0 ratings0% found this document useful (0 votes) 300 views17 pagesChap7 (Tabag)
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, 
claim it here.
Available Formats
Download as PDF or read online on Scribd
97. Each time an intemal autor draws 4 conclusion based on
teridence fom a sample, an addtional risk, sampling isk. Is
introduced. An example of sampling kis
& Projecting the resuls "of sampling beyond the
population tested
. Using an improper aut procedure witha sample
{_Incotectly applying an aut procedure to sample data
4. Drawing en erroneaus conclusion trom sample data
88. n applying variables samping, an auctor attempts to
2: Estimate a qualitative characterise of interest
bb Determine various rates of occurrence for specified
attrbutes
Discover atleast one instance f critical deviation
4. Predict @ monetary population value withn a range of
recsion
89. An auditor's finding was stated as follows: "Twenty of one
hundred randomiy slated items tested revealed that 200000
of cash discounts on. purchases. were lost” Ths varables |
Sampling finding i deficient because the
'2 Recommendation species no action
Sampling methodology i not defined
Amounts not material
<4. Probable effect on the entre population isnot provided
100, In addition 10 evaluating the frequency of
‘deviations in tests of contrels an auditor should also consider
Certain qualitative aspects ofthe deviations. The auditor most
likely would give broader consideration tothe implications of
deviation if it as
‘3 The only deviation discovered in the sample
i, dential to a deviation discovered during the prior
year's audit
Caused by an employee's misunderstanding of
‘4. Initially conceoled by a forged document
 
Pererming the Engegament (avait Evence)
Chapter 7
Frand
(One ofthe most important risks affecting an organization
its vulnerability to aud and no orgarization is exempt irom fraud
"645, The related International Professional. Practices Framework
Practice Guide on “Fraus" described the elfct of fraud in an
‘organization as flows
“Monetary lstes from fraud ore signicant. However, the fll
oa of ud a seansrable ttre of toe, producing
hd reputation including customer relationships. Depending
fm the severty of the lous, ongonizations can be ireparaby
harmed “due. to the final impact of aud sty
‘Therefore ic important for organizations to have 3 strong
aud program that inclader swarenes, prevention, ad
detection programs, at well t ud viakmaesment proces
to Meni aud ike within the organization”
The practice guide further provides thot effective
‘governance processes are the foundation of fraud risk management
Lack of effective corporate governance seriously undermines any
fraud risk management program. Because fraud negatively impacts
coxganzatons in many ways, financially, reputational. and though
psychological and. socal implications, . it is important for
‘organizations to have a strong fraud program that includes
_areness, prevention, and detection programs, a= wel 9s 9 fraud
Fisk assessment proces to dently sks within the organization
The intemal audit activity, on the other hand, plays an
limporant role in helping the management ints faud awarenes,
‘prevention and detection program,“due protessiona care" by considering the following:
DEFINITION
‘The ers the following definition of rau
‘The America Institute of Cortied Public Accountants (1CP4) defines
fraud based on the definition given by Al's Law Dictonay
‘sthesition 1990 as fellows
362 Fr
   
   
 
 
 
 
   
    
   
  
    
ia Standard 12201 requires ternal autos to exercise
Extent of work needed to achieve
the engagements objectives.
Relative complexity, materiality, or
significance of matters to which
assurance proceaures are applied
‘Adequacy and effectiveness of
governance, rk management nd
‘control processes
Probably of significant erors,
fraud or noncompliance
Cost of assurance in relation to
potential Benes.
then devin he
eae
"Frade sre sy plats charted by dee, concanent
laion faa Thee ct ae no dopenden open te
Zpplstion of test, of violence or of pal Fore Froud ae
ror by parse ond organization a siain mony propery
or eres 1 oil pyrene off Senet 10 See
coer eeeee eres
 
“Trad is a itentonal penerson of tra or the purse
taced ait bs ple eee Kb sa a
‘hing Belonging than or te sirveer 3 eal ight. A
sprain oF sabe of ic wine Of et or by cll
ty fee or mileaig legatins, or by concealment ho hich
Tedd bres ber! Seder phek es eel teil
‘kesne anther thee salt pon toi lel ay
fenere term, embracing. al maiiricur means wich. ham
Efe can dre ond ch ered Lo by oe lla
6 ahaage oer anher by fae sagen or bys
Fath wel cludes al rr eur en
Sy une way by which anther chee”
 
 
The definition of fraud and error applicable in rendering
fevtemal audit may is also provided below to gain more
Understanding on the nature of fraud and error Philippine
Standards on Auditing 240 (PSA) distinguishes fraud and error 95
follows
ror refers to an Unintentional misstatement in financial
statements, including the omission of an amount or @ dslosure,
such asthe Fllowing:
‘A mistake in gathering oF processing data fom which
financial statements are prepares
1+ An incorect accounting estimate ofsing from oversight
‘or misnterpretation of facts.
+ Mistake in the application of accounting principles
Felating to measurement, recognition, cassiiction,
presentation or disclosure
Fraud refer a intentional act by one of more inviduals
‘among management, those charged with governance, employees,
fr tiré pares, involving the use of deception to obtain an unjust
for ilegal advantage, It encompasses a range or regularities and
legal acts charactefzed by “intentional” deception or
rmistopresentaton which an indivicual “knows to be fase or does
fot believe to be true (IA Practice Advisories, Thus, the
distinguishing factor between fraud and eror is whether the
underlying action that esl inthe misstatement of the financial
satementsis intentional or unintentional.
Bramples of Fraud
2 theft
Unauthorized or ilaga use of company assets
Claims for series or goods not actualy provided
Sale or assignment of fititous or misrepresented assets
Intentional far to actin czcumstances where action
\srequired by company policies or aw
+ legal busines activities
a.‘Responsibility to Prevent and Detect Fraud
If “contro, as discussed in chapter 4, & a proces effected
by an entiy’s board of vectors, management and other personnel,
fame principle i applcable in faud prevention and detection
‘Meaning. the board and personnel at all levels of the oxganation
including every level of management. staf and internal auditors, ae
Well 35 the organization's external auditors have responsibilty for
ating with frau rik. Nonetheless, the “primary responsibity fo
the prevention and detection of fraud vests wth the management
Management should place a stong emphasis on fraud prevention,
which may reduce opportunites fr fru to take place, and aud
deterrence, which could persuade individuals not fo coment fad
because of the kelood of detection and_punshment. This
lavolves establishing a strong contrl envionment and metntining
pales and procedures to asst in achieving the objective. Of
‘ensuring, 9 far as posible, the orderly and efficent conduct ofthe
enttys business. Establishing approprate contol environment as @
deterent for fraud may include establishing,
+ Code of conduct
Ethics/raud policy to set the appropriate tne at the top
Ethics and whistleblower hotline programs,
ining and promotion guidelines and practices
ey
+ vestigation of reprted issues and remediation of conmed
intemal autos are
responsible for assisting? (Fl vk st potabya
Companies in prevering ai | fo i ccaesatie
detccing tad by examining | soars
find easing. odequcy ana | Pete
tttecveners othe eral
‘onto ten 98 descbed
thedston of tara
ting, "Iteral audtors are responsible in walang |
management's fad rk assesment in portly, tee pace
for denifjiogssesiog and testy potent fee and
misconduct Schemes and scenario Prachcehawsory 120M
further proves that teal atom shld howe saficen.
recline cc
Tebow 238
 
 
364 Fraud
Qversaht by the aut commie, Board or other oversight
knowledge to entity indicators of fraud (rau tisk factor or also
Known a= red flags) when conducting engagements. but is not
expected to have the expertise of a person whose primary
fesponsibilly i detecting and investigating fraud Infact, audlt
procedures alone, even when carted cut with due profesional care,
donot guarantee that aud wil be detected
‘Although sudtors may not be able to know the exact
ative of rationalzaton leading to faud, they are expected to
Understand enough abovt internal contralto ident opportunites
for fraud. Auktors should likewise understand fraud schemes and
scenaias as wal a be aware ofthe signs that point to fraud and
hom ta prevent them. Thus its the responsiblity of every internal
audit function to raise fraud awareness within an organization,
incuaing encouraging the -aucit committee and. senor
‘management t0 set the proper tone at the top, create contol
Consciousness, and help develop  cietable response to the
potential isk of aud,
Internal aut can reduce the risk of fru by assesing
crgansaton ire and governance acre, ae.
rotation pol, ensuing seamless suit policy across erties
Conducting balance sheet reviana, szesing the whsletlowet
poly, conducting ext inteiews et should also emphasize the
fxstence of and adherence to organizational values and. the
Cerporate code of conducts well 5 report any actives that ase
Suspicions that these coud e legal unethical or immoral trough
the wnsteblower hone or other means. The at comme sed
the board expect no Tess from competent and valve sang
Interna uct anc
Fraud 808Managing Froud
[A Practice Guide antited “Managing the Huxinese Risk of
raw: A Praca! Guide’ issued by the Insitute of intemal Auditors,
The Amercan Insitute of Certified Pubic. Accountants and
‘Association of Certified Fraud Examines. identified ve (S) Key
pinples for proactively estabishing an environment to effectively
anage an organization fud risks es flloms:
Principe 1
[AS art of an organizations governance structute, fraud
"sk management program should be tn place, including @
‘araten pote (or polices) to convey the expectations ofthe
board) of vectors and senior management regarding
managing fad ise
Principle 2
Frau risk exposure should be asessed perocialy by the
organization to dently specie potemial schemes. and
events thatthe organvation needs to mitigate
 
Principe 3
Prevention techniques to. avoid potential key fraud rk
events should be establshed, where feasible, to mitigate
possible impacts on the organization.
Principle 4
Detection techriques should be established to uncover
fraud events when preventive measutes fail or unmitigated
aks ae realize.
Princele 5
‘reporting process should bein place to soit input on
potential fraud, and a coordinated
 
66 Fraud
Wety DOES FRauD OCCUR?
Research consistently shows thee factors associated with
fraud, These factors are ao referred to as the Fraud Triangle:
OATS
 
Incentives/pressures/motivation to commit fraud
Regardless of cure, ethnic, religion, or other factors,
cenain individuals vill be motivated to commit fraud. A 2007
Grersight Systeme study dscovered thatthe primary reasons
why faud eecuts are “pressures to do. whatever It Takes 10
meet goals, Practice Advisory 1210 provides the following
‘motivators to commit fraud
Power
Gratification of a desie
1+ Pressure ether from physical stressor ftom outside
partis
 
‘The pressures to commit fraud include
+ Management compensation schemes
Persona wealth ties to franca results o survival ofthe
company
 
Frou 367,(Othe irancal pressures to improve earings othe
balance sheet (Le, to avid vilating debt covenant)
+ Personal factors including perzonalfianclneeds
Tomeet a lender's teria fr granting/estending loan
facilites
To meet corporate performance citera set i the
patent company
Tomeet personal performance citria
To trigger performance-elated compensation or eam
cut payments
+ To preserve a trend of consistent growth, aiding
volatile results
To reduce the value ofan owner-managed business for
Purposes ofa dvoree settlement
2. Opportunities to commit fraud
‘process may be designed propel for typical conditions
however, © window of opportunity may atse for something to
90 wrong or erates czeumstonces forthe contol to fal. AR
‘ppetinity for froud may exist due to poor contol design oF
lack of controls (Practice Advisory 2120), The fllowing are the
‘waring sign indicating opportunities for fraud (Red Flags oF
Fraud rik factors
+ Weak o non-existent intemal controls
+ Complex or unstable organizational structure
Inetfecive monitoring of management, ether becouse
board of directors is not effective, or management i
dominant
Significant accounting estimates made by management
1 Significant elated party transactions
* Industry dominance, including ably to cctate terms
1 supplies or customers
Simple transactions made complex through djinted
recording process
B68 Freud
 
     
    
      
    
     
      
 
   
1COSO REPORT
(C080 tenia characteris of compre
‘hat had perpetted fa
Rationalization of the frau as accoptable
The nature of fraud rationalization often cffers depending on
the type of ead
For defalatonsratisnaizations often revolve around
personal sues:
* Personal financial problems
‘+ Misteatment by the company
1 Sense of entitlement
1 Everyone does it
+ For fraudulent fancial reporting the rationalaations may
involve personal or organizational issues:
* Compensation base on financial results personal)
+ Ego personal)
+ Necessary for organization to survive
 
  
  
   
  
  
  
  
    
TESSONS LEARNED,
Andes a ik
hee they do ot
idle the ete company
hetero ceea
ae
When rd rok ndeatoe
Na inter oud department sa Bacvere hey it
(£0 and Jor CFO vad in 83% ofthe |__be thoroughly invenigted
cee + Computer emoreau be
viewed a ak ctor
 
    
rd of dictre dominated by
Patents rie
    
 
  
 
 
ath tlhe or
fraud might be aking place and that |* Dominant certs cn bea
rts ol eee ent rd preblen
Urvegmte theese Nader hood not
‘Mon revenue frais ahd promature | assume al pple ae
copii or Stow earns 2
Companies were at ststions or
rear breve pir tthe Fad‘nts oF avo
[A The hn nut of Coc Pub he
ied Pubic Acoma
» Understand the business and how changes in
the economy might affect the business
302 Fraud
 
> Understand management's motivations for
commiting a fraud
> Identify opportunities fr other employees to
commit defaleation
> Anaiye changes n company's financial results
for reasonableness
> Identify areas that might suggest fraud
4, Evaluating Evidence
‘The auditor's skeptic shouldbe heightened whenever
There are discrepancies inthe accounting records
“The auditor finds conflicting of missing evidential matter
‘The relationship with managements stained
“There are sigcant or uncsual transactions around
year-end
Conducting the Avdt
(Overview ofthe process to integrate fraud risk
‘assesament and fraud procedures into the alt includes
ten major steps
Understand the nature of fraud, motivations to commit.
{raud, and how fraud may be committed
Develop and implement an approach based on
profesional skepticism
Brainstorm and hare knowledge within the aud eam
‘Audit team to alscuss the risk of material
misstatement due to fraud ~bralnstorming to
Allow experienced auditors to educate less
‘experienced audtors
1 Setthe prope level of professional skepticism
forthe audit
Fraud 883Obtain information useful indenting and assessing
fraud rake
+ Topics should inch:
deni specific fraud sks and areas key to be
affected by fraud
+ Bustence of rua risk indicators shoule cause the
 
1 Linkage prices: fram contra defiieniestoaueht
Consider how fraud can be perpetrated & eae
 What account balances would be affected
and how
>» What audit procedures would provide
‘evidence on whether the account balance
sstated
> Do the aut procedures provide objective
‘evidence indepandent ofthe parties who
have acces tothe arste
"= Using Computers to Analyze the Possibly of rad
Audit software can read a fle and perform 3
umber of procedures to analyze the possiblity
oe of rau
1. Expand audit testing to more detailed sampling fag: IRN Ns atte
ae heeera ete ‘mathematical ecensions and logical
3. Place more emphass on independent outside aoe
ee Statistical selection
4. Perform more procedure at year-end
Evaluate the quality and effectiveness of compony
Controls in mitigating the rik of aud 4
* The procedures used by the auditor should reftect
the intemal control westnesees and freud risk
Indicators found with the lent. Audit procedures
Lsed ar based on specific control deficiencies,
384 Froud
6
i
frou
team
 
‘Search for duplicate entries
‘Analyze unusual patterns in data
‘Analysis of logical relationships among
datasets
“dently unusual sources of entries to a9
Search for mising data
Adjust act procedures to address the ri of fraud and
‘gather evidence. spectialy related tothe possibilty of
{Evaluate findings: evidence signal fraud might ex,
consider whether specialists are needed forthe audit
Froud 885.J Communicate possibilty of foud to management and
ud committee
Document al steps relate to fraud
5. Communicating the Existence of Froud
8, Froud should be communicated to level at which effective
ation can be taken
. The auditor must communicate the existence of aud to
‘management, the Board and the audit committee
fad involves top management. the auditor must assess
the actions taken bythe Board
4. sufficient actions are not taken, the alitor must consider
the control envonment and the possible need to resign the
engagement
©, The alitor must determine that the financial taternents
have been corrected andthe fraud adequately dscosed
the statements are not corected, the auctor shoul issue
‘2 qualified or averse opinion
9. Insome cases, the auditor may be required to report the
fraud to ouside parties, such a to meet regulatory
requivements
fh For public companies, mater raud reflects a weakness in
intemal contol and may need be reported
6. Audit Documentation
{The ault team should document the full extent of the
process described
b. That documentation should incude:
* Discussion among audit team members including
the assessment of fraud rik and how such frauds
might take place
+ Discussion ofthe factors that affected te sk
+ Audi procedures performed
1+ Nees for corroborating evidence
Evaluation of aud evidence and communication to
Feared parties
B86 Freud
 
’ fraud tsk atsessment shouldbe perormed periodically to
‘dentity potential schemes and events tht need to be mitigated
Most organzations have witten policies and procedures to manage
fraud rises such a5 codes of conduct, expense account procedures
4nd incident investigation standards. They usually have. some
{activities that managemant has implomented to asso55 risks, ensue
Compliance, identify and investigate violations, measure and report
the organuzations performance to appropriate stakeholders, and
communicate expectations.
Internal auditing should provide objective assurance to the
board and management that the contol thay have in place ate
appropriate and sufficient for identified fraud 1sks given the
‘rgantations risk appetite. Internal auditors may even! the
comprchensiveness and. adequacy of the sks identified by
management, especially with regard to management overtie ss
‘The practice guide issued by the IVAICPA/ACE proves
vidance for conducting a avd risk assessment. An effective fraud
ek management assessment shouldnt where fraud may occur
and who the perpetrators might be. Therefore, control activities
Should always consider both the fraud scheme and the individuals
‘within and outside the organization who could be the perpetrators
of each scheme, Ifthe scheme is collusive preventive controle
Should be augmented by detective controls as collsion negates
the contol effectiveness of segregation of dues,
Fraud as defined in the Practice Guide a= any
intentional ct ot omission designed to deceive
‘thers, resulting inthe vit suffering a less and/or
the perpetrator achieving 2 gai,
Collvive Scheme — a scheme performed by two oF
frome detest opti
 
Fraud 887The foregoing definition of frud ena intentional
misconduct, designed to evade detection AS sch he Nord fa
assessment should antcipte the Behavior fa poten reed
erp, Conseqenty ts inporant to design hau deterton
Drocedures that perpetrator moy not eect requres 3 en
mindset and involves asking questions suchas a
+" How might a aud perpetaor exploit weknests in
the-system ofcontole
+ How eld 9 perpetrator oreide. or crcumvent
+ What coulda perpetrator doo conceal the ua?
Elements of Froud Risk Assessment
Frau sk tzessment general ices tee key laments
1 Aen tore aud sts
Gather nfermation toobuin the population of
frau that could apy tthe ogoneation vetoed fy
ths paces the exp congestion ofa peso feud
schemes and “scenaros icenves pres
ppotunites to comm aud and aud rk open to
Sraenaton, Bastin sa poner ol en sate
Wenables discussione ofthe tentves, ores
oppotuntes to comm fraud Wak af sane nan
verde of contol and the popuaion of Toes Tele
leant to the ent.» Eerie balnstoning aveies
Preparation tr aance ofthe meeting esa ee
‘gendaand fcitate the sesion and openness ne
fegerding potential ke and cnt Other fas stat
teultoy ard legal acon akg wel or a tae
of nfamationTeinaiogy I on fad ls oie shale oe
Comidered itera i ntaton proces
The frau ts identification process should include
fan assessment of the incentives, pressures, apd)
‘Spporunis to commit aud feta dscssion on Fraud
angle, Table 7-1 page 367). Incentive programs sould
be evaluated by the board for seriar mangement and by
management for others as to. how they may affect
employees’ behavior when conducting business oF applying,
Professional judgment (eg. estimating bad debt alowerces
‘or revenue recognition). Financial incentives and the mets
{on hich they ate based can provide a map to whece aud
'S'most kel to. occur There may also be noafinancia
Incentives, such as when an employee records 2 fictitious
‘wansaction 0 he or she does not have to explain an
otherwise unplanned varance. Even maintaining the status
quo. sometimes a powertl enough incentive. for
Personnel to commit fraud
‘Assess litetinood and significance of inherent Rud sks
‘sts the relative lualnoed and potental sgaicance of
‘dented fraud vats based on stra Iormaton known
fraud schemes, and iterdens mith staf Incuing business
process onners.Asesing the athood and sgfcance of
0c) potential aud nek & 9 subjective proces Al aud
aks remot eal Heeb nor will all fs. have 3
Signitcane impact on every organization. Assessing. the
ikeeod and ngrificance of ested herent ke allows
fhe organization t9 manage te foud nets ond apply
reverive and detective procedures. tational.
(portant to fe consider ra rk tothe business on an
ret bess ortho nado of kvm onl
"aking ths approach, management il be beter able to
erie a rzbvont nud Fels ane deapn contol
Saves the fs. Aker mapping aud rats to relevant
otros, certain rsa sk wl remain, ineicg the isk
‘tmanagements oenide of eablared controls
Paar coc er Moa Oh oe
real dba ners,
Bee ae cea
Neato ia plead eal eed
ce en ee
aan Cece acs ti eal
Serb poy wed ren
Bes arte
Maiaor eacetar oie emcea
TS eee arrose eee
 
 
388 FraudSigritcince
“Managements assesment ofthe signicance of fraud
tisk should nclde not only nancial statement and
Pete eee ttle erates int
‘organizations operations, brand valu, and reputation,
well as criminal cv, and regulatory tabi. Generally,
rgnizaties Gn categorie the sipniicance of potent
Frauds in thee categories at follows, inconsequential
more than inconsequential and mater
 
 
3. Respond to reasonably likely and significant inherent and
‘residual fraud risks Decide what the response should be to
address the identified rsks and perform a cost benefit
analysis of frau risks over which the organization wants 10
implement controls or specific feud detection procedures,
Risk tolerance (Page 146) varies ffom organization 10
organization, At the highest level the board set. the
ftganzation’s rk tolerance level taking into consideration
is responsibites to all shareholders, coptalpronders and
Stakeholders. While some organizations want only to
‘dares ‘faud risks that could have materia fnanclal
Statement impact, other organizations want to have a more
robust fraud response program. Many organizations wal
State that there isa "zero tolerance” policy with respect to
fraud. However, there may be certain fraud risks that an
‘organization considers too expensive and time-consuming
to address via controls. Consequent, the organization may
decide nat to put controls in place to adress such sks. If
fraud is dscovered,2er tolerance for fraud wil be applied,
 
| FRAUD PREVENTION
Prevention is the most proactive fraud.
fighting measure The design and implementation of.
contol activities should be a cootcnated effort
Speatheaded by management with on. assembled
fast of employees. Callecvely, this cross section of
‘the organization should be able to adres al ofthe
ented tsk, desion and lament the conto
ites and sue thr the feces used ae
equate to. prover tau’ rom ‘occuring in
selstdnce wit the oganantions olen
Sample Fraud Preventive Controls
3) Human Resources Procedures. AN
Organizations HR function can play an
important role in. faud prevention by
implementing the felling procedures
+ performing Background
Investigations |
+ Antotaud Training
*aluating Performance and
Compensation Programs
Conducting Eat inteniows
1b) Authority Lit, Fraud i ess kely when an
indvaduats level of authority i
Commensurate with his or her level of
Tesponsiblity, A migalignment_ between
futhorty. and responsibilty, portclary in
the absence of control” actives and
Segregation of tis, can ead to fraud
©) Transaction-level Procedures. Reviews of
thidpary and related-pary.tvansactions
‘an also help prevent feud. Because froud
Schemes often invalve the use of third-party
fntiie/indiduals, organizations need
thorough measures atthe font-end that will
prevent the back-end acts,
& FRAUD DETECTION
Having effective detective controls in place and
visible tone of the strongest deterents to
Fraudulent behavior Used in tandem with
preventive control, detective controls enhance a
aud risk management program’ effectiveness by302 Fra
providing evidence that preventive controle are
working as intended and identifying fraud that
‘occurs. Although detecive contiols may. provide:
evidence that fraud is occuring oF hae occured
they are not intended to prevent fra,
Sample Fraud Detective Controle
8) Whistle blower hotines
b) Process contols sich as reconclitions
independent reviews, physical
Inspections/counts analyses, and audit. A
lack of, or weakness in, preventive controls
increases the rok of fraud and paces @
sreater burden on detective controls The
more significant the fous isk the more
sensitive to occurence the detective control
Should be,
©) Proactive Fraud Detection Procedures
% FRAUD INVESTIGATION AND. CORRECTIVE
ACTION
‘A reporting process should be in place to
soli input on potential fraud, and a coordinated
poroach to investigation and conectve action =
should be used to help ensure potent fraud
adalessed appropriately and timely. Its essential
that any violations, deviation, or other breaches of
the code of conductor contol, regardless of whee
i the organization, or by whom they ate
‘committed, be reported and deal with in a tnely
manner. Appropriate punishment must be imposed,
and suitable remediation completed, The board
should ensure thatthe same ules are applied at all
levels of the organization, including senior
management.
The imestigation and response system should
Include a proces for
+ Ctegoring sues
{Cneming the vl of th allegation
1 eiing te every ofthe allegation.
2 Betting the sue or investigation nen
+ Reforing sues ouside the scape ofthe
program
+ Eondscting the ivesgation and fac
fda.
+ Resolving or dosing the investigation
1 UEtng nper of intomaton tha should be
Kept confident
+ Dahan how telnvestgnton wl be
econ
+ Manugng se retaining documents and
rea
Fraud 393