1. This organization has a commitment to high legal, ethical, and moral standards.
    All members of staff are expected to share this commitment. This policy is
    established to facilitate the development of procedures, which will aid in the
    investigation of fraud and related offences.
  2. The Board already has procedures in place that reduce the likelihood of fraud
    occurring. These include standing orders, documented procedures and
    documented systems of internal control and risk assessment. In addition, the Board
    tries to ensure that a risk (and fraud) awareness culture exists in this organization.
  3. This document, together with the Fraud Response Plan and Investigator’s guide,
    is intended to provide direction and help to those officers and directors who find
    themselves having to deal with suspected cases of theft, fraud, or corruption.
    These documents give a framework for a response and advice and information on
    various aspects and implications of an investigation. These documents are not
    intended to provide direction on prevention of fraud.
    Fraud Policy
  4. This policy applies to any irregularity, or suspected irregularity, involving
    employees as well as consultants, vendors, contractors, and/or any other parties
    with a business relationship with this organization. Any investigative activity
    required will be conducted without regard to any person’s relationship to this
    organization, position, or length of service.
    Actions Constituting Fraud
  5. Fraud comprises both the use of deception to obtain an unjust or illegal financial
    advantage and intentional misrepresentations affecting the financial statements by
    one or more individuals among management, staff or third parties. Guidance is
    contained in the Appendixto this policy.
  6. All Managers and Supervisors have a duty to familiarize themselves with the types
    of improprieties that might be expected to occur within their areas of
    responsibility and to bealert for any indications or irregularity.
    The Board’s Policy
  7. The Board is absolutely committed to maintaining an honest, open, and well-
    intentioned atmosphere within the organization. It is therefore also committed to
    the elimination of any fraud within the organization, and to the rigorous
    investigation of any such cases.
  8. The Board wishes to encourage anyone having reasonable suspicions of fraud
    to reportthem. Therefore, it is also the Board’s policy, which will be rigorously
    enforced, that no employee will suffer in any way as a result of reporting
    reasonably held suspicions.
  9. All members of staff can therefore be confident that they will not suffer in any way
    as a result of reporting reasonably held suspicions of fraud. For these purposes
    reasonably held“suspicions” shall mean any suspicions other than those, which are
    raised maliciously and found to be groundless. The organization will deal with all
    occurrences in accordance with the Public Interest Disclosure Act.
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