acfe fraud prevention check-up - BKD

APPENDIX B: SAMPLE FRAMEWORK FOR A FRAUD CONTROL POLICY(Or Plan) 40NOTE: This appendix is a sample from another entity. As such, no adjustment has been made to this material. Theinformation may or may not agree with all the concepts noted within this paper. The material is being provided as anexample that may be a used as a tool, reference, or starting point.1. EXECUTIVE SUMMARYDefinition of fraudStatement of attitude to fraudCode of conduct (relationship to)Relationship with entity’s other plansRoles and accountabilities2. SUMMARY OF FRAUD CONTROL STRATEGIESAppointment of fraud control officerExternal assistance to the fraud control officerFraud control responsibilitiesFraud risk management (including fraud risk assessment)Fraud awarenessFraud detectionFraud reportingInvestigation of fraud and other improper conductInternal control review following discovery of fraudFidelity guarantee and criminal conduct insuranceInternal audit program3. FRAUD RISK MANAGEMENTRegular program for fraud risk assessmentOngoing review of fraud control strategiesFraud risk assessmentImplementation of proposed actions4. PROCEDURES FOR REPORTING FRAUDInternal reportingReports by members of staffProtection of employees reporting suspected fraudExternal anonymous reporting40This sample is provided by The Australian Standard on Fraud and Corruption Control, AS 8001-2003. Please note that other definitions offraud exist, and thus it is important for the organization to explain clearly what types of transactions or activities are covered by the policy.48