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acfe fraud prevention check-up - BKD

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CriminologyFraud Prevention Programs• Contributions or donations to recognized charitable and nonprofitorganizations are not considered gifts.• Items or services with a total value under $100 per year are excluded.DEFINITION OF SUPPLIER“S<strong>up</strong>plier” includes not only vendors providing services and material to thecompany, but also consultants, financial institutions, advisors, and any personor institution which does business with the company.GIFTSNo employee or member of his immediate family shall solicit or accept from anactual or prospective customer or s<strong>up</strong>plier any compensation, advance loans(except from established financial institutions on the same basis as othercustomers), gifts, entertainment, or other favors which are of more than tokenvalue or which the employee would not normally be in a position to reciprocateunder normal expense account procedures.Under no circumstances should a gift or entertainment be accepted whichwould influence the employee’s judgment. In particular, employees must avoidany interest in or benefit from any s<strong>up</strong>plier that could reasonably cause them tofavor that s<strong>up</strong>plier over others. It is a violation of the code for any employee tosolicit or encourage a s<strong>up</strong>plier to give any item or service to the employeeregardless of its value, no matter how small. Our s<strong>up</strong>pliers will retain theirconfidence in the objectivity and integrity of our company only if eachemployee strictly observes this guideline.REPORTING GIFTSAn employee who receives, or whose family member receives, an unsolicitedgift prohibited by these guidelines, should report it to his s<strong>up</strong>ervisor and eitherreturn it to the person making the gift or, in the case of perishable gift, give itto nonprofit charitable organization.DISCOUNTSAn employee might accept discounts on a personal purchase of the s<strong>up</strong>plier’sor customer’s products only if such discounts do not affect the company’sExcerpted from Fraud Examiners Manual 5

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