Corporate Fraud and Internal Control + Software Demo: A Framework for Prevention

APPENDIX C

Whistleblowing Policy

WHERE FRAUD HAS BEEN UNCOVERED, it frequently becomes evident that staff members realized that there may have been something wrong within the organization but did not express their concerns, either through fear of harassment and victimization or a misplaced sense of loyalty to their colleagues who are, in fact, the fraudsters. Other barriers to the reporting of wrongdoing have, in the past, involved:

• A lack of trust in the internal system whereby such allegations are investigated
• A belief that management will not be held accountable to the same standards as other employees
• An unwillingness to be seen as a corporate informer
• Fear of retaliation
• Fear of ostracism by other employees

This policy is intended to convey the organization’s belief in openness and honesty combined with a commitment to the highest standards of accountability. We encourage staff members to raise serious concerns within the organization rather than ignoring a problem or externalizing it.

This policy is intended to bring to the attention of employees:

• Their duty to report areas of serious concern and the mechanism through which such concerns can be reported.
• The protection which the organization will offer against possible reprisals or victimization for the reporting of such concerns in the reasonable belief that the disclosure was made in good faith.

This Whistleblowing Policy covers major concerns including but not limited to:

• Possible fraud, corruption, and other forms ...