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acfe fraud prevention check-up - BKD

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CriminologyFraud Prevention Programs• Must never agree with a competitor to restrict competition by fixing prices,allocating markets or other means.• Must not arbitrarily refuse to deal with or purchase goods and services fromothers simply because they are competitors in other respects.• Must not require others to buy from us before we will buy from them.• Must not require customers to take from us a service they don’t want just sothey can get one they do want.• Must never engage in industrial espionage or commercial bribery.• Must be accurate and truthful in all dealings with customers and be carefulto accurately represent the quality, features and availability of companyproducts and services.Compliance with Laws and Regulatory OrdersThe applicable laws and regulatory orders of every jurisdiction in which thecompany operates must be followed. Each employee is charged with theresponsibility of acquiring sufficient knowledge of the laws and orders relatingto his duties in order to recognize potential dangers and to know when to seeklegal advice.In particular, when dealing with public officials, employees must adhere to thehighest ethical standards of business conduct. When we seek the resolution ofregulatory or political issues affecting the company’s interests we must do sosolely on the basis of merit and pursuant to proper procedures in dealing withsuch officials. Employees may not offer, provide or solicit, directly or indirectly,any special treatment or favor in return for anything of economic value or thepromise or expectation of future value or gain. In addition, there shall be noentertaining of employees of the U.S. Government.Foreign Corr<strong>up</strong>t Practices ActNo employee will engage in activity that might involve the employee or thecompany in a violation of the Foreign Corr<strong>up</strong>t Practices Act of 1977. TheForeign Corr<strong>up</strong>t Practices Act requires that the company’s books and recordsaccurately and fairly reflect all transactions and that we maintain a system ofinternal controls; transactions conform to management’s authorizations; andthe accounting records are accurate. No employee will falsely reporttransactions or fail to report the existence of false transactions in theExcerpted from Fraud Examiners Manual 3

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