This page states Azari Holdings’ public policy position. Applicable law, contracts, regulatory requirements and more specific subsidiary procedures may impose additional or stricter requirements.
What fraud can include
Fraud may include theft, deliberate misstatement, false invoicing, expense abuse, payroll manipulation, diversion of payments, misuse of customer or company funds, forged documents, procurement collusion or concealment of a material conflict.
Attempted fraud and knowingly assisting another person to conceal fraud are also concerns even if no loss ultimately occurs.
Prevention and controls
Responsibilities, approvals, access and payment instructions should be designed so that one person cannot easily create, approve and conceal a material transaction without review.
Controls should reflect the size and risk of the activity rather than exist as paperwork that people routinely bypass.
Third-party fraud risk
Suppliers, intermediaries, customers and service providers can be a source or target of fraud. Changes in bank details, unusual urgency, inconsistent identity information and unexplained deviations from contract require attention.
Material changes should be verified through a trusted channel rather than relying solely on the communication that requested the change.
Accurate records
Accounting, ledger, operational and audit records should reflect the underlying event. Deliberately creating a false description to make an improper transaction appear acceptable is itself misconduct.
Evidence relevant to a suspected fraud should be preserved and access restricted where necessary to protect an investigation.
Reporting concerns
People should report suspected fraud promptly through an appropriate manager or speak-up route. A reporter is not required to conduct a personal investigation before raising the issue.
Concerns involving senior management or a person who would normally receive the report should be escalated through an independent route.
Investigation and response
Credible allegations should be triaged for immediate financial, legal, security or customer risk, then investigated by people with appropriate competence and independence.
Corrective action may include control changes, recovery efforts, disciplinary measures, contract remedies or reporting to an authority where required.