Professional Documents
Culture Documents
Fraud Prevention
Fraud Prevention
Fraud Prevention
6 Fraud prevention involves not only compiling anti-fraud policies but also
involves putting in place effective accounting and operational controls and
the maintenance of an ethical environment that encourages employees at all
levels to actively participate in protecting company's money & property.
Creating an anti-fraud culture involves:
Having a clear statement of ethical values as enunciated.
1.7 The policy statement is given below for implementation with immediate effect.
2.1 Objective of the Policy is to provide a system for detection, prevention and
reporting of a fraud detected or suspected; and handling of such matters
pertaining to fraud.
2.3 The above guidelines will not be in conflict with the guidelines issued by the
Central Government/Department of Public Enterprises and Central Vigilance
Commission as amended from time to time.
2.4 The Policy is expected to ensure and provide for the following:
f) To provide assurances to one and all, that any and all suspected
fraudulent activity / activities will not be allowed and will be fully
investigated.
3.1 The policy applies to any fraud, or suspected fraud involving employees of
CMRL (all full time, part time or employees appointed on adhoc/
temporary/deputation/contract basis) as well as representatives of vendors,
suppliers, contractors, lenders, consultants, advisors, service providers or
any outside agency(ies) with a business relationship with CMRL.
4.0 DEFINITION
5.1 While fraudulent or suspected fraudulent activity could have a very wide
range of coverage, the following are some of the act(s) which constitute
fraud.
5.2 The list given below is only illustrative and not exhaustive:-
6.1 CMRL has created a separate Vigilance Department which is being headed
by a Chief Vigilance Officer (CVO) to oversee the vigilance functions in
CMRL.
6.2 Chief Vigilance Officer (CVO) is the “Nodal Officer” to oversee the vigilance
functions in CMRL.
6.3 Chief Vigilance Officer (CVO) will directly report to Managing Director and to
the Board of CMRL as & when necessary.
6.4 The Vigilance Department will be provided with the required Officers and
Staff with other necessary infrastructural facilities for assisting Chief Vigilance
Officer (CVO) to discharge the duties and responsibilities of “Chief Vigilance
Officer”. The Officers and staff will be posted to Vigilance Department on
tenure basis from technical divisions of CMRL who will have tenure of 3
years and extendable for a further period of 2 years. Officers on deputation
from TN Government or Government of India may also be considered for
posting in the Vigilance Department to work under CVO who will also have a
tenure of 3 years and extendable for a further period of 2 years.
6.5 Managing Director of CMRL is the Competent Authority for appointing the
Officers and staff in Vigilance Department. The appointment will be done in
consultation with CVO.
6.6 The Board of CMRL is the Competent Authority to notify the name and
designation of officer who will discharge the duties and responsibilities of
“Chief Vigilance Officer” during his/her leave.
A: CONTROLLING OFFICERS
9.1 All the controlling Officers shall share the responsibility of prevention and
detection of fraud and for implementing the “Fraud Prevention Policy” of
CMRL for the department under his/her area of control. It is the responsibility
of all the controlling to ensure that there are mechanisms in place within their
area of control to:-
B: ALL EMPLOYEES
9.2 Every employee (full time, part time, adhoc, temporary, deputation, contract),
representative of vendors, suppliers, contractors, consultants, service
providers or any other agency(ies) doing any type of business with CMRL, is
expected and shall be responsible to ensure that there is no fraudulent act
being committed in their areas of responsibility/control. As soon as it is learnt
that a fraud or suspected fraud has taken or is likely to take place they should
immediately apprise the same to the concerned verbally or in writing.
Acting with propriety in the use of official resources and the handling
and use of public funds.
This may include but not to be limited to cash, payments systems,
receipts, supplies, dealing with suppliers, the use of IT equipment and
placing orders and contracts.
Preventing and detecting fraud.
Being alert to the possibility that unusual events or transactions could
be indicators of fraud.
Reporting details immediately through the appropriate channel if they
suspect that a fraud has been committed or see any suspicious acts or
events.
Cooperating fully with whoever is conducting internal checks or reviews
or fraud investigations.
C: PHYSICAL SECURITY
b) Assets can range from computer terminal that sits on the desk, software
or documents in servers or to the cheques sent out to pay suppliers. As a
general principle assets should be held securely and access to them
restricted as appropriate. The control should apply not only to the
premises but also to computers, databases, documents and any other
area that is critical to the operation of the individual organization. It may
even be appropriate to restrict knowledge of the existence of some
assets.
E: AUDIT TRAIL
9.6 Audit trail is largely a detective control, although its presence may have
deterrent effect and thus prevent a fraud. An audit trail enables all
transactions to be traced through a system from start to finish.
F: STAKE HOLDERS
11.1 The name Chief Vigilance Officer (CVO) will be displayed in the CMRL
website, intranet and in prominent places of corporate office & worksites.
13.1 The Managing Director, CMRL in consultation with Chief Vigilance Officer
shall be the Appropriate Authority for revision of this policy as and when
needed.
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