Sample Fraud Policy
The corporate fraud policy is established to facilitate the development
of controls that will aid in the detection and prevention of fraud
against ABC Corporation. It is the intent of ABC Corporation to
promote consistent organizational behavior by providing guidelines
and assigning responsibility for the development of controls and
conduct of investigations.
SCOPE OF POLICY
This policy applies to any irregularity, or suspected irregularity,
involving employees as well as shareholders, consultants, vendors,
contractors, outside agencies doing business with employees of such
agencies, and/or any other parties with a business relationship with
ABC Corporation (also called the Company).
Any investigative activity required will be conducted without regard
to the suspected wrongdoer’s length of service, position/title, or
relationship to the Company.
Management is responsible for the detection and prevention of fraud,
misappropriations, and other irregularities. Fraud is defined as the
intentional, false representation or concealment of a material fact for
the purpose of inducing another to act upon it to his or her injury.
Each member of the management team will be familiar with the types
of improprieties that might occur within his or her area of respon-
sibility, and be alert for any indication of irregularity.
Any irregularity that is detected or suspected must be reported
immediately to the Director of _____________, who coordinates all
investigations with the Legal Department and other affected areas,
both internal and external.