acfe fraud prevention check-up - BKD

PR4-Workforce ManagementPR4.1 Define Roles, Responsibilities & Duties in relation to fraud risk management responsibilities includingsegregation of duties and avoidance of conflicts of interest.PR4.2 Screen & Select Workforce using selection criteria that minimize the risk of future fraudulent conduct based,in part, upon the results of background checks and how the history of any prior inappropriate or unlawful conductrelates to the responsibilities of the position for which the individual is being considered.PR4.3 Evaluate Performance & Promote Workforce based upon criteria that includes ethical and legal conduct anddoes not provide incentives or inducements to fraudulent or corrupt conduct.PR4.4 Compensate & Reward Workforce according to policies and practices that do not provide an incentive orinducement to commit fraud or corruption.PR4.5 Retire & Terminate Workforce in a manner consistent with fraud policy and using exit interviews as a finalconfirmation that all organizational assets have been returned, that confidential records have been returned ordestroyed in accordance with policy and identifying fraudulent, corrupt or otherwise inappropriate behavior.PR6-Risk Sharing & InsurancePR6.1 Design and Implement Risk Sharing & Insurance to protect the entity at an appropriate level based upon theentity’s risk tolerance after assessment of residual fraud risk not mitigated by controls, policies, and procedures.PR7-Preparedness & PracticePR7.1 Design Preparedness Exercises that afford an opportunity to practice response activities upon the detection offraud or corruption, including public disclosure and regulatory reporting.PR7.2 Conduct Preparedness Exercises to determine if planned approaches need to be modified to better protectagainst fraud risk, particularly reputational risk.M-Ongoing MonitoringM1-Control Assurance & AuditM1.1 Monitor Controls, Policies & Procedures through individuals assigned with such responsibility as periodicallyreviewed by internal audit, escalating detected issues through appropriate procedures for investigation, responseand remediation.M1.2 Survey Employees and Other Stakeholders as an additional check on whether the anti-fraud program iscreating the appropriate culture and is operating effectively, including questions related to whether there has beenobserved fraudulent or corrupt behavior, whether such was reported, and whether the discipline/response has beenconsistent, decisive and timely.M2-Hotline & HelplineM2.1 Define Hotline/Helpline Approach to consistently address concerns and issues through the validation,investigation, resolution, and remediation processes whether identified through audit or a report of suspectedfraudulent or corrupt conduct.M2.2 Provide Hotline that allows the entity to receive reports of suspected fraudulent or corrupt conduct both on anidentified and anonymous basis.M2.3 Provide Helpline that allows both internal and external stakeholders to obtain guidance on whether observedor suspected conduct constitutes fraudulent or corrupt conduct, and thus should be reported or otherwise addressedin accordance with applicable policies and procedures.75