The SABC s fraud hotline is provided and managed externally by Whistle Blowers.
|
|
- Lester Lesley Hunter
- 7 years ago
- Views:
Transcription
1 SABC s Fraud Hotline Purpose The SABC introduces its dedicated fraud hotline to fight fraud and corruption by providing a platform to its stakeholders to anonymously report suspicions of fraud, theft, corruption and other misconducts such as violations of SABC policies and procedures, regulations and statutory compliance relating to the business of the SABC. The SABC s fraud hotline is provided and managed externally by Whistle Blowers. Whistle Blowers (Pty) Ltd is an independent subscription service, offering a 24/7 free call facility enabling employees or third parties to anonymously blow the whistle on irregularities within the subscribing company. Whistle Blowers is an accredited member of the Ethics Institute of South Africa and has a global footprint in over 25 countries. All calls made to the SABC s Whistles Blowers fraud line are screened by trained professionals and a comprehensive report is sent to the SABC s Forensic Audit unit for further investigation. SABC policy statement The SABC will not tolerate theft, fraud and corruption, maladministration or any other dishonest activities of a similar nature. Such activities will be investigated and actions instituted against those found responsible. Furthermore, actions may include the laying of criminal charges, civil and administrative actions and recoveries of losses suffered where applicable. Frequently Asked Questions Q. Does the SABC really want me to report? Yes, the SABC encourages all citizens as they may have knowledge of what is going on in the organisation - both good and bad. You may have initial knowledge of an activity that may be a cause for concern. Your reporting can minimise the potential negative impact on the organisation and its people. Also, offering positive input may help identify issues that can improve corporate culture and performance. Q. Why should I report what I know? We all have the right to work in a positive environment, and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting
2 appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company. Q. what happens after I made a call to Whistle Blowers? After you made a call to Whistle Blowers and gave sufficient answers on who, what, where, when how and why, they will compile a comprehensive report which is forwarded to the SABC Forensic Audit team for further investigation into the allegations. Upon completion of the forensic audit investigation, a report is then issued to senior management for action. These reports also go to the Board, Board subcommittees and the auditor general. Therefore there is no way that your matter will be swept under the carpet. Q. If I become aware of a violation, what should I do? You should use the SABC s Fraud hotline to anonymously report your observation or suspicion. First, the hotline ensures that your report gets to the appropriate people, who have broader experience in these matters, in a timely manner. More importantly, reports can be filed anonymously, if you so choose, and all report information is secure and held in the strictest confidence. Trained call centre consultants from Whistle Blowers will assist you to make sure that all detail / information is captured correctly. Q. I am aware of some individuals involved in unethical conduct, but it doesn't affect me. Why should I bother reporting it? All unethical conduct, at any level, ultimately hurts the company and all its employees. So if you know of any incidents of misconduct or ethical violations, you should consider it your duty as a citizen to report such misconduct to the SABC. Q. I am not sure what I have observed or heard is a violation of company policy, or involve unethical conduct, but it just does not look right to me. What should I do? File a report. Whistle Blowers can help you prepare and file your report so it can be properly understood. We'd rather you reported a situation that turned out to be harmless than let possible unethical behaviour go unchecked because you weren't sure.
3 Q. What if my boss or other managers are involved in a violation? Won t they get the report and possibly start a cover-up? The Whistle Blowers system and report distribution are designed so that no report is ever shared with any person who is implicated in the conduct, their peers or their subordinates. This will help to eliminate cover-ups by any implicated individual. Q. What if I remember something important about the incident after I filed the report? When you file a report via the toll-free Whistle Blowers number, you receive a unique reference number. You can return to the Whistle Blowers system again and add further information that will help resolve open issues or to get feedback on actions taken. Below are some of the most common issues that may be reported and the definitions thereof. Conflict of interest A conflict of interest is defined as a situation in which a person, such as a public official, an employee, or a professional, has a private or personal interest sufficient to appear to influence the objective exercise of his or her official duties. (Examples include: inappropriate vendor relations, bribery, misuse of confidential information, inappropriate customer relations) Falsification of contracts, reports or records Falsification of records consists of altering, fabricating, falsifying, or forging all or any part of a document, contract or record for the purpose of gaining an advantage, or misrepresenting the value of the document, contract or record. Misconduct or inappropriate behaviour
4 Intentional wrongdoing; specifically: deliberate violation of a law or policy. Fraud The unlawful, intentional making of a misrepresentation resulting in actual or potential prejudice to another. Corruption Directly or indirectly accepting or agreeing to accept any gratification from another person; giving or agreeing to give any other person any gratification in order to influence that person directly or indirectly to exercise his powers, duties or legal obligations Theft The unlawful and intentional misappropriation of another person s property or property which is in his/her lawful possession, with the intention to deprive the owner of its rights permanently. ACTIONS CONSTITUTING FRAUD, CORRUPTION AND THEFT Fraud, Corruption and Theft manifests in a number of ways and varying degrees of intensity. These include, but are not limited to: i. Any dishonest or fraudulent act; ii. Misappropriation of funds, supplies, or other assets; iii. Impropriety in the handling or reporting of money or financial transactions; iv. Profiteering as a result of insider knowledge of SABC s activities; v. Disclosing confidential and proprietary information to outside parties; vi. Disclosing to other person s securities activities engaged in or contemplated by the SABC; vii. Accepting or seeking anything of material value from contractors, vendors, or persons providing services / materials to the SABC; viii. Destruction, removal, or inappropriate use of records, furniture, fixtures, and equipment; ix. Private use of the SABC s assets, including vehicles; x. Falsifying subsistence and travel claims; xi. Conspiring with others to obtain a tender;
5 xii. Disclosing proprietary information relating to a tender to outside parties; xiii. Accepting inappropriate gifts from suppliers; xiv. Employing family members or close friends or associates without declaring the relationship; xv. Operating a private business during working hours; xvi. Stealing equipment, stock footage or supplies from work; xvii. Accepting bribes or favours to process requests; xviii. Accepting bribes, favours or turning a blind eye to a service provider who does not provide an appropriate service; xix. Submitting or processing false invoices from contractors or other service providers; xx. Misappropriating fees received from customers, and avoiding detection by not issuing receipts to those customers; xxi. Inappropriate airtime sales discounts; xxii. Any similar or related irregularity; xxiii. Form of favouritism which result in improper favouring of relatives and friends without following due process; and xxiv. Abuse of power. How to report You can report any irregularities to either of the following: Whistle Blowers Anonymous hotline: Or General Manger: Forensic Audit Fax: Or SABC Forensic Audit offices: Radio Park Building
6 11th Floor Room 1147 Telephone: / 2918 / 4964 PROTECTED DISCLOSURE In terms of the Protected Disclosures Act No 26 of 2000: Clause 6 Protected disclosure to employer (1) Any disclosure made in good faith (a) and substantially in accordance with any procedure prescribed, or authorized by the employee s employer for reporting or otherwise remedying the impropriety concerned; or (b) to the employer of the employee, where there is no procedure as contemplated in paragraph (a), is a protected disclosure. (2) Any employee who, in accordance with a procedure authorised by his or her employer, makes a disclosure to a person other than his or her employer, is deemed, for the purposes of this Act, to be making the disclosure to his or her employer
Fraud Policy FEBRUARY 2014
Fraud Policy FEBRUARY 2014 TABLE OF CONTENTS 1. Application of Policy... 2 2. Purpose of Policy... 2 3. Fraud Policy... 2 4. Definition of Fraud... 2 5. Duties and Responsibilities of an Employee or Contractor...
More informationSCHOOLS FRAUD RESPONSE PLAN
SCHOOLS FRAUD RESPONSE PLAN Author Jean Gleave, Chief Internal Auditor Date Last Agreed May 2012 Review Date May 2014 1 WARRINGTON BOROUGH COUNCIL SCHOOLS FRAUD RESPONSE PLAN Introduction The purpose of
More informationWHISTLE BLOWING POLICY
POLICY DOCUMENT NUMBER 19 WHISTLE BLOWING POLICY POLICY NUMBER VERSION DATE APPROVER/EXO MEMBER SIGNATURE OF APPROVER 1.0 5 Aug 2013 Nick Vlok TABLE OF CONTENTS PAGE 1. PURPOSE OF THE POLICY 3 2. SCOPE
More informationANTI-FRAUD POLICY Adopted August 13, 2015
ANTI-FRAUD POLICY Adopted August 13, 2015 Introduction The Board of Commissioners of the Housing Authority of the City of Muskogee (MHA) has established an anti-fraud policy to enforce controls and to
More informationWhistle Blower Policy
22 Ulsoor Road, Bangalore - 42 Section No : WB-A Copy No : Page No : 1 of 9 Whistle Blower Policy 22 Ulsoor Road, Bangalore - 42 Section No : WB-B Copy No : Page No : 2 of 9 Contents Sl. No. Title Section
More informationBusiness Ethics Policy
Business Ethics Policy The WCH Ltd Ethics Code The business philosophy of WCH has been developed around a core set of values which are fundamental to the organisation s development and success. One of
More informationFiscal Policies and Procedures Fraud, Waste & Abuse
DORCHESTER COUNTY, MARYLAND Fiscal Policies and Procedures Fraud, Waste & Abuse Adopted August 11, 2009 SECTION I - INTRODUCTION The County Council of Dorchester County, Maryland approved on August 11,
More informationRaising concerns (Whistleblowing) Policy and Procedure
Raising concerns (Whistleblowing) Policy and Procedure The Public Interest Disclosure Act provides strong protection for workers who blow the whistle on or raise a genuine concern about malpractice. The
More informationCODE OF BUSINESS CONDUCT AND ETHICS ( CODE )
BHAGERIA DYE-CHEM LIMITED CIN: L24230MH1989PLC052574 REGISTERED OFFICE: A1/101 VIRWANI INDUSTRIAL ESTATE, W.E. HIGHWAY, GOREGAON [EAST], MUMBAI 400 063. Web: www.bhageriagroup.com Phone: 91-22-40436666,
More informationEthical Corporate Management Best Practice Principles
Ethical Corporate Management Best Practice Principles Article I: Last Updated: 2015/11/06 (Purpose of establishment and scope of application) This set of principles was instituted in accordance with the
More informationCode of Business Conduct and Ethics. With Special Message for Senior Business and Finance Leaders
Code of Business Conduct and Ethics With Special Message for Senior Business and Finance Leaders Index Letter from our Chairman & CEO and from our President Annual Letter to Senior Leaders Introduction
More informationWHISTLEBLOWING POLICY NUS policies adopted and adapted by Yale-NUS College
WHISTLEBLOWING POLICY NUS policies adopted and adapted by Yale-NUS College Introduction 1. The University and Yale-NUS College (the College) are not-for-profit organizations that rely largely on public
More informationAnti-bribery and Fraud Protection Policy
Anti-bribery and Fraud Protection Policy Dear Colleagues and Partners, Carbo One Limited is one of the largest coal trading companies in the market and the nature of its business requires interaction with
More informationWhistleblower Policy
Whistleblower Policy The Feedback Group including Feedback Infra, its subsidiaries and associate companies, is committed to conducting its affairs ethically and lawfully. The Group's philosophy on ethics
More informationHow To Handle A Fraud At Psc
FRAUD POLICY Purpose and Background PSC is committed to the highest standards of moral and ethical behavior. The purpose of PSC s Fraud Policy is to foster an environment that promotes awareness to fraudulent
More informationINTERNAL REGULATIONS OF THE AUDIT AND COMPLIANCE COMMITEE OF BBVA COLOMBIA
ANNEX 3 INTERNAL REGULATIONS OF THE AUDIT AND COMPLIANCE COMMITEE OF BBVA COLOMBIA (Hereafter referred to as the Committee) 1 INDEX CHAPTER I RULES OF PROCEDURE OF THE BOARD OF DIRECTORS 1 NATURE 3 2.
More informationHelix Energy Solutions Group, Inc. Code of Business Conduct and Ethics
Helix Energy Solutions Group, Inc. Code of Business Conduct and Ethics Introduction This Code of Business Conduct and Ethics ( Code ) covers a wide range of business practices and procedures. It does not
More informationAudit Committee Charter
Audit Committee Charter 1. Members. The Audit Committee (the "Committee") shall be composed entirely of independent directors, including an independent chair and at least two other independent directors.
More informationPostNL Group Policy. on Fraud Prevention. PostNL Group Policy. on Fraud Prevention Page 1 of 15
on Fraud Prevention on Fraud Prevention Page 1 of 15 Contents 1 Objective of this group policy 3 2 Scope 4 3 Definitions 5 4 Policy provisions and responsibilities 7 4.1 Fraud Prevention controls 7 4.2
More informationWhistleblowing Policy. Page 2 of 15. Copyright statement. United Gulf Bank B.S.C. 2011
Copyright statement Page 2 of 15 United Gulf Bank B.S.C. 2011 Unless explicitly stated otherwise, all rights including those in copyright in the content of this document are owned by or controlled for
More informationPolicy-Standard heading. Fraud and Corruption Policy
Policy-Standard heading Fraud and Corruption Policy September 2013 Table of contents Introduction 3 Purpose 3 Scope 3 Related Policies and Processes 3 Definition of Fraud and Corruption 4 Policy 4 Code
More informationWESTERN ASSET MORTGAGE CAPITAL CORPORATION CODE OF CONDUCT
WESTERN ASSET MORTGAGE CAPITAL CORPORATION CODE OF CONDUCT I. Introduction This Code of Conduct (the "Code") sets out basic principles to guide the day-today business activities of directors, officers
More information1. Compliance with Laws, Rules and Regulations
CODE OF BUSINESS CONDUCT - EXAMPLE INTRODUCTION This Code of Business Conduct covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic
More informationI. AUTHORITY AND PURPOSE
2015 AMENDED AGREEMENT FOR BUSINESS DEVELOPMENT BY KENOSHA COUNTY AND KENOSHA AREA BUSINESS ALLIANCE FOR KENOSHA COUNTY REVOLVING LOAN FUND & BUSINESS PARK DEVELOPMENT This agreement between Kenosha County,
More informationDLI CODE OF BUSINESS CONDUCT & ETHICS
DLI CODE OF BUSINESS CONDUCT & ETHICS All DLI employees, regardless of where they are located, must conduct their affairs with uncompromising honesty and integrity. Business ethics are no different from
More informationSanchez Energy Corporation. Code of Business Conduct and Ethics
Sanchez Energy Corporation Code of Business Conduct and Ethics Introduction The Board of Directors (the Board ) of Sanchez Energy Corporation (the Company ) has adopted this Code of Business Conduct and
More informationGLOBAL PORTS INVESTMENTS PLC
Adopted by the Directors of GLOBAL PORTS INVESTMENTS PLC Resolution of 14 July 2008 GLOBAL PORTS INVESTMENTS PLC (previously GLOBAL PORTS INVESTMENTS LTD) ANTI-FRAUD POLICY TABLE OF CONTENTS 1. INTRODUCTION.....
More informationFor personal use only
Code of conduct for directors and senior executives Sino-Excel Energy Limited ACN 085 162 456 (Company) MinterEllison L A W Y E R S RIALTO TOWERS, 525 COLLINS STREET, MELBOURNE VIC 3000, DX 204 MELBOURNE
More informationRiverside Community College District Policy No. 7700 Human Resources
Riverside Community College District Policy No. 7700 Human Resources BP 7700 WHISTLEBLOWER PROTECTION References: California Labor Code Section 1102.5; Government Code Section 53296; Private Attorney General
More informationA Message to Employees
A Message to Employees Financial integrity is key to the Company s reputation among our investors, customers, business partners, suppliers, regulators, government entities, employees and professional advisors.
More informationFraud Risk Management Procedures
Fraud Risk Management Procedures 1. Introduction KCE Electronics Public Company Limited ( KCE or the Company ) is committed to achieving the highest levels of business integrity, morals and transparency
More informationOIG Hotline. Overview... 2. Examples of Allegations That Should Be Reported to the OIG Hotline... 3. Guidelines for Reporting Fraud...
OIG Hotline Overview... 2 Examples of Allegations That Should Be Reported to the OIG Hotline... 3 Guidelines for Reporting Fraud... 4 False Claims... 4 Embezzlement of Government Funds... 4 Contract Fraud...
More informationFraud and the Government Internal Auditor
Fraud and the Government Internal Auditor January 2012 Fraud and the Government Internal Auditor January 2012 Official versions of this document are printed on 100% recycled paper. When you have finished
More informationWellesley College Whistleblower Policy Adopted April 2009
Wellesley College Whistleblower Policy Adopted April 2009 1. General Wellesley College (the "College") requires all employees (including faculty) to observe high standards of business and personal ethics
More informationBERKSHIRE HATHAWAY INC. CODE OF BUSINESS CONDUCT AND ETHICS
BERKSHIRE HATHAWAY INC. CODE OF BUSINESS CONDUCT AND ETHICS A. Scope. This Code of Business Conduct and Ethics applies to all Berkshire Hathaway directors, officers and employees, as well as to directors,
More informationPrivacy Statement Relating to the Collection, Use and Disclosure of Personal Data & Customer Information
Privacy Statement Relating to the Collection, Use and Disclosure of Personal Data & Customer Information Safeguarding personal data and customer information and using it in a lawful manner, consistent
More informationPART A: OVERVIEW...1 1. INTRODUCTION...1 2. APPLICABILITY...1 3. OBJECTIVE...1 PART B: LEGAL PROVISIONS...2 4. LEGAL PROVISIONS...
PART A: OVERVIEW...1 1. INTRODUCTION...1 2. APPLICABILITY...1 3. OBJECTIVE...1 PART B: LEGAL PROVISIONS...2 4. LEGAL PROVISIONS...2 PART C: POLICY...2 5. SCOPE OF ACTIVITIES THAT CAN BE OUTSOURCED...2
More informationRevised 05/22/14 P a g e 1
Corporate Office 107 W. Franklin Street P.O. Box 638 Elkhart, IN 46515-0638 Phone (574) 294-7511 Fax (574) 522-5213 INTRODUCTION PATRICK INDUSTRIES, INC. CODE OF ETHICS AND BUSINESS CONDUCT As a leader
More informationAudit Committee Forum
Audit Committee Forum TM Position Paper 11 Audit committee guidelines for evaluating whistleblowing channels TM The Audit Committee Forum is proudly sponsored by KPMG. Audit Committee Forum TM 1 Position
More informationStandards of. Conduct. Important Phone Number for Reporting Violations
Standards of Conduct It is the policy of Security Health Plan that all its business be conducted honestly, ethically, and with integrity. Security Health Plan s relationships with members, hospitals, clinics,
More informationMALAYSIAN TECHNOLOGY DEVELOPMENT CORPORATION SDN. BHD.
MALAYSIAN TECHNOLOGY DEVELOPMENT CORPORATION SDN. BHD. WHISTLEBLOWING POLICY AND GUIDELINES 16 March 2012 Version 1.0 TABLE OF CONTENTS WHISTLEBLOWING POLICY Page WHISTLEBLOWING GUIDELINES B1 DEFINITION
More informationCORPORATE GOVERNANCE
CORPORATE GOVERNANCE Ethics are vital to Brown Strauss, Inc. (Brown Strauss) and each of its and employees. Brown Strauss is committed to the highest ethical standards and to conducting its business with
More informationCalifornia Mutual Insurance Company Code of Business Conduct and Ethics
California Mutual Insurance Company Code of Business Conduct and Ethics This Code of Business Conduct and Ethics (the Code ) applies to all officers, employees, and directors of California Mutual Insurance
More informationBusiness Ethics Policy
Business Ethics Policy Page 1 of 12 Preface and document control This document is intended to provide information in respect of G4S Group Head Office policy, procedure, standards or guidance and will be
More informationWOLTERS KLUWER WHISTLEBLOWER POLICY. Version: April 2009
WOLTERS KLUWER WHISTLEBLOWER POLICY Contents 1 Introduction and summary 2 Type of behaviour that should be reported under this policy 3 Viewpoints on whistleblowing 3.1 Non-retaliation 3.2 Confidentiality
More informationCOMPUAGE INFOCOM LIMITED VIGIL MECHANISM / WHISTLE BLOWER POLICY
COMPUAGE INFOCOM LIMITED VIGIL MECHANISM / WHISTLE BLOWER POLICY PREAMBLE Section 177 (9) of the Companies Act, 2013 mandates the following classes of companies to constitute/establish a vigil mechanism
More informationIMAX CORPORATION PROTOCOL FOR REPORTING SUSPECTED VIOLATIONS OF THE IMAX CODE OF ETHICS. (Whistle Blower Program)
IMAX CORPORATION PROTOCOL FOR REPORTING SUSPECTED VIOLATIONS OF THE IMAX CODE OF ETHICS (Whistle Blower Program) November 2004 (updated February 2012) PROTOCOL FOR REPORTING SUSPECTED VIOLATIONS OF THE
More informationHeritage Foods Whistle Blower Policy. HERITAGE FOODS LIMITED (Formerly known as M/s. Heritage Foods (India) Limited) WHISTLE BLOWER POLICY
HERITAGE FOODS LIMITED (Formerly known as M/s. Heritage Foods (India) Limited) WHISTLE BLOWER POLICY 1 I. PREAMBLE This policy is formulated to provide an opportunity to employees and an avenue to raise
More informationSTATEMENT FROM THE CHAIRMAN
STATEMENT FROM THE CHAIRMAN In an ever-changing global marketplace, it is important for all of us to have an understanding of the responsibilities each of have in carrying out day-to-day business decisions
More informationCODE OF BUSINESS CONDUCT AND ETHICS
CODE OF BUSINESS CONDUCT AND ETHICS This Code of Business Conduct and Ethics covers a wide range of business practices and applies to all employees, officers, and directors and all majority-owned and controlled
More informationCODE OF CONDUCT. Providers, Suppliers and Contractors
CODE OF CONDUCT Providers, Suppliers and Contractors Table of Contents Code of Conduct... Honesty and integrity... Quality and Service... Responsibilities of Providers, Suppliers and Contractors... Compliance
More informationa. employees Company; or
Code of Busines ss Conduct and Ethics 1. Introduction a. This Code of Business Conduct and Ethics (the Code ) applies to all directors, officers, employees and third parties employed or directly engaged
More informationMinerals Technologies Inc. Summary of Policies on Business Conduct
Minerals Technologies Inc. Summary of Policies on Business Conduct Lawful and Ethical Behavior is Required at All Times This Summary of Policies on Business Conduct (this "Summary") provides an overview
More informationWHISTLE BLOWING POLICY & PROCEDURES
Management Circular No: GCSL/01.2013 Revised: 01/2014 WHISTLE BLOWING POLICY & PROCEDURES All rights reserved. No part contained in this Policy may be reproduced or copied in any form without the written
More informationFraud Waste and Abuse Training First Tier, Downstream and Related Entities. ONECare by Care1st Health Plan Arizona, Inc. (HMO) Revised: 10/2009
Fraud Waste and Abuse Training First Tier, Downstream and Related Entities ONECare by Care1st Health Plan Arizona, Inc. (HMO) Revised: 10/2009 Overview Purpose Care1st/ ONECare Compliance Program Definitions
More informationINTEGRITY & FRAUD RISK POLICY
INTEGRITY & FRAUD RISK POLICY A. Objectives The Lion Group is committed to achieve the following objectives in strengthening integrity within the Group : 1. Enhanced culture of integrity and professionalism
More informationE Distribution: GENERAL POLICY ISSUES. Agenda item 4 WFP ANTI-FRAUD AND ANTI-CORRUPTION POLICY. For approval
Executive Board Second Regular Session Rome, 8 11 November 2010 POLICY ISSUES Agenda item 4 For approval WFP ANTI-FRAUD AND ANTI-CORRUPTION POLICY E Distribution: GENERAL WFP/EB.2/2010/4-C/1 29 September
More informationWhistle Blowing Mechanism- A Move towards Better Corporate Governance
Global Journal of Management and Business Studies. ISSN 2248-9878 Volume 3, Number 8 (2013), pp. 855-860 Research India Publications http://www.ripublication.com/gjmbs.htm Whistle Blowing Mechanism- A
More informationCODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS
CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS Statement of Principle Our long-standing policy, as stated in our Pledge, is to maintain the highest standard of moral and ethical behavior in our relationships
More informationWHISTLE-BLOWER POLICY
WHISTLE-BLOWER POLICY WHISTLE-BLOWER POLICY Objective Motherson Sumi Systems Limited (MSSL) (hereinafter known as "the Company") is committed to conduct its business with highest standards of business
More informationVIDANT HEALTH POLICY & PROCEDURE. PREPARED BY: Office of Audit & Compliance REVISED: 11/09, 2/12 REVIEWED: 2/07, 2/08, 2/09, 3/10, 2/11
NUMBER: VH-AC 16 Page 1 of 9 EFFECTIVE: 01/2007 REVIEWED: 2/07, 2/08, 2/09, 3/10, 2/11 CEO APPROVAL: Topic: To Prevent and Detect Fraud and Abuse and Information regarding the Federal False Claims Act
More informationSM ENERGY COMPANY CODE OF BUSINESS CONDUCT AND CONFLICT OF INTEREST POLICY
SM ENERGY COMPANY CODE OF BUSINESS CONDUCT AND CONFLICT OF INTEREST POLICY We at SM Energy Company are committed to compliance with applicable laws, rules and regulations and to conducting our business
More informationNRG ENERGY, INC. SUPPLIER CODE OF CONDUCT. Revision 1, Released June 10, 2014
NRG ENERGY, INC. SUPPLIER CODE OF CONDUCT Revision 1, Released June 10, 2014 Ethics toll-free Helpline 888.263.0463-1 Table of Contents INTRODUCTION and MESSAGE FROM CEO 3 NRG STRIVE VALUES 4 ETHICS HELPLINE
More informationBARRICK GOLD CORPORATION
BARRICK GOLD CORPORATION Code of Business Conduct and Ethics Introduction Barrick s success is built on a foundation of personal and professional integrity and commitment to excellence. As a company and
More informationCORPORATE GOVERNANCE. Code of Business Conduct & Ethics
CORPORATE GOVERNANCE Ethics are vital to AZCON and its employees. AZCON is committed to the highest ethical standards and to conducting its business with the highest level of integrity. These values must
More informationCODE OF BUSINESS CONDUCT AND ETHICS
CODE OF BUSINESS CONDUCT AND ETHICS Wellgreen Platinum Ltd. Suite 1128-1090 West Georgia Street 604.569.3690 info@wellgreenplatinum.com CODE OF BUSINESS CONDUCT AND ETHICS I. INTRODUCTION This Code of
More informationWhistle Blower Policy
Whistle Blower Policy 1 Applicability This policy is applicable to: - All Employees, Business Associates, Contract Consultants (Retainers), Academic Interns and ACE Associates of Tata Consultancy Services.
More informationFraud Waste and Abuse Training First Tier, Downstream and Related Entities
Fraud Waste and Abuse Training First Tier, Downstream and Related Entities Revised: 04/2010 OVERVIEW Centene Corporation Purpose Bridgeway Compliance Program Definitions of Fraud Waste & Abuse Laws and
More informationCalifornia PUBLIC CONTRACT LAW
California PUBLIC CONTRACT LAW Book at a Glance CHAPTER 1 Basic Principles of Contract and Civil Law............. page 1 CHAPTER 2 Special Requirements Applicable to Public Contracts......... page 23 CHAPTER
More informationFraud Prevention Policy
FRAUD PREVENTION POLICY 1. Purpose 1.1. This policy sets out the general principles and minimum requirements for managing fraud risks across the Amcor Group and all its member and affiliated companies
More informationPUREPROFILE LTD. ACN 167 522 901 CONTINUOUS DISCLOSURE AND COMMUNICATION POLICY
PUREPROFILE LTD. ACN 167 522 901 CONTINUOUS DISCLOSURE AND COMMUNICATION POLICY Contents 1 Overview 3 2 Continuous Disclosure Requirements and Procedures 3 3 Disclosure Responsibilities 4 4 Potentially
More informationThe best advice before you decide on what action to take is to seek the advice of one of the specialist Whistleblowing teams.
Whistleblowing Policy (HR Schools) 1.0 Introduction Wainscott school is committed to tackling unlawful acts including fraud, corruption, unethical conduct and malpractice regardless of who commits them,
More informationFor special fraud investigations the Audit Committee has the authority to:
Prepared Document Number: Anders Haker CORP-07:009 Approved Security Class Date Revision Document Type Board of Directors Public 2007-09-12 C Policy FRAUD REPORTING AND INVESTIGATION ( WHISTLE BLOWER )
More informationTHE PRACTICE OF INSOLVENCY. A Guide to Professional Conduct and Ethics. Guide to Professional Conduct and Ethics LIST OF CONTENTS: Preface
THE PRACTICE OF INSOLVENCY A Guide to Professional Conduct and Ethics LIST OF CONTENTS: Preface 1 Introduction Insolvency Ethical Principles (1) Integrity (2) Objectivity (3) Competence (4) Due Skill (5)
More informationWhistle Blower Policy
OBJECTIVE Whistle Blower Policy This policy seeks the support of RBNL employees, channel partners and vendors to report Significant deviations from key management policies and report any non-compliance
More informationUNIVERSITY OF MARYLAND WHISTLEBLOWER POLICY ON REPORTING FISCAL IRREGULARITIES, ILLEGAL ACTIVITY, AND VIOLATIONS OF POLICY
UNIVERSITY OF MARYLAND WHISTLEBLOWER POLICY ON REPORTING FISCAL IRREGULARITIES, ILLEGAL ACTIVITY, AND VIOLATIONS OF POLICY UM Policy VIII-7.11(B) Effective Date: June 1, 2011 I. Purpose and Scope of Policy
More informationWhistle Blower Policy
I. PREAMBLE This afresh policy is formulated to establish a vigil mechanism and to provide an opportunity to Director(s)/employee(s) and an avenue to raise concerns and to access in good faith the Chairman
More informationDisciplinary Policy and Procedure
Disciplinary Policy and Procedure Policy 1. Purpose of the policy and procedure Disciplinary rules are important for the running of the University so that everyone understands what is expected of them
More informationHORIZON OIL LIMITED (ABN: 51 009 799 455)
HORIZON OIL LIMITED (ABN: 51 009 799 455) CORPORATE CODE OF CONDUCT Corporate code of conduct Page 1 of 7 1 Introduction This is the corporate code of conduct ( Code ) for Horizon Oil Limited ( Horizon
More informationFalse Claims Act NUMBER NH-LD-CP-220 Last Revised/Reviewed TITLE. Apr13. LD, CP Corporate Wide TJC FUNCTIONS APPLIES TO I.
ADMINISTRATIVE TITLE False Claims Act NUMBER NH-LD-CP-220 Last Revised/Reviewed Effective Date: TJC FUNCTIONS APPLIES TO LD, CP Corporate Wide Apr13 I. SCOPE / PURPOSE It is the policy of Novant Health
More informationFraud, Waste & Abuse Policy
Fraud, Waste & Abuse Policy Issue Date: Policy approved by the Board of Directors on February, 18, 2015 The Independence Center (The IC) is committed to the responsible stewardship of our resources, and
More informationPro-iii Insurance Innovators Inc. Po Box 969, 130 S. Easton Rd. Glenside, PA 19038 P-215-885-7300 F-215-886-2482 Email: Sam@iiigroup.
ADMIRAL INSURANCE COMPANY 1255 Caldwell Road Cherry Hill, NJ 08034 Phone: 856-429-9200 Fax: 856-429-8611 Internet: http://www.admiralins.com Pro-iii Insurance Innovators Inc. Po Box 969, 130 S. Easton
More informationCROCS, INC. Business Code of Conduct and Ethics Amended and Restated on February 18, 2008
CROCS, INC. Business Code of Conduct and Ethics Amended and Restated on February 18, 2008 Introduction This Code of Business Conduct and Ethics (this Code ) contains general guidelines for conducting the
More informationFERRARI N.V. AUDIT COMMITTEE CHARTER (Effective as of January 3, 2016)
FERRARI N.V. AUDIT COMMITTEE CHARTER (Effective as of January 3, 2016) For so long as shares of Ferrari N.V. (the Company ) are listed on the New York Stock Exchange ( NYSE ) and the rules of the NYSE
More informationHow To Write A Prison Service Plan
ISLE OF MAN PRISON SERVICE CODE OF CONDUCT AND DISCIPLINE Isle of Man Prison Service Code of Conduct and Discipline Contents Statement of Purpose and Values Purpose Prison Service Objectives Values Definition
More informationNETGEAR, INC. CODE OF BUSINESS ETHICS AND CONFLICT OF INTEREST POLICY FOR DIRECTORS, OFFICERS AND KEY EMPLOYEES
NETGEAR, INC. CODE OF BUSINESS ETHICS AND CONFLICT OF INTEREST POLICY FOR DIRECTORS, OFFICERS AND KEY EMPLOYEES I. INTRODUCTION This Code of Ethics and Conflict of Interest Policy (collectively, the Code
More informationMEAD JOHNSON NUTRITION COMPANY CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS
MEAD JOHNSON NUTRITION COMPANY CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS Statement of Principle Our policy is to maintain the highest standard of moral and ethical behavior in our relationships with
More informationEADS-NA Code of Ethics
Page: 1 of 7 EADS-NA Code of Ethics Introduction The Company demands high ethical standards of conduct from its directors, employees, and agents and will conduct its business with honesty, integrity, and
More informationStates of Jersey Human Resources Department. Code of Conduct
States of Jersey Human Resources Department Code of Conduct INTRODUCTION The Island community is entitled to expect the highest standards of conduct from all employees who work for the States of Jersey.
More informationMeeting Audit Committee Date 08/09/2014. Agenda item 7 Time 10 Minutes. Yes publication Reporting of fraud, whistleblowing and security incidents
Meeting Audit Committee Date 08/09/2014 Agenda item 7 Time 10 Minutes Proactive publication Title Presenter ICO Plan aim Information rights strategy aim Issue Decision Yes Internal publication Yes Reporting
More informationDestiny Media Technology s Code of Conduct
Destiny Media Technology s Code of Conduct INTRODUCTION Destiny Media Technology s ( Destiny ) reputation depends on the conduct of its employees, officers and directors who have an obligation to Destiny
More informationRisk Management Policy
Risk Management Policy PURPOSE: NEW/REVISED POLICY: The California State Student Association maintains a Risk Management Policy to ensure the ongoing identification of potential risks and threats to the
More informationBusiness Ethics Policy
BUSINESS ETHICS POLICY Table of Content Page Content 1 Message from the Chief Executive Officer 2 Business Integrity 3 No Improper Advantage 4 Disclosure of Information 4 Intellectual Property 5 Fair Business,
More informationFraud Prevention DEFINITIONS
AD 19 Fraud Prevention Classification: Responsible Authority: Director, Finance and Administrative Services Executive Sponsor: Approval Authority: President s Council Date First Approved: NEW Date Last
More informationCIVEO CORPORATION CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS. Effective as of May 5, 2014
CIVEO CORPORATION CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS Effective as of May 5, 2014 Purpose This Corporate Code of Business Conduct and Ethics (this Code ) contains the policies that relate to
More informationNational Aluminium Company Ltd Fraud Prevention Policy
National Aluminium Company Ltd Fraud Prevention Policy 1. BACKGROUND: Over the years NALCO has implemented various policies and procedures, systems to guide NALCO employees within and outside the organization
More informationHyatt Hotels Corporation. Code of Business Conduct and Ethics
INTRODUCTION This (this Code ) is designed to reaffirm and promote Hyatt Hotels Corporation s compliance with laws and ethical standards applicable in all jurisdictions in which Hyatt Hotels Corporation
More informationTITLE: Fraud Prevention and Detection Program IDENTIFIER: S-FW-LD-1008 APPROVED: Executive Cabinet (Pending)
PAGE 1 of 5 TITLE: Fraud Prevention and Detection Program IDENTIFIER: S-FW-LD-1008 APPROVED: Executive Cabinet (Pending) ORIGINAL: 11/03 REVISED: 10/07, 09/10, 04/13 REVIEWED: EFFECTIVE DATE Acute Care
More information3 For the Year Ended December 31, 2013
Report of the Auditor General of the Ville de Montréal to the City Council and to the Urban Agglomeration Council 3 For the Year Ended December 31, 2013 Investigative and Forensic Accounting Report 3.
More information