Advisory Forensic Services. Economic Crime in a Downturn Global Economic Crime Survey Hungarian Country Report 2009
|
|
- Luke Townsend
- 6 years ago
- Views:
Transcription
1 Advisory Forensic Services Economic Crime in a Downturn Global Economic Crime Survey Hungarian Country Report 200
2 Introduction We are pleased to present the 200 PricewaterhouseCoopers Global Economic Crime Survey results the largest study of its kind now available worldwide. In our fifth survey, we interviewed senior representatives of more than 3,000 companies in 54 countries, including 53 leading companies within Hungary, providing us with unparalleled depth of insight into perceptions, awareness and the impact of economic crime on business around the world. We believe that the results of our survey will help business leaders to understand and confront the issues around economic crime. Our aim was: to assess corporate attitudes to fraud in the current economic environment; to understand in particular if fraud has increased as a result of the economic downturn; and to find out: - which types of fraud are the most prevalent; - who are the perpetrators of fraud; - what are the costs to business; and - what steps companies are actually taking to detect and prevent fraud. Our survey indicates that the number of incidences of fraud uncovered has increased in Hungary at a much greater rate in the past 12 months than in the wider Central and Easter European ( CEE ) region with % of companies who suffered indicating an increase (compared to 48% in CEE). In addition, the cost of fraud to a company is also reported by the majority of companies who have suffered as increasing and the impact on employees and morale was judged to be more significant in Hungary than in other countries in the region. A large proportion of fraud is still detected by chance rather than internal controls or other systems. In our previous surveys, Asset Misappropriation has always been the most prevalent type of economic crime suffered, until this year, respondents endured more Bribery and Corruption than any other economic crime. Whether this is due to economic pressures is unclear. What is reported is that the global economic downturn has significantly affected most organisations, with 2% of respondents reporting a decline in financial performance over the past 12 months. Furthermore, the current economic climate has affected individuals views on fraud risks with 38% of respondents reporting that, they believe that their organisation faces a greater risk of economic crime at present. We also discovered that the nature of fraud has changed as a result of increased economic pressure, namely the need to achieve high targets or financial performance and/or the fear of losing jobs. Half of respondents who commented on this area state that staff reductions have resulted in fewer resources deployed on internal controls whilst two thirds suggested management is focussing on the survival of the business and less on fraud. Companies need to consider how to balance the need to meet profit targets and the consequences of excessive pressure on employees, as well as how to adjust control systems to ensure their effectiveness. The survey indicates there appears to be a serious mindset issue in Hungarian companies, 8% of respondents who commented report that people are prone to committing fraud when they believe others do it as well. This stresses the need for strong corporate communication and a very clear tone from the top that is also followed by decisive action when fraud is identified. Last but not least, over two thirds of frauds uncovered were committed by an organisation s own staff, this compares to 3% in the wider CEE and 53% globally. We are very grateful to all respondents and organisations who have participated in the survey, and without which we would not have been able to produce this report. We hope that this information will further assist the readers in their ongoing fight against economic crime. David Wake, Partner Miklós Fekete, Partner Lee Coles, Director Forensic Services PricewaterhouseCoopers Hungary
3 Key findings Economic crime continues to be a serious issue affecting organisations in Hungary and worldwide, 30% of companies in Hungary experienced one or more economic crimes in the past 12 months; compared to CEE (34%) and globally (30%). With 25% of the victims of fraud in Hungary having had more than 10 incidents. Fear of losing their jobs (43%) and a belief that competitors were paying bribes to win contracts (43%, compared to 30% in the CEE as a whole) increased the pressure on companies to commit fraud in Hungary in the current economic climate. A belief that others do it so it is OK is also a common way to rationalise fraud in Hungary (8%) and in CEE (58%) compared to the global level (35%). Asset misappropriation is no longer the most common type of economic crime reported in Hungary, replaced by Bribery and Corruption (81%), this exceeds both the CEE and global averages of 44% and 27% respectively and shows a huge increase on our 2007 survey where 17% reported they had suffered from this form of economic crime. In prior surveys we had commented on the fact that the belief of respondents was that Bribery and Corruption was the most prevalent economic crime, but it was not actually the crime most experienced. However, as the survey shows, that is no longer the case. An increase in the cost of fraud over the last 12 months was reported by 3% of companies who had suffered an economic crime in Hungary. 5% of respondents highlighted employee morale as the most significant indirect cost of economic crime in the last 12 months whilst 50% indicated that there had been a significant impact on business relations after suffering an economic crime. This compares to the CEE average of 23%. % of companies lost over USD 1 million as a result of fraud with 25% losing over USD 500,000. The main threat of economic crime in the last 12 months came internally from employees (%). Middle Management in Hungary is reported as perpetrating 4% of internal frauds, which is in line with CEE (47%) and globally (42%). In the case of internal perpetrators, dismissal was the most frequent action taken in Hungary, in 1% of cases. External parties to the company played a role in % of fraud cases in Hungary which involved agents/intermediaries (40%) and customers (0%) being the perpetrators. 38% of the incidents of economic crime detected were by accident, or by means that were beyond the influence of management, namely a combination of internal/external tip-offs other than the formal whistle-blowing mechanism. 85% of respondents surveyed mentioned that they had not changed the frequency of conducting fraud risk assessment compared to 12 months ago. In addition, 43% of companies in Hungary had not performed any fraud risk assessment in the last 12 months. Economic downturn and the risk of fraud The global economic downturn has significantly affected most organisations, with 2% of respondents reporting a decline in financial performance over the past 12 months. Furthermore, the current economic climate has affected the individual s views on fraud risks globally, with 38% of respondents reporting that they believe that their organisations face a greater risk of economic crime at present. What drives fraud in times of crisis? Fraud practitioners often point to three factors that are commonly found when fraud occurs (the Fraud Triangle - Figure 1). Figure 1 Incentive or Pressure 30% FRAUD RISK 35% 35% Opportunity Attitude / Rationalisation First, perpetrators of fraud need an incentive or pressure to engage in misconduct. Second, there needs to be an opportunity to commit fraud, and third, perpetrators are often able to rationalise or justify their actions. Our survey probed deeper into the impact of these three factors and found that amongst the respondents who believed that there is a greater risk of fraud in the current economic environment one of the three factors of the fraud triangle was the most likely reason for the greater risk of fraud. PricewaterhouseCoopers 1
4 Figure 2 People are afraid they might lose their jobs People want to make the numbers in order to earn performance bonuses There is a belief that competitors are paying bribes to win contracts Global CEE Hungary Reasons for increasing pressures and incentives to commit fraud Targets more difficult to achieve Bonuses not paid this year The responses were markedly different in Hungary compared to CEE and globally. Respondents perceive themselves as far less likely to commit due to incentives or pressures and much more likely to do so because they can rationalise committing the economic crime. And what contributes to this higher level of rationalisation? 8% reported that others do it and so it is OK. The maintenance of the existing standard of living was the next highest perceived pressure at 57%. When we asked companies to categorize what, if anything, has contributed to increasing pressures and incentives to commit fraud in the current economic environment, in Hungary, CEE and globally, trying to achieve difficult targets was the key reason provided (57% in Hungary), whilst 43% of respondents highlighted job security as a key consideration. (Figure 2) Interestingly in Hungary 43% believed that competitors were paying bribes to win contracts, compared to % globally and 30% in the wider CEE. Moreover, 83% of respondents surveyed highlighted at least one of three key issues that contributed to greater opportunities of the risk of fraud: staff reductions have resulted in fewer resources deployed in internal controls; management focusing on the survival of the business; and internal audit being asked to do too much. Economic downturn has increased the risk of fraud Economic crime takes on many different forms, some more common than others, but all can be equally damaging if they occur. Asset misappropriation has always been the most common form of economic crime reported in Hungary but no longer, with respondents in 200 identifying they suffered from Bribery and Corruption more than anything else. (Figure 3) Figure 3 IP infringement, including theft of data Bribery and corruption Asset misappropriation Financial statement fraud- Accounting manipulations Money laundering Tax fraud % of respondents Types of Economic Crimes In some ways this could be viewed as a positive trend that means that companies in Hungary are identifying more incidents in an area that is typically difficult to detect. However the sheer weight of numbers indicates this could be a wider business culture problem where such activities can be viewed as a necessary evil because as the survey suggests, others (including competitors) do it as well (or at least are perceived to). Of those that reported economic crime in the last year in Hungary, % suffered some form of financial statement or accounting fraud. This is a dramatic increase on prior years (% in 2007). Fraudulent borrowing/raising of finance and credit are the two reasons provided for financial statement fraud in Hungary. The significant increase in this type of fraud could be linked to the current economic climate and a combination of a weaker control environment due to staff reductions and the increasing pressure placed upon management to meet targets. Asset Misappropriation remains a significant problem with 3% of respondents identifying it as an area where they have been a victim. The prevalence of this type of fraud is not surprising, as it is among the easiest to detect; it involves the taking of items with % of respondents Global Economic Crime Survey November 200
5 Figure 4 Monthly Quarterly Every months Once Not at all Global CEE Hungary a defined value and provides a clear indication of where management should concentrate its immediate attention in order to avoid losses. Prevention, detection and response are key Of the total respondents for Hungary, 30% reported that they had suffered economic crime in the past 12 months. Whilst it cannot be proven, it is extremely likely that further fraud remains undetected. Fraud risk assessments are a critical tool in identifying potential fraud threats and in controlling weaknesses that can create opportunities to commit fraud. However, Hungary reported that 43% of respondents had not performed a fraud risk assessment in the past year and a further 3% had only performed it once. (Figure 4) 85% indicated the frequency of performing fraud risk assessments remained unchanged from the past. Global results have shown a clear correlation between the frequency of fraud risk assessments and the number of detected frauds. Are organisations detecting fraud effectively? Our survey statistics show that 1% of the frauds reported were detected by internal audits. Frequency of conducting fraud risk assessment As such, it can be extrapolated that if there were no reductions in internal control staff levels, more frauds could have been detected. % of reported frauds were detected through risk management measures, including preventive fraud risk assessments. 38% of all frauds detected were via means that were beyond the influence of management, namely a combination of internal/external tip-offs other than the formal whistle-blowing mechanism, or by accident. This compares to CEE (32%) and globally (32%), which suggests that companies in Hungary may rely too heavily on chance. (Figure 5) Interestingly globally, 7% of frauds were detected through formal whistle-blowing procedures. Hungarian responses indicate 0% was detected in this way. This may suggest either the ineffectiveness or the absence of such procedures, which could be Figure 5 43 Risk management, including preventive fraud risk management How was the fraud detected? By accident Corporate security External audit Internal audit Change of personnel/duties Activity/investigation by law enforcement agencies /regulatory authority External tip-off through means other than the formal whistle blowing mechanism Internal tip-off through means other than the formal whistle blowing mechanism due to a lack of support within organisations, insufficient publicity and/or leadership not being seen to take whistle-blowing seriously or perhaps cultural or historical issues with such mechanisms which a company needs to consider and address. Do organisations have the right tone at the top? Employee morale was reported to be the area of greatest impact on economic crime, with 5% of those experiencing economic crime reporting its effect to be significant on morale. This is much higher than the CEE figure of %. 50% also said that the economic crime committed against them had significantly damaged business relations with others whilst 25% indicated the company brand had been significantly impacted upon. Our survey indicates that in % of cases respondents took criminal or civil action against external perpetrators, which is lower than the CEE average (%). (Figure ) With respect to internal perpetrators (Figure 7), 1% of companies in Hungary claimed they dismissed the perpetrator whilst 27% brought civil actions and/or criminal charges against % of frauds PricewaterhouseCoopers 3
6 him/her. This compares to the CEE figure of 4% and a global average of 48%. It should be noted that this survey does not differentiate from those employees removed through dismissal and those which may be removed through other actions such as mutual agreement or an accepted resignation. In terms of deterrent, the latter two options make a much weaker statement when it comes to the perception of how fraudsters are dealt with by an organisation. We are pleased to note that all organisations reported that they took at least some action against internal perpetrators although % indicated external perpetrators suffered no follow up action. Only 7% of respondents consider measures adopted by the regulatory framework to prevent fraud to be effective. fraudsters, and 5% across CEE. No questions relating to age or sex of perpetrators were asked. The only perpetrators of external fraud reported in Hungary were customers (0%) and agents/ intermediaries (40%). Figure No action Notify relevant regulatory authorities Cessation of the business relationship Civil action/criminal charges were brought Global Central & Eastern Europe Hungary Which action was taken against external perpetrators? Moreover, % of fraud discussed in our survey was actually detected by an action from authorities. At the same time, 2% of victims of fraud admitted that the fraud had no significant impact at all on their relations with regulators. Figure 7 No action Notify relevant regulatory authorities Civil action/criminal charges were brought Which action was taken against internal perpetrators? Dismissal Profile of the internal fraudsters Transfer 4 4 In 4% of cases, the respondents identified that the perpetrator had been a member of middle management; and % were senior management, a combined total of 4%. In comparison to our 2007 Hungary survey this shows a worrying increase as previously respondents indicated 27% of Senior and 20% of Middle Management were involved (a combined total of 47%) (Figure 8). Warning/reprimand Global Central & Eastern Europe Hungary Figure 8 Senior management Middle management Profile of the internal fraudsters Globally our 200 results showed middle and Senior Management comprised 5% of the profile of Others Global Economic Crime Survey November 200
7 Fraud in the Future % of respondents who reported fraud believed that there had been an increase in the level of economic crime compared to 12 months ago. However, since fraud is not a static threat, organisations need continually to assess their fraud risks. Despite the figures in this survey, the overwhelming majority of companies in Hungary still think it unlikely that their organisation will be subject to economic crime in the next 12 months, particularly financial statements fraud only 11%, asset misappropriation 25% and/or corruption and bribery 33% think it likely or very likely they will fall victim to these economic crimes. It should be noted that the corruption and bribery perception is higher than that in CEE (28%) and significantly higher than the global perception (1%). (Figure ) Figure Figure 10 Detection Bribery and corruption Asset misappropriation Accounting manipulations Prevention n Effective fective fraud combat perception 200 perception 200 reality Perception vs. Reality 21 Response % of the companies 3 81 In our experience global procedures can themselves be effective in detecting and, over a period of time, deterring fraudsters, our research and experience also shows that it is the culture of a company one that supports a compliance programme working in conjunction with a clearlyunderstood, and lived, code of ethics that is the true foundation for an effective anti-fraud programme. PricewaterhouseCoopers 5
8 Contacts David Wake Partner, Advisory Tel.: david.wake@hu.pwc.com Miklós Fekete Partner, Advisory Tel.: miklos.fekete@hu.pwc.com Lee Coles Director, Forensic Services Tel.: lee.x.coles@hu.pwc.com Zoltán Pintér Manager, Forensic Services Tel.: zoltan.pinter@hu.pwc.com The 200 Global Economic Survey can downloaded from the following link: PricewaterhouseCoopers provides industry-focused assurance, tax and advisory services to build public trust and enhance value for our clients and their stakeholders. More than,000 people in 151 countries across our network share their thinking, experience and solutions to develop fresh perspectives and practical advice. 200 PricewaterhouseCoopers LLP. All rights reserved. PricewaterhouseCoopers refers to PricewaterhouseCoopers LLP (a limited liability partnership in the United Kingdom) or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity.
Economic crime in a downturn
Economic crime in a downturn The Economic Crime Survey November 2009 PwC Introduction Our 2009 survey addresses economic crime and its associated integrity risks, in a time when most, if not all territories,
More informationThe Global Economic Crime Survey Cybercrime: are you at risk?
www.pwc.com/crimesurvey The Global Economic Crime Survey Cybercrime: are you at risk? Hungarian country report December 2011 Table of contents 1) Introduction 3 2) Executive Summary Key findings 4 3) Fraud,
More informationUnderestimated threats?
http://www.pwc.com/hu/en/crimesurvey Underestimated threats? Global and Hungarian Economic Crime Survey 201 % The most common type of economic crime in Hungary is asset misappropriation. 17% Less than
More informationRussia The Global Economic Crime Survey Cybercrime in the spotlight
www.pwc.ru/en/crimesurvey Russia The Global Economic Crime Survey Cybercrime in the spotlight With almost 4000 responses from senior executives in 72 countries, this is the most comprehensive global survey
More informationEconomic crime: people, culture & controls. The 4th biennial Global Economic Crime Survey Chemicals industry
Economic crime: people, culture & controls The 4th biennial Global Economic Crime Survey Chemicals industry 2 Economic crime: people, culture & controls The 4th biennial Global Economic Crime Survey Chemicals
More informationglobal economic crime survey 2005
global economic crime survey 25 India Economic Crime in India: an ever increasing phenomenon Introduction With a coverage of 334 respondents in 34 countries, the PricewaterhouseCoopers Global Economic
More informationCybercrime in the spotlight
www.pwc.co.za/crimesurvey Cybercrime in the spotlight 6th PwC Global Economic Crime Survey n Edition November 2011 The PwC Global Economic Crime Survey remains the most comprehensive survey of its kind
More informationGlobal Economic Crime Survey Italian Addendum 2016
Global Economic Crime Survey Italian Addendum 2016 www.pwc.com/it 2016: Economic crime evolution PwC's Economic Crime Survey 2016 shows a significant awareness of companies on issues relating to economic
More informationGlobal Economic Crime Survey 2014
www.pwc.com/sk/forensic-services Global Economic Crime Survey 2014 Economic Crime is on the rise Report for Slovakia Evolution of Fraud Dangers of Crime Cybercrime Procurement Fraud Corruption and Bribery
More informationAnti-Fraud, Bribery and Corruption Policy
Anti-Fraud, Bribery and Corruption Policy Anti-Fraud, Bribery and Corruption Policy Version 2 Approved by: Audit and Risk Committee Approved date: 22 May 2017 1.0 Introduction 1.1 Optivo is committed to
More informationProtecting Your Company's Value: Study of fraud trends and creating an action plan
Protecting Your Company's Value: Study of fraud trends and creating an action plan April 11, 2017. Presenters: Brian Miller, CPA, CFE Grant Thornton LLP. All rights reserved. Presenting today: Brian Miller
More informationProfile of a Fraudster:
Profile of a Fraudster: The picture in Central and Eastern Europe June 2016 kpmg.com/cee KPMG in Central and Eastern Europe KPMG recently released profiles of the fraudster 1, which contains observations
More informationREPORT TO THE NATIONS
REPORT TO THE NATIONS 2018 GLOBAL STUDY ON OCCUPATIONAL FRAUD AND ABUSE E AST ER N E UR O PE AN D WE ST E R N/ C E N T R AL AS I A E DI T I O N REPORT TO THE NATIONS 2018 GLOBAL STUDY ON OCCUPATIONAL FRAUD
More informationEconomic Crime in the Arab World
PwC Middle East Economic Crime Survey February 2014 Economic Crime in the Arab World 21% One in five Middle East organisations report being the victim of economic crime 5% Only 5% of frauds were detected
More informationThe offering, giving, soliciting or acceptance of an inducement or reward which may influence the action of any person.
Anti-Bribery Policy Responsible Officer Director of Finance 1.0 WHAT IS BRIBERY Bribery can be defined as: The offer or receipt of any gift, loan, payment, reward or other advantage to or from any person
More informationGroup Business Integrity Policy
Group Business Integrity Introduction Regrettably, bribery and corruption is a feature of corporate and public life in many countries across the world. Even the suggestion of corruption may damage the
More informationSTATEMENT OF PRINCIPLES
THE BERMUDA MONETARY AUTHORITY THE PROCEEDS OF CRIME (ANTI-MONEY LAUNDERING AND ANTI-TERRORIST FINANCING SUPERVISION AND ENFORCEMENT) ACT 2008 October 2010 Content 1. Introduction Page 3 2. Enforcement
More informationCCG CO06: Anti-Fraud, Bribery and Corruption Policy
Corporate CCG CO06: Anti-Fraud, Bribery and Corruption Policy Version Number Date Issued Review Date V2 17/03/2016 01/09/2016 Prepared By: Consultation Process: Formally Approved: Policy Adopted From:
More informationI. STATEMENT OF COMMITMENT AGAINST CORRUPTION, BRIBERY & EXTORTION
CITY DEVELOPMENTS LIMITED ANTI-CORRUPTION POLICY & GUIDELINES* (*All employees of CDL are required to read the full version of the CDL Anti-Corruption Policy & Guidelines, which is available on CDL s intranet,
More informationUnder attack: are organisations doing enough to tackle the cyber threat?
PwC Global Economic Crime Survey 2016 mainland China, Hong Kong and Macau Supplement Under attack: are organisations doing enough to tackle the cyber threat? www.pwchk.com www.pwccn.com Contents 1 Foreword
More informationFirstRand anti-bribery policy
FirstRand anti-bribery policy - 1 - table of contents 1. DEFINITIONS 3 2. POLICY CONTEXT 4 2.1 Ensuring integrity in all business dealings 4 2.2 What is bribery? 4 2.3 Purpose of the policy? 5 2.4 How
More informationThe Institute of Company Secretaries of India Northern India Regional Council Seminar on. Dr. Sanjeev Gemawat
The Institute of Company Secretaries of India Northern India Regional Council Seminar on Fraud Risk & Governance: Professionals Responsibility & Liability Dr. Sanjeev Gemawat PHD House, New Delhi Saturday,
More informationCorporate Governance Statement
Corporate Governance Statement INTRODUCTION The board of directors (the Board ) of Driver Group PLC (the Company ) recognises the importance of good corporate governance and has elected to adopt the QCA
More informationNETCARE LIMITED CORPORATE GOVERNANCE ANTI-CORRUPTION POLICY POLICY NUMBER COR12 CORPORATE GOVERNANCE PREPARED BY PREPARATION DATE JUNE 2014
NETCARE LIMITED CORPORATE GOVERNANCE POLICY POLICY NUMBER COR12 PREPARED BY APPROVED BY CORPORATE GOVERNANCE CORPORATE GOVERNANCE PREPARATION DATE JUNE 2014 ISSUE DATE FEBRUARY 2017 REVISION DATE FEBRUARY
More informationAnti-Fraud, Bribery and Corruption Response Policy. Telford and Wrekin Clinical Commissioning Group
Anti-Fraud, Bribery and Corruption Response Policy 2018 Telford and Wrekin Clinical Commissioning Group The Anti-Fraud, Bribery and Corruption Policy for Telford and Wrekin Clinical Commissioning Group
More informationFraud and Corruption Prevention Policy
Fraud and Corruption Prevention Policy Version Approved by Approval date Effective date Next review 2.3 Director of Governance 15 January 2018 15 January 2018 January 2016 Policy Statement Purpose Scope
More informationUACN WHISTLEBLOWING POLICY
UACN WHISTLEBLOWING POLICY JULY 2015 VERSION 2.0 Document approval This document was approved by the Board of UAC of Nigeria PLC on 29 th July 2015 2 Table of Contents 1. Policy Statement..... 4 2. Application.....
More informationBoard and Committees Terms of Reference
Board and Committees Terms of Reference December 2015 National Friendly Page 1 CONTENT Introduction Definitions & Abbreviations Terms of Reference for: The Board Audit Committee Investment Committee Nomination
More informationNORTHERN IRELAND PRACTICE AND EDUCATION COUNCIL FOR NURSING AND MIDWIFERY
NIPEC/12/12 NORTHERN IRELAND PRACTICE AND EDUCATION COUNCIL FOR NURSING AND MIDWIFERY Anti-Bribery Policy May 2012 Review date: April 2015 Centre House 79 Chichester Street BELFAST BT1 4JE Tel: (028) 9023
More informationFebruary 2017 THE ACCOUNTANCY PROFESSION PLAYING A POSITIVE ROLE IN TACKLING CORRUPTION
February 2017 THE ACCOUNTANCY PROFESSION PLAYING A POSITIVE ROLE IN TACKLING CORRUPTION Exposure Drafts, Consultation Papers, and other IFAC publications are published by, and copyright of, IFAC. IFAC
More informationAnti-Fraud, Bribery and Corruption Policy and Response Plan
Anti-Fraud, Bribery and Corruption Policy and Response Plan Ref: Finance 2.1 Version: 3.0 Supersedes: Author (inc Job Title): Ratified by: (Name of responsible Committee) 2.1 Anti-Bribery Policy and Procedure
More informationANTI-BRIBERY & CORRUPTION POLICY
GABRIEL RESOURCES LIMITED ANTI-BRIBERY & CORRUPTION POLICY 1 INTRODUCTION 1.1 The Board of Directors of Gabriel Resources Ltd. 1 (the Company or "Gabriel") has determined that, on the recommendation of
More informationThe 2017 TRACE Matrix Bribery Risk Matrix
The 2017 TRACE Matrix Bribery Risk Matrix Methodology Report Corruption is notoriously difficult to measure. Even defining it can be a challenge, beyond the standard formula of using public position for
More informationLEGAL REVIEW: ANTI-CORRUPTION TOOLS IN SOUTH AFRICA
LEGAL REVIEW: ANTI-CORRUPTION TOOLS IN SOUTH AFRICA Presented at the Black Management Forum Conference, October 2012 Why should we care? Because corruption kills. Misappropriation of public funds steal
More informationCounter-fraud and anti-bribery policy
Counter-fraud and anti-bribery policy Responsible Officer Author Ben Bennett, Business Planning & Resources Director Corporate Office Date effective from May 2012 Date last amended November 2016 Review
More informationWhistle-Blowing Policy and Procedure Manual
Whistle-Blowing Policy and Procedure Manual TABLE OF CONTENTS 1. EXPLANATORY FORWARD 2 2. POLICY STATEMENT 3 3. OBJECTIVES OF THE POLICY 3 4. SCOPE OF THE POLICY 4 5. COMMITMENT TO THE POLICY 5 6. PROCEDURE
More informationForeign bribery Views from the coal-face. March 2016 Publication No
Foreign bribery Views from the coal-face March 2016 Publication. 16-02 1 Background In August 2015, KordaMentha made a submission to the Senate References Committee inquiry 1 into foreign bribery. Our
More informationANGLOGOLD ASHANTI LIMITED Registration No. 1944/017354/06 ( AGA or the Company ) AUDIT AND RISK COMMITTEE TERMS OF REFERENCE
ANGLOGOLD ASHANTI LIMITED Registration No. 1944/017354/06 ( AGA or the Company ) AUDIT AND RISK COMMITTEE TERMS OF REFERENCE APPROVED BY THE BOARD OF DIRECTORS ON 16 FEBRUARY 2018 1. INTRODUCTION AND PURPOSE
More informationFutures & Options Association Bribery Act Checklist
Futures & Options Association Bribery Act Checklist Berwin Leighton Paisner LLP Adelaide House London Bridge London EC4R 9HA Tel: +44 (0)20 3400 1000 Fax: +44 (0)20 3400 1111 Contents Clause Name Page
More informationTHE INTERNATIONAL IMPACT OF FRAUD THE UK BRIBERY ACT RAISING THE BAR ABOVE THE FOREIGN CORRUPT PRACTICES ACT
THE INTERNATIONAL IMPACT OF FRAUD THE UK BRIBERY ACT RAISING THE BAR ABOVE THE FOREIGN CORRUPT PRACTICES ACT The UK Bribery Act has an effective date of April 2011. Prior to this act, the U.S. Foreign
More informationSerco Group plc (the Company )
Serco Group plc (the Company ) Audit Committee Terms of Reference 1. Constitution The Board of Serco Group plc (the Board ) has reviewed and confirmed the establishment of a Committee of the Board to be
More informationCranham Church of England (VA) Primary School. Anti Fraud and Corruption
Cranham Church of England (VA) Primary School Anti Fraud and Corruption September 2014 Anne Nolan (Headteacher) September 2014 Nick Ryan (Chair of Governors) September 2014 Version Notes Date 1 New Policy
More informationANTI-FRAUD AND CORRUPTION POLICY. For the ACT Alliance
ANTI-FRAUD AND CORRUPTION POLICY For the ACT Alliance Approved by ACT International Executive Committee on April 27 th, 2009 This document was updated in March 2010 to take in account the change of name
More informationTo: All contacts in England, Wales, Scotland and Northern Ireland
Briefing 11/32 July 2011 Bribery Act 2010 To: All contacts in England, Wales, Scotland and Northern Ireland Key issues New offences created to replace previous bribery crimes Both the private and public
More informationTerms of Reference for the Audit Committee (approved at a meeting of the Board of Directors (the "Board") held on 20th October 2014)
Terms of Reference for the Audit Committee (approved at a meeting of the Board of Directors (the "Board") held on 20th October 2014) Constitution 1. It is resolved that a Committee of the Board be established,
More informationTruform Manufacturing LLC. Anti-Bribery, Anti-Corruption & Rev /22/17
Truform Manufacturing LLC Anti-Bribery, Anti-Corruption & Whistle Blowing Policy Contents 1. What does your policy cover?... 3 2. Policy statement... 3 3. Who is covered by the policy?... 3-4 4. Definition
More informationPOLICY AGAINST BRIBERY AND CORRUPTION. Introductory Guidance. This policy has been introduced in response to the Bribery Act 2010 ( the Act )
POLICY AGAINST BRIBERY AND CORRUPTION Introductory Guidance This policy has been introduced in response to the Bribery Act 2010 ( the Act ) The Act creates four key offences:- Active bribery (the offence
More informationAccountancy Scheme Sanctions Guidance
Guidance Financial Reporting Council April 2018 Accountancy Scheme Sanctions Guidance The FRC s mission is to promote transparency and integrity in business. The FRC sets the UK Corporate Governance and
More informationANTI FRAUD, BRIBERY AND CORRUPTION POLICY
ANTI FRAUD, BRIBERY AND CORRUPTION POLICY Version: 2.0 Ratified by: NHS Leeds West CCG Audit Committee Date ratified: 9 December 2015 Name & Title of Originator/Author(s): Visseh Pejhan-Sykes, Chief Finance
More informationFirm Competitiveness and Detection of Bribery
Firm Competitiveness and Detection of Bribery George Serafeim Working Paper 14-012 April 4, 2014 Copyright 2013, 2014 by George Serafeim Working papers are in draft form. This working paper is distributed
More informationThis Policy sets out Sewtec s position on any form of bribery and corruption and provides guidelines aimed at:
ANTI-BRIBERY & CORRUPTION POLICY Introduction Sewtec Automation Limited ( The Company ) is committed to promoting and maintaining the highest level of ethical standards in relation to all of its business
More informationFraud and Corruption Control Plan
Fraud and Corruption Control Plan 2018-2019 1. INTRODUCTION 1.1 Commitment to fraud and corruption control University of Adelaide ( the University ) recognises that it has a responsibility to develop,
More information2. Anti-Bribery and Corruption Policy
2. Anti-Bribery and Corruption Policy This document sets out the policy of Canary Wharf Group plc and its group of companies (the Group ) in relation to bribery and corruption. It may be amended by the
More informationPolice Firearms Survey
Police Firearms Survey Final Report Prepared for: Scottish Police Authority Prepared by: TNS JN:127475 Police Firearms Survey TNS 09.12.2014 JN127475 Contents 1. Background and objectives 3 2. Methodology
More informationAnti-Bribery and Corruption Policy
Anti-Bribery and Corruption Policy Policy # BW-GRP- ABC-01 Effective Date 30 September 2017 Email hilaryw@barloworld.com Version V2.2 Contact Hilary Wilton Phone 011 445 1168 Purpose... 1 Scope... 1 Regulatory
More informationFraud, bribery and money laundering: corporate offenders Definitive Guideline DEFINITIVE GUIDELINE
Fraud, bribery and money laundering: corporate offenders Definitive Guideline DEFINITIVE GUIDELINE 2 Fraud, Bribery and Money Laundering: Corporate Offenders Definitive Guideline Applicability of guideline
More informationHOW CAN BORDER MANAGEMENT SOLUTIONS BETTER MEET CITIZENS EXPECTATIONS?
HOW CAN BORDER MANAGEMENT SOLUTIONS BETTER MEET CITIZENS EXPECTATIONS? ACCENTURE CITIZEN SURVEY ON BORDER MANAGEMENT AND BIOMETRICS 2014 FACILITATING THE DIGITAL TRAVELER EXPLORING BIOMETRIC BARRIERS With
More informationOffice of the Police and Crime Commissioner. Scheme of Governance 2012/2013
Office of the Police and Crime Commissioner Scheme of Governance 2012/2013 Contents Introduction 1 Key role of the PCC 2 General principles of delegation 3 Functions delegation to Deputy Police and Crime
More informationThis policy and Code of Conduct will form part of the induction of new EMPLOYEES (as defined below).
ANTI CORRUPTION POLICY STATEMENT OF COMMITMENT RICHLAND GROUP (as defined below) is fully committed to conduct our business with utmost integrity and with the highest ethical standards, and in compliance
More informationFIA INSTITUTE ANTI BRIBERY AND CORRUPTION POLICY
! FIA INSTITUTE ANTI BRIBERY AND CORRUPTION POLICY 1. POLICY STATEMENT 1.1 As indicated in Article 8 of the Internal Regulations of the FIA Institute, we take a zero tolerance approach to bribery and corruption
More informationResearch Report on Corruption in the South African Private Sector
Research Report on Corruption in the South African Private Sector - 2006 - Commissioned by: and Conducted by: 14 February 2007 Table of Contents: 1. Introduction...3 2. Objectives of the study... 4 3.
More informationCowen Execution Services Limited
Cowen Execution Services Limited BRIBERY ACT POLICY August 2017 Cowen Execution Services Limited BRIBERY ACT POLICY CONTENTS SECTION 1: GENERAL INTRODUCTION 3 SECTION 2: COWEN EXECUTION SERVICES LIMITED
More informationAUDIT & RISK ASSURANCE COMMITTEE TERMS OF REFERENCE
AUDIT & RISK ASSURANCE COMMITTEE TERMS OF REFERENCE 1. Purpose 1.1. The purpose of the Audit and Risk Assurance Committee ( the Committee ) is to: 1.1.1. advise Council on the accounts/financial statements
More informationIt is the responsibility of all Fletcher Personnel to understand and comply with this Policy, including any reporting requirements set out below.
POLICY: ANTI-BRIBERY AND CORRUPTION 1. POLICY STATEMENT AND PURPOSE Fletcher Building Limited ( Fletcher Building ) is committed to complying with the law in all jurisdictions in which we operate, as well
More informationGLOBAL NEW CAR ASSESSMENT PORGRAMME ANTI BRIBERY AND CORRUPTION POLICY [DRAFT]
GLOBAL NEW CAR ASSESSMENT PORGRAMME ANTI BRIBERY AND CORRUPTION POLICY [DRAFT] 1. POLICY STATEMENT 1.1 We take a zero tolerance approach to bribery and corruption and will uphold all laws relevant to countering
More informationANTI-CORRUPTION AND BRIBERY POLICY
ANTI-CORRUPTION AND BRIBERY POLICY Date Approved by Governors March 2017 Review Date March 2019 On behalf of Governors signed Print name On behalf of Governors signed Print name Principal s signature All
More informationANTI-BRIBERY POLICY 1 POLICY STATEMENT
ANTI-BRIBERY POLICY Issued/approved by: Modern Water plc Board on 14 June 2011 Last updated: 17 September 2014 Applies to: Modern Water plc and any company or other entity (registered or operating anywhere
More informationANTI BRIBERY AND CORRUPTION POLICY
ANTI BRIBERY AND CORRUPTION POLICY 1. POLICY STATEMENT 1.1 The Foundation takes a zero tolerance approach to bribery and corruption and will uphold all applicable laws relevant to countering bribery and
More informationPhoto by photographer Batsaikhan.G
Survey on perceptions and knowledge of corruption 2017 1 2 Survey on perceptions and knowledge of corruption 2017 This survey is made possible by the generous support of Global Affairs Canada. The Asia
More informationANTI-CORRUPTION AND BRIBERY POLICY - INCLUDING CODE OF PRACTICE ON BUSINESS GIFTS AND HOSPITALITY
ANTI-CORRUPTION AND BRIBERY POLICY - INCLUDING CODE OF PRACTICE ON BUSINESS GIFTS AND HOSPITALITY Policy Number 5 July 2015 This Document is for the use of Scotmid Employees and their advisors only. No
More informationAUSTRIA Anti-Corruption
CHAMBERS AUSTRIA Anti-Corruption Global Practice Guides LAW AND PRACTICE: p.3 Contributed by Brandl & Talos Rechtsanwälte GmbH Law and&practice Austria The Law Practice sections provide easily accessible
More informationOn ethics, Inequality, Corruption and the Middle Class: The Case of South Africa. Presented by: Prof E.Mantzaris, Prof P.Pillay
On ethics, Inequality, Corruption and the Middle Class: The Case of South Africa Presented by: Prof E.Mantzaris, Prof P.Pillay Introduction Corruption in SA on the rise at unprecedented level The article
More informationNORTHERN IRELAND SOCIAL CARE COUNCIL
NORTHERN IRELAND SOCIAL CARE COUNCIL BRIBERY POLICY FINAL SEPTMBER 2012 1. INTRODUCTION The Bribery Act 2010 (the Act) introduces a new, clearer regime for tackling bribery that applies to all commercial
More informationWhistle Blowing Policy
Great Bedwyn CE VC Primary School Whistle Blowing Policy Date of Last Review: November 2015 Date to be Reviewed: Will stand until LA changes apply Review Body: Full Governing Body 1 Whistle Blowing Policy
More informationIndustry Agenda. PACI Principles for Countering Corruption
Industry Agenda PACI Principles for Countering Corruption January 2014 World Economic Forum 2014 - All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any
More informationWilmington Anti-Bribery and Corruption Policy Standard. Effective Date : June 2012
Wilmington Anti-Bribery and Corruption Policy Standard Effective Date : June 2012 Table of Contents 1. Executive Summary 1 2. Who this Policy Applies to 1 3. Who is Responsible for this Policy 2 4. Key
More informationAUDIT COMMITTEE TERMS OF REFERENCE
INTERTEK GROUP PLC AUDIT COMMITTEE TERMS OF REFERENCE 1 Membership 1.1 comprise at least three members. Members of the Committee shall be appointed by the Board, on the recommendation of the Nomination
More informationDirector of Customer Care & Performance. 26 April The Board is asked to consider and approve the attached draft
To: From: Subject: Status: Date of Meeting: BSO Board Director of Customer Care & Performance Anti Bribery Policy For Approval 26 April 2012 The Board is asked to consider and approve the attached draft
More informationMUTHOOT MICROFIN LIMITED
MUTHOOT MICROFIN LIMITED WHISTLE BLOWER POLICY Purpose Version Author Date To create a fearless environment for the employees / various stakeholders. 1.1 Head of HR 11-08 - 2016 Policy Ownership Head of
More informationEthical Culture. Speaking up: Information for CII members about whistleblowing. CII guidance series
Ethical Culture CII guidance series Speaking up: Information for CII members about whistleblowing www.cii.co.uk Contents 2 Introduction 3 What is whistleblowing? 6 How to be better prepared 8 FAQs 10 Concluding
More informationINTERNATIONAL ANTI-FRAUD EFFORTS: THE ISSUES OF BORDERLESS FRAUD FRAUD AND CORRUPTION IN AFRICA
INTERNATIONAL ANTI-FRAUD EFFORTS: THE ISSUES OF BORDERLESS FRAUD FRAUD AND CORRUPTION IN AFRICA Economic and high-tech crimes are an ongoing problem in Africa. Explore the challenges of managing fraud
More informationCounter Fraud Framework Manual Prosecution and Sanction Policy Statement
Counter Fraud Framework Manual 2014 Prosecution and Sanction Policy Statement Document Control Document Counter Fraud Framework Manual Prosecution and Sanction Policy Description Statement Project Name
More information[company name] Anti-Bribery & Anti-Corruption Policy
[company name] Anti-Bribery & Anti-Corruption Policy Contents 1. What does your policy cover?...3 2. Policy statement...3 3. Who is covered by the policy?... 3-4 4.. Definition of bribery...4 5.. What
More informationAudit and Finance Committee Terms of Reference
Audit and Finance Committee Terms of Reference 1. Purpose The Board of Directors has established an Audit and Finance Committee, (the committee) the main role and responsibilities of which include: 1.1
More informationGlobal Anti Bribery and Corruption Compliance Program Be transparent and keep it transparent
Global Anti Bribery and Corruption Compliance Program Be transparent and keep it transparent Page 1 of 13 Table of Contents 1 Why a Global Anti Bribery and Corruption Compliance Program?... 3 2 Our approach...
More informationEgypt s Administrative Corruption Perception Index February 2018
Egypt s Administrative Corruption Perception Index 2016 February 2018 Egypt s Administrative Corruption Perception Index Definition of Administrative Corruption The term of administration corruption is
More informationGood Governance for Medicines
Good Governance for Medicines A Framework for Good Governance in the Pharmaceutical Sector Good Governance Good Health What is Good Governance? Good governance is an essential factor for sustainable development
More informationFORENSIC. Doing business under the UK Bribery Act. Survey kpmg.com/in
FORENSIC Doing business under the UK Bribery Act Survey 2012 kpmg.com/in Executive summary Following several law commission papers, a first draft of the Bribery Bill was published in March 2009. After
More informationRECENT MULTILATERAL MEASURES TO COMBAT CORRUPTION. Cecil Hunt *
September 2006 RECENT MULTILATERAL MEASURES TO COMBAT CORRUPTION Cecil Hunt * Prepared for the American Law Institute-America Bar Association Program Going International: Fundamentals of International
More informationBe transparent and keep it transparent
Page 1 of 23 Be transparent and keep it transparent Anti-Corruption Compliance Program Date: February 2013 Page 2 of 23 Contents Welcome from our Chief Executive Officer... 3 Welcome from our CFO & GM
More informationBUILDING INTEGRITY IN UK DEFENCE PRACTICAL RECOMMENDATIONS TO REDUCE CORRUPTION RISK POLICY PAPER SERIES NUMBER FIVE
BUILDING INTEGRITY IN UK DEFENCE PRACTICAL RECOMMENDATIONS TO REDUCE CORRUPTION RISK POLICY PAPER SERIES NUMBER FIVE Transparency International (TI) is the world s leading nongovernmental anti-corruption
More informationAnti-Bribery Policy. Perform Green. Perform Green Limited. Registered organisation number:
Anti-Bribery Policy Perform Green Anti-Bribery Policy Page 2 Table of Contents Anti-Bribery & Anti-Corruption Policy... 3 1. Policy statement... 3 2. Who is covered by the policy?... 3 3. Definition of
More informationLobbying and Bribery
Lobbying and Bribery Vivekananda Mukherjee* Amrita Kamalini Bhattacharyya Department of Economics, Jadavpur University, Kolkata 700032, India June, 2016 *Corresponding author. E-mail: mukherjeevivek@hotmail.com
More informationEY UK Additional information
EY UK Additional information EY UK 2017 Additional information Page 1 of 28 Section 1 The Audit Firm Governance Code The Financial Reporting Council s (FRC s) Audit Firm Governance Code (AFGC) provides
More informationBANK OF INDUSTRY LIMITED. Whistle blowing Policy
BANK OF INDUSTRY LIMITED Whistle blowing Policy SECTION 1: INTRODUCTION Whistle blowing vary in terms of definition, depending on the role it is designed to play in the society at large and the organization
More informationContent. 01. Foreword Key findings Rise in risks to travellers... 4
Ipsos Global Reputation Centre TRAVEL RISKS & REALITY Front Cover: Travel Risk Map 2017 www.internationalsos.com/travelriskmap Editorial: Alex Lewis Matthew Painter Nick Jones Erin Mitchell Content Information:
More informationIX. Differences Across Racial/Ethnic Groups: Whites, African Americans, Hispanics
94 IX. Differences Across Racial/Ethnic Groups: Whites, African Americans, Hispanics The U.S. Hispanic and African American populations are growing faster than the white population. From mid-2005 to mid-2006,
More informationAll staff including managers who may have cause to take disciplinary action against a member of staff. Disciplinary Rules
Classification: Policy Lead Author: David Hargreaves, Deputy Director of Human Resources Additional author(s): Jon Dobson Authors Division: Human Resources Unique ID: 101TD(HR)06 Issue number: 8 Expiry
More informationAMAN strategy (strategy 2020)
AMAN strategy 2017-2020 (strategy 2020) Introduction: At times of political transition and building states, corruption tends to spread due to lack of legislations and firmly established institutions in
More informationTHE BRIBERY ACT 2010 POLICY STATEMENT AND PROCEDURES
THE BRIBERY ACT 2010 POLICY STATEMENT AND PROCEDURES DECEMBER 2011 CONTENTS Page 1. Introduction 2 2. Objective of This Policy 3 3. The Joint Committee s Commitment to Action 3 4. Policy Statement Anti-Bribery
More information