents hereof. The Head of Assurance and Risk may report of any fraud that could affect the Group s financial statements to the Group s external auditor. In addition, the Group must report any fraud to the applicable regulatory bodies in terms of the relevant legislation including, but limited to, the Prevention and Combating of Corrupt Activities Act, the Prevention of Organised Crime Act and the UK Bribery Act. In terms of the Prevention and Combating of Corrupt Activities Act, fraud greater than R in value should be reported to [Lonmin, please verify this] Reporting to insurance should also be conducted, where appropriate. ADMINISTRATION OF POLICY 8 The Head of Assurance and Risk is responsible for the administration, revision, interpretation, and application of this policy, which will be reviewed and updated as changes in business or legislation are identified. 6
7 POLICY: continued APPLICABLE BUSINESS GOVERNANCE FORUMS REFERENCE 9 NON-COMPLIANCE 10 In the event of non-compliance, the individual shall be subject to Lonmin s disciplinary procedures. Lonmin Board of Directors Lonmin Audit and Risk Committee Lonmin Social, Ethics and Transformation Committee Lonmin Health, Safety and Environmental Committee Lonmin Remuneration and Nomination Committee Lonmin Executive Committee PERIOD OF OPERATION 11 This Policy will remain in force from the date of acceptance until amended and circulated as an updated policy. DEFINITION 12 Bribery Corruption Exco Lonmin/the Group Fraud Forgery Hacking Insider trading Policy Theft The offering, acceptance or receipt of anything of value intended to influence behaviour contrary to honesty/integrity The misuse of entrusted power or public office for private gain, covering a range of criminal offences including bribery and other crimes (such as fraud, extortion and money laundering) Lonmin Executive Committee Lonmin The intentional misrepresentation or concealment of a material fact for the purpose of inducing another to act upon it and cause actual or potential prejudice The unlawful and intentional creation of a false document to the actual or potential prejudice of another Intentionally accessing a computer without authorisation or exceeding authorised access in order to obtain or manipulate electronically stored information Using inside information relating to securities or financial instruments when dealing in such securities or financial instruments A set of principles applicable to a specific discipline or processes The unlawful appropriation of moveable corporeal property belonging to another with intent to deprive the owner permanently of the property 7
8 POLICY: continued APPENDIX A DECISION MATRIX R Responsible A Accountable I Inform C Consult Action required LBAS Fraud and Investigations Finance and Accounting Line Management Legal Counsel Corporate Affairs Executive Management Controls to prevent and detect fraud C R R A Recommendations to prevent fraud R I I I I Reporting of incidents to LBAS Fraud and Investigations R R A Investigation of fraud R C I Referrals to law enforcement officials C R C I Recovery of monies lost due to fraud C R C R Monitoring of recoveries I R I I Communications, publicity and press releases I I C R C Civil litigation I R C Fraud education and training R R C Fraud risk assessment C C R C I Deloitte Tip-Offs Anonymous R I I 8
POLICY: FRAUD INVESTIGATION. October 2017
POLICY: October 2017 CONTENTS 1. PURPOSE P3 2. SCOPE P3 3. POLICY STATEMENT AND INTERNAL STANDARDS P3 3.1 Possible outcomes P3 3.1.1 Suspension P3 3.1.2 Disciplinary action P3 3.1.3 Criminal action P3
More informationAnti-fraud and Corruption Policy
Anti-fraud and Corruption Policy Responsible Division: Finances Validated by: Board (Executive Committee) Date of approval: 17/05/2017 Date of next review: May 2019 Language versions available: English
More informationHUMAN CAPITAL FRAUD AND CORRUPTION PREVENTION
1. Policy Statement Grindrod Limited ( Grindrod ) is committed to its responsibility of protecting its revenue, expenditure, assets and reputation from any attempt by any person to gain financial or other
More informationANTI-FRAUD POLICY AND RESPONSE PLAN FOR BARLOWORLD LIMITED
ANTI-FRAUD POLICY AND RESPONSE PLAN FOR BARLOWORLD LIMITED Table of Contents GLOSSARY OF TERMS... 3 1. BACKGROUND... 3 2. ETHICS... 4 3. SCOPE OF THE POLICY... 4 4. THE POLICY... 4 5. REPORTING PROCEDURES
More informationTEXAS WORKFORCE COMMISSION LETTER. ID/No: Regulatory Integrity Date: August 17, 2009
TEXAS WORKFORCE COMMISSION LETTER ID/No: Regulatory Integrity 04-09 Date: August 17, 2009 TO: FROM: Executive Director Deputy Executive Director Commission Executive Staff Department Heads LWDB Executive
More informationEastern Band of Cherokee Indians Fraud Policy
Article I. BACKGROUND According to Management Antifraud Programs and Controls, released in 2002 as an exhibit to Statement on Auditing Standards No. 99 Consideration of Fraud in a Financial Statement Audit,
More informationApproval version. G l o b a l P o l i c y : F r a u d R e s p o n s e a n d W h i s t l e b l o w i n g P o l i c y. Board of Directors.
Approval version G l o b a l P o l i c y : Issuer Author Approved by Board of Directors Group Legal Department Board of Directors Issue date July 01 2013 Revision history Publication via n/a BCnet Limitations
More informationSOMERVILLE HOUSING AUTHORITY ANTI- FRAUD POLICY. April 3, 2013
SOMERVILLE HOUSING AUTHORITY ANTI- FRAUD POLICY April 3, 2013 Introduction The Board of Commissioners of the Somerville Housing Authority has established an anti-fraud policy to enforce controls and to
More informationANTI FRAUD, BRIBERY AND CORRUPTION POLICY
ANTI FRAUD, BRIBERY AND CORRUPTION POLICY St Alban Catholic Academies Trust Anti-Fraud, Bribery and Corruption Policy 1. Introduction The Scheme of Delegation and/or the Financial Regulations Handbook
More informationFraud Prevention Policy
Annexure-1 Fraud Prevention Policy Background ONGC is a Maharatna Public Sector undertaking engaged in exploration and production of Oil & Gas. One of the Mission of ONGC is for Imbibing high standards
More informationPOLICY: WHISTLEBLOWING. October 2017
POLICY: October 2017 CONTENTS 1. PURPOSE P3 2. RESPONSIBILITY P3 3. SCOPE P3 4. OVERVIEW P3 5. WHAT IS P4 5.1 Scope exclusion P4 5.2 Why is whistleblowing important? P4 5.3 Who can raise a concern? P4
More informationHeerema Marine Contractors
Heerema Marine Contractors ANTI-FRAUD POLICY Date of issue September 2012 Version 2012.02 Document HMC L055 Summary HMC requires its staff at all times to act honestly and with integrity in order to safeguard
More informationSample Fraud Policy. Statements
Sample Fraud Policy Statements Disclaimer Whilst every effort has been made in the construction of these sample fraud policy statements, compliance with them does not guarantee that you and/or your business
More informationAnti-Fraud Policy. Version: 8.0 Approval Status: Approved. Document Owner: Graham Feek. Review Date: 07/12/2018
Anti-Fraud Policy Version: 8.0 Approval Status: Approved Document Owner: Graham Feek Classification: External Review Date: 07/12/2018 Last Reviewed: 09/12/2016 Table of Contents 1. Policy Statement...
More informationAnti-Fraud and Corruption Policy
Anti-Fraud and Corruption Policy Document Detail Policy Reference Number: 002 Category: Risk Management Authorised By: Board of Directors Author: Trust Business Manager Version: 2016-2 Status: Final April
More informationWhistle-Blowing Policy
2017 Ithmaar Bank Human Resources Department Table of Contents Table of Contents 2 1.0- Statement of Purpose: 3 2.0- Responsibilities 3.0- Actions Constituting Fraud 3.1- Criminal / Unethical Conduct 3.2-
More informationWhistle-Blowing Policy
2011 Ithmaar Bank Risk Management & Compliance Division 21-Oct-11 Table of Contents Table of Contents 2 1.0- Statement of Purpose: 3 2.0- Responsibilities 4 3.0- Actions Constituting Fraud 4 3.1- Criminal
More informationFraud Control Framework
London Pension Fund Authority Fraud Control Framework Dec 2017 Page 1 of 14 Introduction: From April 2016 the LPFA partnered with Lancashire County Pension Fund (LCPF) in order to establish Local Pensions
More informationAnti - Fraud and Corruption Policy
Anti - Fraud and Corruption Policy This policy applies Trust Wide Document control page Policy number Name of policy Names of linked procedures Accountable Director Author with contact details Status (draft/
More informationFRASER & NEAVE HOLDINGS BHD
FRASER & NEAVE HOLDINGS BHD (Company No. 004205-V) FRAUD CONTROL POLICY Table of Contents 1. Document Information and History... 2 2. Purpose / Overview... 3 3. Scope... 3 4. Definitions... 3 5. Roles
More informationANTI-FRAUD AND CORRUPTION POLICY
ANTI-FRAUD AND CORRUPTION POLICY AIM/PURPOSE 1.1 Trinity Church of England High School (Academy) is committed to ensuring that it acts with integrity and has high standards. Everyone involved with the
More informationLast Updated: 1 February 2018 To be reviewed: Annually
CARE International Policy on Fraud and Corruption Awareness, Prevention, Reporting and Response Sponsor: Secretary General/CEO Policy Owner: Deputy Secretary General, CARE International Effective Date:
More informationANTI-FRAUD, BRIBERY AND CORRUPTION POLICY AND STRATEGY THE VIEW TRUST
ANTI-FRAUD, BRIBERY AND CORRUPTION POLICY AND STRATEGY THE VIEW TRUST INTRODUCTION 1. Introduction 2. What are Fraud, Bribery and Corruption? 3. Purpose of this Document 4. Scope of this Document 5. Anti-Fraud,
More informationRevenue Scotland Counter-Fraud Policy
Revenue Scotland Counter-Fraud Policy 0 Table of Contents Contents 1. Introduction and Scope... 2 2. Related Policies and Procedures... 2 3. Overview of Policy... 3 4. Responsibilities... 3 5. Exceptions...
More informationANTI BRIBERY FRAUD AND CORRUPTION. RES-CG-003-V02 Anti Bribary, Fraud and Corruption If printed this document is uncontrolled
ANTI BRIBERY FRAUD AND CORRUPTION RES-CG-003-V02 Anti Bribary, Fraud and Corruption If printed this document is uncontrolled 1. Scope This policy applies to all employees of the company and to temporary
More informationFraud, Bribery and Corruption Control Policy
Fraud, Bribery and Corruption Control Policy 1. Introduction DuluxGroup acknowledges the need for directors, executives, employees and contractors to observe the highest ethical standards of corporate
More informationANTI-FRAUD POLICY. Reference No: ANTIFP-251. Policy Type: Governance. Directorate Area: All Directorates. Policy Author / Champion: Maurice Atkinson
ANTI-FRAUD POLICY Reference No: ANTIFP-251 Policy Type: Directorate Area: Policy Author / Champion: Governance All Directorates Maurice Atkinson Date(s) Equality Screened: 21 July 2017 Date(s) Approved
More informationPolicy 42 Anti-Fraud, Anti-Theft & Anti-Corruption
Policy 42 Anti-Fraud, Anti-Theft & Anti-Corruption Table of Contents Introduction...1 Our written rules...2 Expected Behaviour...2 Preventing fraud, theft and corruption...3 Detecting and investigating
More informationFRAUD PREVENTION POLICY
Page 1 of 13 FRAUD PREVENTION POLICY POLICY NO: 0094 Page 2 of 13 TABLE OF CONTENT Page 3 of 13 AMENDMENT AND APPROVAL RECORD TITLE: FRAUD PREVENTION POLICY Policy Number 0094 Effective Date From date
More informationAPPENDIX 2 CORPORATE ANTI-FRAUD AND CORRUPTION STRATEGY
APPENDIX 2 CORPORATE ANTI-FRAUD AND CORRUPTION STRATEGY January 2017 CONTENTS Section Page 1 Introduction 3 2 Definition of Fraud 3 3 Standards 4 4 Corporate Framework and Culture 4 5 Roles and Responsibilities
More informationAnti-Fraud Policy Date: Version: Review Date:
Anti-Fraud Policy Date: July 2017 Version: 4.0 Review Date: July 2019 Policy Title Anti-Fraud Policy Policy Number: POL 022 Version 4.0 Policy Sponsor Policy Owner Committee Chief Executive Director of
More informationPolicies and Procedures. Code of Ethics Policy
Policies and Procedures Code of Ethics Policy Approved by: Group CEO Department: Group Company Secretariat Table of Contents 1. Introduction... 3 2. Purpose... 3 3. Scope... 3 4. Policy Standards... 3
More informationThe Co-operative Academies Trust Anti-Fraud and Anti-Bribery Policy. Approved by the Trust Board on 21 April 2016 Implementation from 22 April 2016
The Co-operative Academies Trust Anti-Fraud and Anti-Bribery Policy Approved by the Trust Board on 21 April 2016 Implementation from 22 April 2016 April 2016 1 Anti-Fraud and Anti-Bribery Policy Contents
More informationFRAUD POLICY. Fraud is a serious matter and the Trust is committed to investigating all cases of suspected fraud.
FRAUD POLICY To ensure all staff, Directors and Academy Council Governors are aware of their responsibilities for the proper use of Trust assets and finances. Fraud is a serious matter and the Trust is
More informationWHL ANTI-BRIBERY, CORRUPTION AND SANCTIONS POLICY
WHL ANTI-BRIBERY, CORRUPTION AND SANCTIONS POLICY 1. POLICY OVERVIEW Woolworths Holdings Limited ( WHL ) and its subsidiaries ( the Group ) is committed to conducting its business in accordance with all
More informationTHE CORPORATION OF THE CITY OF WINDSOR POLICY
THE CORPORATION OF THE CITY OF WINDSOR POLICY Service Area: Office of the CAO Policy No.: Department: Chief Administrative Office Approval Date: April 20, 2015 Division: Approved By: M140-2015 Effective
More informationThe Australian National University Fraud Control Framework. Corporate Governance & Risk Office
The Australian National University Fraud Control Framework 2017 2018 Corporate Governance & Risk Office Corporate Governance and Risk Office 21 July 2017 The Australian National University Canberra ACT
More informationGLOBAL CODE OF CONDUCT AND ETHICS
Author: Legal Department Updated by: Global Compliance Release Date: 10 September 2014 Last Reviewed: 10 September 2014 Status: Approved Owner: Legal Department Version: 2.0 Custodian: Global Compliance
More informationCODE OF BUSINESS CONDUCT AND ETHICS
CODE OF BUSINESS CONDUCT AND ETHICS The Board of Directors (the Board ) of Robert Half International Inc. (the Company ) has adopted the following Code of Business Conduct and Ethics (the Code ) for itself
More informationCode of Conduct. This Code of Conduct covers all associates. When appropriate, it also covers all members of the Company's Board of Directors.
Code of Conduct This Code of Conduct has been adopted for the purpose of ensuring that the Company's "Associates" (Officers and Employees) conduct themselves and operate the Company's business in accordance
More informationCARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY PILLARS I AND II INTEGRITY AND ETHICS POLICY
CARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY PILLARS I AND II INTEGRITY AND ETHICS POLICY To provide for measures to promote Institutional Integrity and Ethics
More informationRevised: May Fraud Prevention Policy
Revised: May 2011 Fraud Prevention Policy Contents Page 1. Introduction 2 2. Basis of the Policy 3 3. Purpose and Definitions 3 4. Management and Staff Responsibilities 4 5. Adherence to University Regulations,
More informationFRAUD & THEFT POLICY & RESPONSE PLAN
FRAUD & THEFT POLICY & RESPONSE PLAN POLICY OWNER: Chief Finance Officer AUTHOR: Louise Jones DATE OF REVIEW: July 2015 DATE OF APPROVAL: July 2015 FOR APPROVAL BY: Corporation NEXT REVIEW DATE: July 2017
More informationWhistleblowing Policy
Whistleblowing Policy COPYRIGHT EXPO DUBAI 2020 ALL RIGHTS RESERVED UNCONTROLLED IF PRINTED All texts, photographs, publications, designs, graphics, images, and all other elements contained herein and
More informationPOLICY. Tiger Brands Anti-Bribery and Anti-Corruption Policy
and Anti- TABLE OF CONTENTS DOCUMENT CONTROL INFORMATION... 3 1 INTRODUCTION... 5 2 SCOPE... 5 3 OBJECTIVE... 5 4 POLICY DETAILS... 6 5 ROLES AND RESPONSIBILITIES... 10 6 COMPLIANCE... ERROR! BOOKMARK
More informationCategory: BOARD POLICY ADMINISTRATIVE PARAMETERS
Category: BOARD POLICY ADMINISTRATIVE PARAMETERS Title: Theft, Fraud, Corruption, and Non-Compliant Activities Policy Reference Number: AB 630 1. POLICY OBJECTIVES Last Approved: February 22, 2017 Last
More informationFRAUD EXAMINERS MANUAL (INTERNATIONAL EDITION)
TABLE OF CONTENTS SECTION 1 FINANCIAL TRANSACTIONS AND FRAUD SCHEMES OCCUPATIONAL FRAUDS ACCOUNTING CONCEPTS Accounting Basics... 1.101 Financial Statements... 1.105 FINANCIAL STATEMENT FRAUD What Is Financial
More informationPolicy on Fraud Prevention and Detection
Status: Approved Custodian: Director: Finance and Administration Date approved: 2011-09-21 Decision number: SAQA 0893/11 Implementation date: 2011-09-21 Due for review: 2014-09-20 File Number: 1 Table
More informationINTERSERVE PLC POLICY ON FRAUD
INTERSERVE PLC POLICY ON FRAUD Interserve Plc ( The Company ) is committed to the highest standards of personal and corporate behaviour. We will not tolerate any incidence of fraud committed by workers
More informationTown of Cohasset FRAUD RISK POLICY Adopted by Board of Selectmen:
Town of Cohasset FRAUD RISK POLICY Adopted by Board of Selectmen: The Town of Cohasset is committed to protecting its revenue, property, information, and other assets from any attempt, either by members
More informationANTI-BRIBERY POLICY AND ANTI-FRAUD POLICY AND RESPONSE PLAN
University for the Creative Arts Financial Regulations: Appendix K ANTI-BRIBERY POLICY AND ANTI-FRAUD POLICY AND RESPONSE PLAN INDEX 1. Introduction 2. Definitions 3. Culture 4. Responsibilities and Reporting
More informationWHISTLE BLOWING PROCEDURES. Version 1
WHISTLE BLOWING PROCEDURES Version 1 Page 1 of 13 TABLE OF CONTENTS 1. Introduction 4 2. Purpose and ownership of the document 4 3. Procedure for amending the document 4 4. Compliance with laws, regulations
More informationANTI-BRIBERY & CORRUPTION POLICY
1 INTRODUCTION 1.1 The Board of Directors of Ascendant Resources Inc. 1 has determined that, on the recommendation of the Corporate Governance Committee, Ascendant should formalise its policy on compliance
More informationCARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY PILLARS I, II AND III WHISTLEBLOWER POLICY
CARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY PILLARS I, II AND III WHISTLEBLOWER POLICY To provide for a Whistleblower System and the protection of Whistleblowers
More informationFRAUD EXAMINERS MANUAL INTERNATIONAL EDITION
TABLE OF CONTENTS VOLUME I SECTION 1 FINANCIAL TRANSACTIONS AND FRAUD SCHEMES ACCOUNTING CONCEPTS Accounting Basics... 1.101 Financial Statements... 1.105 Generally Accepted Accounting Principles (GAAP)...
More informationFraud and corruption prevention and control policy of the International Federation of Red Cross and Red Crescent Societies
www.ifrc.org Saving lives, changing minds. Fraud and corruption prevention and control policy of the International Federation of Red Cross and Red Crescent Societies Document Issued On: [insert date] Approved
More informationCODE OF BUSINESS CONDUCT
CODE OF BUSINESS CONDUCT CONTENTS Introduction from Doug Duguid 2 What is the Code of Business Conduct? 3 Who Does the Code Apply to? 4 Business Partners, Agents and Business Representatives 5 What is
More informationFraud prevention Plan
Fraud prevention Plan Compiled by: Approved By: M Ndlovu M Moeletsi Date of approval 24 July 2009 Date of implementation 27 July 2009 Page 1 of 17 TABLE OF CONTENTS Page 1. Introduction 3 1.1 Purpose 3
More informationAnti-bribery policy. Lynas Corporation Limited ACN
Lynas Corporation Limited ACN 009 066 648 Contents Lynas Corporation Limited... 1 1. Introduction... 1 2. Application... 1 3. Objectives... 2 4. Bribes... 2 5. Political Contributions and Charitable Contributions/
More informationFinancial Policies and Procedures Preventing Bribery, Corruption and Money Laundering (August 2018)
Institute of Development Studies Financial Policies and Procedures Preventing Bribery, Corruption and Money Laundering (August 2018) Contents Page 1. Introduction 1 2. Principles 4 3. Bribery prevention
More informationAnti-Bribery and Corruption Policy. Viva Energy Group Limited (ACN )
Anti-Bribery and Corruption Policy Viva Energy Group Limited (ACN 626 661 032) Adopted by the Board on 18 June 2018 1 Introduction and purpose 1.1 Viva Energy Group Limited (together with its subsidiaries
More informationFRAUD EXAMINERS MANUAL
TABLE OF CONTENTS VOLUME I SECTION 1 FINANCIAL TRANSACTIONS AND FRAUD SCHEMES ACCOUNTING CONCEPTS Accounting Basics... 1.101 Financial Statements... 1.105 Generally Accepted Accounting Principles (GAAP)...
More informationAmpco-Pittsburgh Corporation
Ampco-Pittsburgh Corporation CODE OF BUSINESS CONDUCT AND ETHICS For Directors, Officers, Employees and Business Partners of Ampco-Pittsburgh Corporation and its subsidiaries Adopted on December 14, 2004
More informationWHISTLE BLOWING POLICY. Version 1
WHISTLE BLOWING POLICY Version 1 Page 1 of 8 TABLE OF CONTENTS 1. Introduction Scope of the Policy 4 2. Purpose and Ownership of the document 4 3. Procedure for amending the document 4 4. Compliance with
More informationEldorado Resorts, Inc. Code of Ethics and Business Conduct. The Code includes standards that are designed to deter wrongdoing and to promote:
Eldorado Resorts, Inc. Code of Ethics and Business Conduct This Code of Ethics and Business Conduct, which includes our Conflicts of Interest Policy attached as Exhibit A hereto (collectively, the Code
More informationANTI - FRAUD, BRIBERY & CORRUPTION POLICY (INCLUDING MONEY LAUNDERING POLICY AND PROCEDURE) REPORT OF CORPORATE DIRECTOR RESOURCES AGENDA ITEM: 6
CITY OF CARDIFF COUNCIL CYNGOR DINAS CAERDYDD CABINET MEETING: 11 JUNE 2015 ANTI - FRAUD, BRIBERY & CORRUPTION POLICY (INCLUDING MONEY LAUNDERING POLICY AND PROCEDURE) REPORT OF CORPORATE DIRECTOR RESOURCES
More informationInternational Standard on Auditing (UK) 250 (Revised)
Standard Audit and Assurance Financial Reporting Council December 2017 International Standard on Auditing (UK) 250 (Revised) Section A Consideration of Laws and Regulations in an Audit of Financial Statements
More informationFRAUD POLICY. Mr Paul Nicholson, Assistant Director of Finance
Policy Code: TW/2/Fin (v5) 2016 Title: Author(s): Ownership: FRAUD POLICY Fraud Policy Mr Paul Nicholson, Assistant Director of Finance Finance and IT Directorate Date of SEMT Approval: April 2016 Date
More informationNovember 2017 ICPAK FORENSIC AUDIT SEMINAR
November 2017 ICPAK FORENSIC AUDIT SEMINAR Introduction What is Fraud? 2 1 Insert Banner Profile of a Fraudster Introduction to Fraud A false representation of a matter of fact, whether by words or by
More informationSTURM, RUGER & COMPANY, INC. CODE OF BUSINESS CONDUCT AND ETHICS
STURM, RUGER & COMPANY, INC. CODE OF BUSINESS CONDUCT AND ETHICS Sturm, Ruger & Company, Inc. (the "Company") maintains an extensive "Corporate Compliance Program" which governs the obligation of all employees,
More informationGUIDANCE NOTE ON DETERING, PREVENTING, DETECTING, REPORTING AND REMEDYING INSURANCE FRAUD
GUERNSEY FINANCIAL SERVICES COMMISSION GUIDANCE NOTE ON DETERING, PREVENTING, DETECTING, REPORTING AND REMEDYING INSURANCE FRAUD Introduction Fraud is a serious risk to the insurance sector and can have
More informationCounter Fraud Framework Manual Anti-Money Laundering Policy Statement and Procedure
Counter Fraud Framework Manual 2014 Anti-Money Laundering Policy Statement and Procedure Document Control Document Counter Fraud Framework Manual Anti Money Laundering Policy Statement Description and
More informationFITBIT CODE OF CONDUCT AND ETHICS. As adopted on February 17, 2015 and. amended on October 26, 2016 and. July 20, 2017
FITBIT CODE OF CONDUCT AND ETHICS As adopted on February 17, 2015 and amended on October 26, 2016 and July 20, 2017 1. Introduction Employees of Fitbit, Inc. or any of its affiliates, related entities
More informationNN Group. Whistleblower. Policy. Version 2.3 Date September 2015 Department. Corporate Compliance
Whistleblower Policy Version 2.3 Date September 2015 Department Corporate Compliance Policy Summary Sheet Purpose of the policy document and key requirements NN Group's reputation and organisational integrity
More informationSTAR GAS PARTNERS, L.P.
STAR GAS PARTNERS, L.P. SUBJECT: CODE OF BUSINESS CONDUCT AND To Whom the Code Applies This Code applies to all employees of Star Gas Partners, L.P. and its direct and indirect subsidiaries (collectively
More informationCounter Theft, Fraud and Corruption Policy
South East Cornwall Multi Academy Regional Trust Dobwalls Primary School, Landulph Primary School, Liskeard School and Community College, Looe Community Academy, saltash.net Community School, and Trewidland
More informationThornhill Associates Anti-Bribery Policy
Thornhill Associates Anti-Bribery Policy Date: 01 June 2015 Approved by the Board of Directors Introduction Thornhill Associates is committed to conducting its business responsibly and in accordance with
More informationAU4000 THEFT, FRAUD AND CORRUPTION January 2014
AU4000 THEFT, FRAUD AND CORRUPTION January 2014 1.0 PURPOSE Interior Health (IH) is committed to fostering integrity in our workplace and is committed to minimizing risk of all forms of theft, fraud, corruption
More informationWhistleblowers Policy
Whistleblowers Policy Adacel Technologies Limited ACN 079 672 281 (the Company) Adopted by the Board on 21 July 2017 Whistleblowers Policy Adacel Technologies Limited (the Company) 1. Introduction and
More informationThis Policy supports our culture through procedures for the receipt, review and retention of Complaints from Representatives or others.
Approved by: Board of Directors Date: effective as of January 1, 2011 Revised: July 29, 2015 INTRODUCTION At Obsidian Energy our policies, procedures, and financial controls are the foundation for excellence.
More informationCounter Fraud, Bribery and Corruption Policy
Counter Fraud, Bribery and Corruption Policy Version: 4 Consultation: Ratified by: Date ratified: Name of originator/author: Audit Committee Andrew Lee Lee Sheridan Date issued: June 2016 Review date:
More informationEmployee Code of Conduct Handbook
Employee Code of Conduct Handbook Table of Contents 1.0 INTRODUCTION.............................................................................1 2.0 POLICY ON ETHICS..........................................................................
More informationGLOBAL ANTI-CORRUPTION POLICY
GLOBAL ANTI-CORRUPTION POLICY Contents Foreword by the Chief Executive Officer 2 Glencore s objective a Compliance Culture 3 1. Introduction 4 2. What is bribery? 5 3. Applying the law on bribery in practice
More informationWhistleblowing Policy & Procedures. GFH Financial Group
Whistleblowing Policy & Procedures GFH Financial Group Table of Contents 1. Definitions 4 2. Introduction 4 3. Objective of the Policy 4 4. Ownership and Approval of the Policy 4 5. Scope 4 6. What is
More informationAn overview of the fraud threat to business, including the particular threat posed by electronic funds transfer fraud
An overview of the fraud threat to business, including the particular threat posed by electronic funds transfer fraud Every business is susceptible to fraud But some are more susceptible than others. That
More informationWHISTLEBLOWER PROTECTION POLICY
WHISTLEBLOWER PROTECTION POLICY NOVEMBER 2016 Policy Whistleblower Protection Policy Approval Date 22 November 2016 Approved By R. Armstrong Owner Group Security, Fraud and Crisis Manager Version 0.1 Amendments
More informationAnti Fraud Policy. 1. Introduction
Anti Fraud Policy 1. Introduction Fraud is a broad legal concept. Unlike error, fraud is intentional and usually involves deliberate concealment of the facts. It may involve directors, management, employees
More informationPolicies, Procedures, Guidelines and Protocols
Policies, Procedures, Guidelines and Protocols Document Details Title Anti-Fraud, Bribery and Corruption Trust Ref No 1963-39667 Local Ref (optional) Main points the The Policy lays down procedures which
More informationANTI- FRAUD & WHISTLE-BLOWING POLICY November 2017
ANTI- FRAUD & WHISTLE-BLOWING POLICY November 2017 1. Introduction Concern is committed to the highest possible standards of openness, transparency and accountability in all its affairs. We wish to promote
More informationANTI-FRAUD, BRIBERY AND CORRUPTION POLICY
ANTI-FRAUD, BRIBERY AND CORRUPTION POLICY Version: 6 Date issued: February 2018 Review date: February 2021 Applies to: All Trust staff, contractors and vendors This document is available in other formats,
More informationRoku, Inc. Code of Conduct and Business Ethics
Roku, Inc. Code of Conduct and Business Ethics Introduction Integrity is fundamental to Roku, Inc. ( Roku or the Company ). We are committed to maintaining the highest standards of business conduct and
More informationANNUAL CORRUPTION CASE REPORT 2016
External Document ANNUAL CORRUPTION CASE REPORT 2016 Integrity, Compliance & Legal Dept. This report has been prepared to the best knowledge and judgment of the Integrity, Compliance & Legal department
More informationCode of Business Conduct and Ethics For Directors, Officers and Employees
This document contains both information and navigation buttons. To read information, use the Down Arrow from a form field. April 2016 Code of Business Conduct and Ethics For Directors, Officers and Employees
More informationWHISTLEBLOWERS POLICY REGISTRY DIRECT LIMITED ("Company")
WHISTLEBLOWERS POLICY REGISTRY DIRECT LIMITED ("Company") Version: 1 Board Endorsement: 9 August 2017 Last Review Date: 26 July 2017 Next Review Date: 26 July 2018 1 Introduction and purpose The Company
More informationFraud Risk Assessment CARRIE KENNEDY, PARTNER DUSTIN BIRASHK, PARTNER
Fraud Risk Assessment CARRIE KENNEDY, PARTNER DUSTIN BIRASHK, PARTNER Disclaimer The material appearing in this presentation is for informational purposes only and should not be construed as advice of
More informationAnti-Bribery, Anti- Corruption Policy
Anti-Bribery, Anti- Corruption Policy Reviewed by: B Carroll (Global Head of Compliance, Safety and Quality) Date: 21 Sep 2017 Approved by: A McLean (CEO) Date: 27 Sep 2017 Commercial-in-Confidence. All
More informationARCHDIOCESE OF ST. LOUIS Cardinal Rigali Center 20 Archbishop May Drive St. Louis, Missouri Memorandum
ARCHDIOCESE OF ST. LOUIS Cardinal Rigali Center 20 Archbishop May Drive St. Louis, Missouri 63119-5738 Deacon C. Frank Chauvin Chief Financial Officer 314-792-7280 chauvin@archstl.org Memorandum TO: FROM:
More informationANTI-FRAUD CODE CONTENTS INTRODUCTION GOAL CORPORATE REFERENCE FRAMEWORK CONCEPTUAL FRAMEWORK ACTION FRAMEWORK GOVERNANCE STRUCTURE
ANTI-FRAUD CODE CONTENTS INTRODUCTION GOAL CORPORATE REFERENCE FRAMEWORK CONCEPTUAL FRAMEWORK ACTION FRAMEWORK GOVERNANCE STRUCTURE PREVENTION, DETECTION, INVESTIGATION AND RESPONSE MECHANISMS APPLICATION
More informationApril 2015 FC 158/12 E. Hundred and Fifty-eighth Session. Rome, May Anti-Fraud and Anti-Corruption Policy
April 2015 FC 158/12 E FINANCE COMMITTEE Hundred and Fifty-eighth Session Rome, 11-13 May 2015 Anti-Fraud and Anti-Corruption Policy Queries on the substantive content of this document may be addressed
More informationFraud Prevention Strategy
Inclusive of Policy, control strategies and procedures for investigations Approved by: Accounting Authority Signed on behalf by (name and position): Signed: Date: Contents 1 Introduction 1 1.1 Purpose
More information