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acfe fraud prevention check-up - BKD

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CriminologyFraud Prevention Programs• Using, divulging or transmitting confidential company information in thecourse of outside employment or other relationship or any succeedingemployment or other relationship at any time; and• Trading in the company stocks, or the stocks of any company, based oninformation which has not been disclosed to the public or divulging suchinformation to others so that they might trade in such stock. Insider tradingis prohibited by company policy and federal and state law.Employees shall not seek out, accept or use any confidential companyinformation of or from a competitor of the company. In particular, should wehire an employee who previously worked for a competitor, we must neitheraccept nor solicit confidential information concerning that competitor from ouremployee.Classified National Security InformationOnly employees with proper government clearance and a need to know haveaccess to classified national security information. Government regulationsoutlined in company instructions for safeguarding must be followed. Disclosingsuch information, without authorization, even after leaving employment, is aviolation of law and this code.Adverse information about employees having government clearance must bereported to the Security or Law Departments’ representatives havingresponsibility for clearances.Company AssetsCash and Bank AccountsAll cash and bank account transactions must be handled so as to avoid anyquestion or suspicion of impropriety. All cash transactions must be recorded inthe company’s books of account.All accounts of company funds, except authorized imprest funds, shall beestablished and maintained in the name of the company or one of itssubsidiaries and might be opened or closed only on the authority of thecompany’s Board of Directors. Imprest funds must be maintained in the nameof the custodian and the custodian is wholly responsible for these funds. AllExcerpted from Fraud Examiners Manual 9

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