5.1. PREVENTING FRAUD AND CORRUPTION
5.1.1. The company has established internal controls, policies, and
procedures to deter, prevent, and detect fraud and corruption.
5.1.2. New employees and contractors will be subject to background
investigations, including a criminal background check. If a
criminal background check facility is not available, a police
clearance must be obtained. The Company will also verify all
applicants’ employment history, education, and personal
references prior to making an offer of employment.
5.1.3. Vendors, contractors, and suppliers must be active, in good
standing, and authorized to transact business in their country.
Vendors, contractors, and suppliers are subject to screening,
including verification of the individual’s or company’s status as
a suspended or debarred party.
5.1.4. Contractual agreements with the Company will contain a
provision prohibiting fraudulent or corruptive acts and will
include information about reporting fraud and corruption.
5.1.5. The Company employees will receive fraud and corruption
awareness training. New hires will receive the training as part of
their orientation at the commencement of employment and will
sign a statement acknowledging that they have received and
read the Sample Fraud Policy. All employees will receive fraud
and corruption awareness training every three years.
5.2. REPORTING FRAUD AND CORRUPTION
5.2.1. Any person who has a reasonable basis for believing fraudulent
or corrupt acts have occurred has a responsibility to report the
suspected act to the Compliance Department, immediately.
Failure to report suspected fraudulent or corrupt activity in a
timely manner according to the procedures below will also be
subject to disciplinary action. The procedures for doing so
anonymously are laid out in the Whistleblower Policy.
Alternatively, staff members can report suspected fraudulent or
corrupt acts as stated below. In all instances, the suspected
fraudulent activity must be escalated to the Director of
Compliance. No other actions are to be taken until the
Compliance department is aware of the suspicious activity.
5.2.1.1. Headquarters Staff - should report to their respective
National Director and/or Regional Director, who will
report to the Director of Compliance.