How many of us have a policy about fraud, outlining prevention and discussing detection?
Here's an example of a policy statement that prevents or at least seems to prevent fraud:
"Accepting or seeking anything of material value from contractors, vendors, or persons providing services/materials to the Company. Exception: Gifts less than $50 in value."
Detection by others (besides self reporting) would be built into a whistleblower policy.
Do you have something like this?
Most companies that I've worked with had a gift policy which included similar language (often also indicating that the giving or receiving of gifts should be around some occasion - wedding, birth of child, birthday, etc) and that the value of cumulative gifts also be reported (i.e., getting a $40 gift card from a supplier every week for a year would obviously be a violation of said policy using a substance over form argument).
These policies are also written to comply with FCPA (and so would indicate a zero gift policy to elected officials, etc).
the policy of my company is worded as " we may only offer business courtesies that are lawful, appropriate and in accordance with reasonable business customs, unsolicited, not in the form of cash or a cash equivalent". We prohibit giving anything in the hopes of influencing someone's decision (including grease payments). There is no dollar amount attached.
The telecommunications industry was hit with fraud pretty heavily this year and as a result we put quite a few new measures into practice to help. We saw immediate benefits from it. I think it's probably one of those areas we don't spend enough time on.
