APPENDIX B

Corporate Fraud Policy

THIS POLICY DEFINES THE RESPONSIBILITIES of management and staff of the organization with regard to the establishment and maintenance of an effective system of internal controls and defines responsibilities when impropriety, including fraud, is suspected or detected.

POLICY

It is the policy of the board of directors that:

  • Management officers and supervisors will develop and maintain an appropriate system of antifraud measures and will integrate adequate internal controls into organizational processes to protect the corporate assets and resources for which they are responsible. The system should ensure that all transactions are appropriately authorized and properly recorded, that assets are properly safeguarded, and that actions can be accurately traced with originators identified
  • Management officers and supervisors will be responsible for evaluating and testing antifraud controls on a periodic basis and will develop the policies, guidelines, and procedures appropriate to ensure the implementation of an effective system of internal control.
  • Management officers, supervisors, and staff will maintain an understanding of the risks of irregularities or violations of internal controls and will be alert for any indicators of the potential existence of fraud.
  • Management officers, supervisors, and staff will escalate and report any suspected employee or ...

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