acfe fraud prevention check-up - BKD

Sample Fraud PolicyREPORTINGPROCEDURESGreat care must be taken in the investigation of suspectedimproprieties or irregularities so as to avoid mistaken accusationsor alerting suspected individuals that an investigation is underway.An employee who discovers or suspects fraudulent activity willcontact the _____________ Unit immediately. The employee orother complainant may remain anonymous. All inquiriesconcerning the activity under investigation from the suspectedindividual, his or her attorney or representative, or any otherinquirer should be directed to the Investigations Unit or theLegal Department. No information concerning the status of aninvestigation will be given out. The proper response to anyinquiries is: “I am not at liberty to discuss this matter.” Underno circumstances should any reference be made to “theallegation,” “the crime,” “the fraud,” “the forgery,” “themisappropriation,” or any other specific reference.The reporting individual should be informed of the following:• Do not contact the suspected individual in an effort todetermine facts or demand restitution.• Do not discuss the case, facts, suspicions, or allegations withanyone unless specifically asked to do so by the LegalDepartment or ____________ Unit.TERMINATIONIf an investigation results in a recommendation to terminate anindividual, the recommendation will be reviewed for approval bythe designated representatives from Human Resources and theLegal Department and, if necessary, by outside counsel, before anysuch action is taken. The ___________ Unit does not have theauthority to terminate an employee. The decision to terminate anemployee is made by the employee's management. Should the_____________ Unit believe the management decisioninappropriate for the facts presented, the facts will be presented toexecutive level management for a decision.ADMINISTRATIONThe Director of ___________ is responsible for the administration,revision, interpretation, and application of this policy. The policywill be reviewed annually and revised as needed.APPROVAL________________________________(CEO/Senior Vice President/Executive_______________DatePage 4