Theft and Fraud Prevention Policy

The company is committed to preventing and detecting fraud and theft, assigning responsibility for implementing appropriate controls to prevent and detect fraud and theft, establishing the appropriate reporting mechanisms to be used for notification of known or suspected fraud and theft, and establishing the consequences for fraud and theft by employees. 

Scope of Policy

Employees must comply with applicable state and federal law, and company policy. Furthermore, an employee cannot be compelled by a manager to violate a law or company policy.

This policy applies to any known or suspected fraud or theft involving employees, customers, vendors, contractors, consultants, or other parties related to the company.

Prevention and Detection of Fraud and Theft

Employees shall not perpetrate, engage in, or otherwise facilitate the act of committing fraud and theft.

Management is responsible for establishing the controls to prevent and detect fraud and theft. Managers are responsible for knowing the types of improprieties that might occur within their areas of responsibility and for identifying and assessing any irregularities.  Employees are responsible for the prevention and detection of fraud and theft that might occur within the scope of their work assignments and for reporting any known or suspected fraud and theft.

Reporting Known or Suspected Fraud and Theft

Employees are responsible for immediately reporting known or suspected incidents of fraud, including theft and misappropriation of company assets, to their management chain.

Any employee who has knowledge of fraud or theft of company assets by any person or organization, including another employee, and does not report it to management may be subject to disciplinary action, up to and including termination of employment.

Investigation of Reports of Known or Suspected Fraud and Theft

The management shall investigate allegations of fraud and theft in accordance with company established policies and procedures.

Management shall be responsible for ascertaining the extent of loss, and for reviewing and evaluating control and/or process failures related to the loss.

Any employee who suspects fraudulent activity should not attempt to personally conduct an investigation related to the activity. If there are any questions about what constitutes fraud and theft, a manager should be contacted.

Reports and investigations of allegations of fraud and theft ordinarily will be kept confidential to the reasonable extent possible under the law and consistent with the need to conduct an adequate investigation and take corrective action. 

Consequences

If appropriate management concludes that an employee has engaged in fraud or theft, appropriate disciplinary action will be pursued, up to and including termination of employment, in accordance with applicable personnel policies. In addition, employees engaging in fraud or theft will be required to pay restitution, including the cost of the investigation.

Employees, who engage in fraudulent activity or theft are not acting within the scope of their employment and should not expect protection for their acts under company insurance.

It is the company policy to pursue legal action based on the merits of the case in consultation with Company Counsel.

Ordinarily, the submission of a resignation by an employee accused or suspected of fraud or theft will not preclude later disciplinary action, including restitution and legal action. If restitution is required, payment arrangements will be established with the management.