Sample Fraud Policy For Corporation (Page 3 of 4) in pdf

CONFIDENTIALITY

The ______________ Unit treats all information received

confidentially. Any employee who suspects dishonest or fraudulent

activity will notify the _____________ Unit immediately, and should

not attempt to personally conduct investigations or interviews/interrogations

related to any suspected fraudulent act (see REPORTING

PROCEDURE section below).

Investigation results will not be disclosed or discussed with anyone other

than those who have a legitimate need to know. This is important in

order to avoid damaging the reputations of persons suspected but

subsequently found innocent of wrongful conduct and to protect

the Company from potential civil liability.

AUTHORIZATION FOR

Members of the Investigation Unit will have:

INVESTIGATING

• Free and unrestricted access to all Company records and

SUSPECTED FRAUD

premises, whether owned or rented; and

• The authority to examine, copy, and/or remove all or any

portion of the contents of files, desks, cabinets, and other

storage facilities on the premises without prior knowledge or

consent of any individual who might use or have custody of

any such items or facilities when it is within the scope of their

investigation.

REPORTING

Great care must be taken in the investigation of suspected

PROCEDURES

improprieties or irregularities so as to avoid mistaken accusations

or alerting suspected individuals that an investigation is under way.

An employee who discovers or suspects fraudulent activity will

contact the _____________ Unit immediately. The employee or other

complainant may remain anonymous. All inquiries concerning the

activity under investigation from the suspected individual, his or

her attorney or representative, or any other inquirer should be

directed to the Investigations Unit or the Legal Department. No

information concerning the status of an investigation will be given

out. The proper response to any inquiries is: “I am not at liberty to

discuss this matter.” Under no circumstances should any reference be

made to “the allegation,” “the crime,” “the fraud,” “the forgery,”

“the misappropriation,” or any other specific reference.

The reporting individual should be informed of the following:

• Do not contact the suspected individual in an effort to determine

facts or demand restitution.

• Do not discuss the case, facts, suspicions, or allegations with any-

one unless specifically asked to do so by the Legal Department or

____________ Unit.

Sample Fraud Policy For Corporation Page 3

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