Title Page
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Client / Site
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Location
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Conducted on
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Prepared by
Culture of Honesty and Ethics
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Setting the Tone at the Top:
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Is there a written Code of Conduct?
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Is the Code of Conduct disseminated to all employees at time of hire?
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Is there at least annual refresher training on the code of conduct for every employee?
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Is there a method of determining that employees understand the contents of the code of conduct?
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Do employees have a communication avenue for asking questions when ethical situations arise?
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Is there a Confidential Reporting Mechanism for employees to use to report suspected or possible fraud without fear of reprisal?
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Is the Confidential Reporting Mechanism contact widely advertised so that all employees are aware of it?
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Is there a protocol for handling all Confidential Reporting Mechanism activity?
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Is activity of the Confidential Reporting Mechanism reported to executive management and the board?
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Creating a Positive Workplace Environment:
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Is there an employee recognition and reward system or compensation program?
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Is there a whistleblower policy, a system for employees to obtain advice internally before making decisions that have significant legal or ethical implications, and/or a process to encourage employees to communicate or report, on a confidential or anonymous basis, without fear of retribution, concerns related to wrongdoing or violations?
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Hiring and Promoting Appropriate Employees:
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Are background checks, both criminal and work, performed on employees, especially those in positions of trust?
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Training:
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Is there a mechanism for tracking employee training and understanding of the code of conduct?
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Notification and Confirmation:
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Are employees held accountable for proactively addressing the potential of fraud in the discharge of their assigned duties?
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Are awareness of fraud and the management of fraud risks included in every managers (perhaps employees) personnel evaluation?
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Discipline:
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Are there consequences for employees who commit fraud and are those consequences consistent and fair?
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Are consequences pre-determined, that is defined in a fraud policy?
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Is there a formal procedure for documenting the consequences of each proven fraud?
Antifraud Processes and Controls
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Implementing and Monitoring Appropriate Internal Controls:
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Is risk assessment performed by each division, location, or segment separately?
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Are possible misconduct schemes, fraud scenarios, fraud categories, and applicable business activity or process identified?
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Were consequences posed by each scheme and were management’s tolerance for risks considered? (e.g Reputation damage, Financial damage - Monetary loss; Legal damage – Criminal or civil sanctions)
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Were they documented?
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Were red flags of fraud considered in the evaluation? Personal characteristics or situational
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pressures that can lead to fraud; Agency opportunities that can lead to fraud; Opportunities that allow or encourage management fraud
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Was the likelihood that each particular fraud will occur evaluated? Remote; Reasonably possible; Probable
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Were direct or indirect controls applicable to above-documented scenarios identified? Basic controls include: Segregation of duties relating to authorization, custody of assets, and recording and reporting of transactions; Supervisory reviews, verifications,
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reconciliation; Automated edit checks and system controls; Physical and logical security of assets; Embedded audit checks; Fraud detection software
Appropriate Oversight Process
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Commission or Board of Directors:
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Is there a communication mechanism by which executive management and the board is made aware of antifraud programs, controls, and results?
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Are they advised of the potential fraud risks in the agency?
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Are they made aware of the elements of the agency’s antifraud programs and controls?
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Are they advised of all actual frauds and the actions taken to mitigate future similar frauds?
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Are they advised of activity to the Confidential Reporting Mechanism?
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Management:
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Is there a member of executive management designated as the responsible party or point of contact for the fraud prevention?
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Is this person the liaison with the Office of the Inspector General?
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Does this person provide continuous reinforcement of the antifraud programs to all employees?
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Is this person responsible directly to executive management and the board for the antifraud programs of the agency?
Completion
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Full Name and Signature of Inspector