Sample Fraud Policy For Corporation (Page 2 of 4) in pdf

Sample Fraud Policy For Corporation Page 2

ACTIONS

The terms defalcation, misappropriation, and other fiscal irregularities

CONSTITUTING

refer to, but are not limited to:

FRAUD

• Any dishonest or fraudulent act

• Misappropriation of funds, securities, supplies, or other assets

• Impropriety in the handling or reporting of money or financial

transactions

• Profiteering as a result of insider knowledge of company activities

• Disclosing confidential and proprietary information to outside

parties

• Disclosing to other persons securities activities engaged in or

contemplated by the company

• Accepting or seeking anything of material value from contractors,

vendors, or persons providing services/materials to the Company.

Exception: Gifts less than $50 in value.

• Destruction, removal, or inappropriate use of records, furniture,

fixtures, and equipment; and/or

• Any similar or related irregularity

OTHER

Irregularities concerning an employee’s moral, ethical, or behavioral

IRREGULARITIES

conduct should be resolved by departmental management and the

Employee Relations Unit of Human Resources rather than the

_________________ Unit.

If there is any question as to whether an action constitutes fraud, con-

tact the Director of ______________ for guidance.

INVESTIGATION

The ____________ Unit has the primary responsibility for the

RESPONSIBILITIES

investigation of all suspected fraudulent acts as defined in the policy.

If the investigation substantiates that fraudulent activities have oc-

curred, the ______________ Unit will issue reports to appropriate

designated personnel and, if appropriate, to the Board of Directors

through the Audit Committee.

Decisions to prosecute or refer the examination results to the

appropriate law enforcement and/or regulatory agencies for

independent investigation will be made in conjunction with legal

counsel and senior management, as will final decisions on disposition

of the case.

Sample Fraud Policy For Corporation Page 2