Forensic Outlook De-risking India Inc. to combat fraud and corruption

Transcription

1 Forensic Outlook 2014 De-risking India Inc. to combat fraud and corruption

2 Introduction Corporate India reached its tipping point with cases of fraud, espionage and corruption seeing a significant rise in Comprehensive changes were made in the regulatory landscape, and after half a decade, two Bills (crucial to the growth and progress of the larger ecosystem in the country) received the nod of approval from the Government. These landmark Bills included the Lokpal Bill (awaiting the approval of the Secretary Legislative Department after the President s assent) and the Companies Act 2013 (enacted, but with a large number of provisions yet to be notified). The widespread belief is that the new Companies Act, 2013 will improve corporate governance practices, enhance transparency in functions of organizations, protection of investments and disclosure norms as well as enable friendly corporate regulations and a structured mechanism to curtail fraudulent activities. The complex global regulatory scenario is also pushing organizations to comply with a number of relevant Indian and international laws to run and protect their businesses. Corruption and bribery is a major risk for global corporations today, with an overwhelming majority of prosecutions related to corruption and bribery worldwide targeting third parties such as agents, consultants, vendors, suppliers, distributors, etc. EY s report, Bribery and corruption: ground reality in India, corroborates this fact and reveals that third party risk is a contagious issue that can expose organizations to the dangers of bribery and corruption. Nearly 75% of the respondents of the survey conducted for the report stressed on the fact that it was the responsibility of organizations to oversee activities managed by third parties including vendors, dealers and distributors. Therefore, it is very important that companies conduct integrity-related due diligence on third parties before initiating any relationships with them. Forensic Outlook 2014 Demystifying the impact of the Companies Act, Forensic Outlook 2014 Streamlining company-vendor partnerships Multi-faceted role of human resources Riding the technology wave Whistleblowing for greater awareness

3 Human Resource (HR) departments play a critical role in managing and monitoring human capital in organizations. HR professionals are trained to recognize, assess, identify, train, counsel, supervise and mentor employees to ensure that work is conducted seamlessly in companies. However, their role has evolved significantly and has gone beyond just dealing with employee-related issues. Going forward, we expect to see HR being given a broader mandate and taking on the responsibility of laying the foundation for an ethical culture in organizations. In this digital era, technology has become a double-edged sword and fraud-related investigations have become challenging. On one hand, the quantum of data to be analyzed is humongous, and on the other, fraudsters are deploying sophisticated technology to commit cybercrime and other fraud. Another key factor for organizations, which adds to the complexity of the issue, includes challenges relating to regulatory or legal requirements pertaining to preventive monitoring, reporting and effective investigation of fraud. Today, fraud continues to rage rampant across the world. According to EY s EMEIA fraud survey 2013, 57% of its global respondents agreed that bribery, corruption and financial misstatement were widespread. The survey s India findings revealed that the number was higher in the country than the global average and stood at 69%. The corporate domain has also become increasingly interlinked and networked. However, while senior management members are more tuned to the pulse of their organizations today, the concept of vigilance needs to go beyond the boardroom and trickle down to the employee level. According to EY s India fraud survey 2012, out of the companies that witnessed fraudulent activities during the year, 62% indicated that whistleblowing helped in their detection. Worldwide, organizations have realized and recognized the benefits of putting in place a whistleblowing mechanism. India Inc. has followed suite. The Companies Act 2013 has played a major role in this initiative. In 2014, the need of the hour is for organizations to evaluate their business strategies, and assess and put in place stringent measures to de-risk themselves by institutionalizing holistic frameworks that foster transparency, promote an ethical culture and sustain their long-term profitability. In line with this, corporate India will also need to focus on these key trends to mitigate fraud risks in their new age workplaces Arpinder Singh Partner and Head India and Emerging Markets Fraud Investigation & Dispute Services EY Forensic Outlook

4 Demystifying the impact of the Companies Act, 2013 EY s viewpoint Yogen Vaidya, Partner, Fraud Investigation and Dispute Services at EY, elaborates on how he expects the Companies Act 2013 to be a game changer for India Inc. and stimulate anti-fraud and anti-corruption practices. He believes that under the new corporate regime, companies are gearing up to develop globally accepted sustainable and sound governance practices. Building a strong business case for good governance The Companies Act, 2013 covers loop holes by prescribing stricter compliance and disclosure norms than were imposed earlier. The sweeping changes made by it with respect to governance, transparency, disclosures, the responsibilities of auditors and directors, class action suits and the empowerment of the Serious Fraud Office (by conferring on it a statutory status) are expected to result in stringent punishment in the event of any breach of the Act. Therefore, companies need to make the requisite changes in their polices and functions to foster healthy governance practices and avoid these penalties. Nipping potential fraud risks in the bud The Companies Act mandates that organizations implement preventive as well as reactive mechanisms to mitigate instances of fraud. It also includes provisions that impose rigorous and harsh penalties if fraud is proved. Therefore, it is likely that companies will put in place efficient fraud risk assessment and fraud response teams to protect their organizational interests in this new era. This will enable the creation of a robust framework for effective fraud risk-management. 4 Forensic Outlook 2014

5 Mainstreaming the slogan Say no to bribery! It is anticipated that implementation of the new Act will lead to increased awareness of anti-fraud and anti-corruption practices in organizations. With stricter amendments in place, companies are also expected to actively implement and comply with these policies. Additionally, institutionalization of effective antibribery programs is essential and expected due to the diverse nature of global anti-bribery policies. Embracing the holy grail of ethics There has been a gradual rise in the number of organizations offering their employees compliance-related training on a wide range of topics, including discrimination and harassment at the workplace, competitors dealings, insider trading, protection of trade secrets, record management, bribery and kickbacks, etc. This trend is expected to see an uptick as challenges in the business environment intensify. Typically, most of these compliance topics are addressed in an organization s code of conduct. An individual s ability to differentiate right from wrong conduct is a critical factor in successful propagation of a code of conduct. The rise of ethics-related training in corporate organizations, some mandated by government regulations, is another driver that is credited with changing behavior and culture in India Inc. The aim of such training is to help employees make ethical decisions in complex and sensitive situations. Organizations can also conduct annual or bi-annual training sessions on codes of conduct for their employees instead of scheduling multiple, individual training programs for them. Keeping the spotlight on Independent Directors Over the years, the roles and responsibilities of Independent Directors (IDs), which saw minimal mention under the old Act, have gone up seven-fold. Today, IDs are entrusted with increased responsibility and play a proactive role in overseeing the conduct and strategic affairs of companies. They act on behalf of their organizations to report their concerns about unethical behaviour, actual or suspected fraud and any violation of companies codes of conduct or ethics policies. It is expected that the practice of appointing a Lead Director will substantially enhance sound governance practices. A Lead Director, elected from the board s IDs, serves as an independent chief among all the board members. He or she also helps to ensure that board relations run smoothly. Furthermore, IDs have the power to hold separate meetings (without other directors being present) to assess the board s performance. It also provides them the opportunity of voicing their concerns or sounding an alarm in case of mismanagement, fraud or any other wrongdoing. The Act makes it mandatory for an ID to convene at least one such meeting a year without the presence of non-independent directors and management. It is, however not mandatory for all IDs to attend this meeting, but they should attempt to do so. Fraudsters, watch out! The implementation of a vigil mechanism, to bolster transparency in corporate governance, has been made mandatory for certain class (es) of companies. Such provisions are expected to give lead to the establishment, implementation and enforcement of an elaborate whistleblowing policy, which is in accordance with the larger ethics framework. It is believed that such a mechanism will enable companies to detect fraud and unethical practices, and provide them with optimum solutions to address related challenges at an early stage. Conclusion The new Act has been developed in the aftermath of a number of corporate scandals. While its true impact can only be gauged over time, and much remains to be implemented, its initiation has led to companies shifting from being complacent to playing a more compliant role. They are proactively promoting good governance and transparency, and advocating ethical corporate practices. Undoubtedly, 2014 is set to see a dramatic change in sound governance practices to enable corporate India to achieve significant success due to the stringent nature of new legislations and the penal provisions prescribed therein. Forensic Outlook

6 Streamlining company-vendor partnerships EY s viewpoint Dinesh Moudgil, Partner, Fraud Investigation & Dispute Services at EY, elucidates the importance of third party due diligence programs in a business environment where numerous local and global laws and regulations need to be considered. He emphasizes the need of screening third parties with greater caution, since the risks prevalent today can have a detrimental effect on organizations long-term profitability and reputations. A strategic approach to managing third party engagements Today, most large corporations have a variety of third party intermediaries associated with them. These play various specialized roles such as that of suppliers, distributers and consultants. The relationship between companies and associated third parties is symbiotic in nature. However, the larger the organization, the more complex its network of third party partnerships, and the greater its fraud or corruptionrelated risks. Therefore, to minimize the possibility of a negative impact on their business, organizations need to focus on conducting extensive due diligence before commencing and while maintaining such partnerships. Due diligence should cover the background, track record and reputation of third parties and investigate the possibility of any undisclosed relationships that may lead to conflict of interest. Legal compliance to become increasingly complex Companies with global operations are required to comply with a number of local and global anti-corruption and briberyrelated legislations such as the Foreign Corrupt Practices Act of 1977 (FCPA) and the UK Bribery Act of 2010 (UKBA). These legislations cover the use of third parties, and therefore, corporate anti-corruption compliance programs should focus on them. Organizations also need to demonstrate their intent of not dealing with third parties that offer and receive bribes or indulge in other unscrupulous practices during business transactions. Therefore, it is important that companies conduct due diligence on parties that perform certain activities on their behalf as an effective compliance-related procedure. Due diligence programs can be complex in terms of their cost and require substantial resources to address third party-related threats, and therefore, need to be proportionate and risk-based. 6 Forensic Outlook 2014

7 Supervision of companies overseas operations Driven by the need to grow fast and to be competitive, Indian companies are expected to develop wider and more diverse operations outside their home country. They are likely to explore foreign markets to sell and distribute their products and services, and thereby build global customer bases. Organizations are also expected to increasingly develop more partnerships with foreign companies for a variety of reasons including sourcing, technical or financial tie-ups. In such situations, it will be prudent for them to conduct third party due diligence to assess the background and credibility of their third parties or business partners. This will help them preempt any shocks later, especially in emerging and high- risk geographical jurisdictions. Sectoral focus Certain sectors are more vulnerable to unethical and corrupt practices by associated third parties than others. For instance, sectors that have a substantial interface with government agencies, either for licenses or approvals or for government sales (e.g. public health), are especially susceptible compared to others. Liaising with agents and consultants as well as distributors, and selling to government agencies should be carefully monitored to ensure that no unethical business practices are undertaken on behalf of companies. In recent years, businesses in sectors such as mining, telecom, construction and pharmaceuticals have been under the scanner for alleged breaches of legislations, often resulting in withdrawal of licenses or cancellation of large contracts. Diligence as an anti-fraud tool A significant proportion of fraud-related investigations indicates collusion between employees and third parties, and suggests conflict of interest. There have been numerous instances of multiple entities with the same undisclosed beneficial owners, employees setting up entities to do business with their own employers, etc. Furthermore, companies may unwittingly engage in business with third parties with tainted reputations. Therefore, it is vital to undertake a due diligence program to identify and corroborate a third party s beneficial ownership and track record, credentials, litigation history and relationships with organizations or individuals of potential concern. Conclusion Business partnerships have increasingly come under the scanners of various local and global regulatory agencies. Therefore, it is imperative that companies keep a watchful eye on all their associates and partners to avoid financial or reputational losses. Implementation of a strong third party due diligence framework will be a key step in this direction. Forensic Outlook

8 Multi-faceted role of human resources EY s viewpoint Jagdeep Singh, Partner, Fraud Investigation & Dispute Services at EY, elaborates on the relevance of the Human Resource (HR) function in fraud risk management. He also explains HR s contribution in encouraging employees to closely conform with organizations codes of conduct and their compliance with relevant laws. Winning the fraud battle by redefining ethics The ever-changing corporate diaspora is influenced by multiple factors governments, shareholders interests, corporate governance, etc. However, the most important element comprises employees, who form the human machinery, which drives organizations forward. The success or failure of a company is largely dependent on the efforts of its employees, and it is important to steer them in a positive direction. Therefore, in the future, the role of HR will be redefining the concept of ethics, ensuring that employees are cognizant of companies codes of conduct and comply with to highest standards of governance. Propagating an over-arching code of conduct and sound governance framework The last few years have seen a significant rise in the number of cases relating to organizational misconduct. Therefore, it is in an organization s best interest to take a pragmatic approach, and proactively address and mitigate these growing concerns. HR professionals need to think and work outside the box and help organizations develop a robust code of conduct and implement sound governance practices. They should also play a vital role in explaining to employees the rationale for a company having a code, and following this through training and awareness programs at regular intervals. 8 Forensic Outlook 2014

9 Donning the hat of a strategic consultant Evolving corporate dynamics are also expected to drive HR professionals to considerably improve their skill-sets and go beyond their perceived job description. Taking an unconventional approach, they will now need to cultivate the capabilities of lawyers, investigators and trainers. As part of this new role, they will be tasked with consulting their senior leadership teams, especially on matters relating to good governance. This will include formulating the right policies, developing extensive training exercises, providing strategic counsel and raising awareness about the right conduct. Adding a human perspective The nature of work handled by HR professionals will be seen as a science as well as an art. It has always involved dealing with human behavior, feelings and emotions. While HR professionals are expected to don several new hats, they will need to retain the human touch and be proficient in the art of adding that human perspective. Profiling a fraudster The role of HR professionals relating to fraud risk is extremely valuable because of their constant interaction with people and dealing with human behavior, which is often not discernible. HR professionals backgrounds and ability to understand the complexities of human behavior gives them an edge in demystifying the psyche of fraudsters. An important element to be noted here is that two of the three main ingredients of fraud (according to Donald Cressey) are human behavioral factors incentive and rationalization. Putting the brake on sexual harassment at the workplace Today, there are an increasing number of women joining the corporate world. Therefore, a key focus area for organizations is to protect their interests and foster an inclusive work environment for them. In this regard, the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, which was approved by the President in April 2013 and was notified in December 2013, is expected to be instrumental in transforming the culture at the workplace. The provisions of the Act will be crucial in protecting the interest of women employees and fuel the adoption of sound governance practices in corporate organizations. Needless to say, HR will play a pivotal role in making policies, ensuring legal compliance, spreading awareness, and creating the right environment and culture for the safety of women at the workplace. Conclusion The role envisaged for HR will need to evolve to become a source of unwavering, corporate strength to the senior leadership team, with changes in the regulatory scenario significantly augmenting the duties of employers in organizations. The provisions of the new Companies Act 2013, the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013 and the revisions in the Indian Penal Code place the bulk of the responsibility for maintaining a safe work environment on employers. Additionally, HR will also need to induce employees to accept and abide by companies internal codes of conduct as organizational Bibles. Therefore, its responsibilities in organizations are expected to become all-encompassing and extend from redefining ethics at the workplace to promoting a holistic code of conduct, and ensuring increased compliance with laws and leading corporate governance practices. Forensic Outlook

10 Riding the technology wave EY s viewpoint Anil Kona, Partner, Fraud Investigation & Dispute Services at EY, elaborates on the latest technology trends that can be leveraged in the war against global cybercrime and digital fraud. With the next decade expected to be dominated by transformative mega trends such as Big Data, cloud, social media and mobility, organizations will need to ride the technology wave, adopt sophisticated methods to mitigate cyber risks and protect the confidentiality of their data and other critical assets. Leveraging technology to fight new age technology risks Today, organizations constantly use technology to access, connect and share information all with just a simple click of a button. This has led to a phenomenal increase in the amount of electronic data stored, and managing this information has become complex. Furthermore, augmented accessibility has made fraud control challenging for companies. Fraudsters are now tech-savvy and pose a threat to global organizations. Therefore, the use of cutting edge technology and analytics has become essential to effectively combat high-tech fraud and cybercrime. In this scenario, companies deployment of Big Data solutions, forensic data analytics and predictive analytics procedures will enable them to create a robust security framework to mitigate potential fraud. Big risks require Big Data Electronically Stored Information (ESI) is growing exponentially through a variety of data sources. This ever-increasing volume of data across dissimilar systems is a reality as well as a challenge for global organizations. With rising cases of fraud and data theft, managing this deluge of data has become critical for companies in order to maintain their continuity and protect their business. Extracting the important elements from this gigantic data during fraud (or potential fraud) investigations, and responding to regulators inquiries and litigation issues may seem a herculean task, but adoption of Advanced Forensic Data Analytics techniques, strong text mining capabilities and effective implementation of Big Data makes the process seamless. These techniques also help in in mitigating the various risks faced by organizations. Data analytics on structured and unstructured data can therefore be viewed as a way of transforming organizational capabilities to address potential fraud. 10 Forensic Outlook 2014

11 The power of analytics The heavily regulated business environment has driven CXOs to factor in all possible threats relating to bribery and corruption as part of their boardroom agendas. They are also under tremendous pressure to enhance their anti-bribery and corruption programs, and comply with relevant regulations mandated by the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and other such Acts. Therefore, companies implementing data analytics or anti-bribery and corruption analytics need to adopt a risk-based approach that identifies target areas for internal audit or compliance tests to ascertain areas of possible improper conduct. Organizations that conduct deep text mining (of unstructured data), statistical analyses and visual analytics, and create interactive dashboards with 100% data sampling are in an advantageous position in identifying patterns that are symptomatic of potential fraud. Strengthening the fight against cybercrime EY s 16th annual Global Information Security Survey 2013 revealed that organizations continue to invest significantly in safeguarding themselves against cyber attacks and threats. However, the number of security breaches is on the rise and it is no longer of question of if, but when, a company will be the target of an attack. This could be in the form of data theft, leakage of information, IP infringement etc., and it is imperative for organizations to adopt a multi-pronged approach to combat such risks. Approaches to fight against cybercrime: Preventive measures such as risk assessment and identification, the creation of comprehensive policies, proactive education and training Detective measures such as responding to data breachrelated challenges, strengthening existing security-related policies and monitoring network-related activities to identify attacks Response measures including data extraction, forensic disk imaging and plugging of loopholes Unearthing evidence through computer forensics Every bit and byte of information stored and subsequently erased from most devices is likely to be recovered. Computer forensics makes this possible and is expected to play a vital role in enabling a breakthrough when detecting relevant sources of evidence. Identifying, preserving and analyzing evidence in litigation by using forensically sound technology and procedures is critical for establishing such evidence in a court of law. Forensic specialists are also equipped with the requisite skills to recover data from PDA or mobile phones, and this activity can contribute significantly, especially in instances where commercial confidentiality may have been breached. The use of computer forensics is instrumental during fraud investigations, since it aids extraction of data from mailboxes, documents and files (even if they are password-protected); reconstruction of websites, discovery of previously connected storage devices, etc. It also helps in detection and recording of unusual patterns or sequences of behavior among employees or third parties, which may indicate fraudulent or other improper activity. e-discovering compliance Organizations need to develop a strategic approach when managing electronic data, especially since they need to be compliant with global laws and regulations under the Foreign Corrupt Practices Act, the UK Bribery Act, etc. Consequently, e-discovery, which requires advanced technology in legal hold, processing, searching, culling and filtering of s and other data, navigation through discussion threads and identification of key responsive documents, is expected to become a critical area of focus, going forward. This is a clear indicator while ascertaining an organization s position in a case or investigation. The use of e-discovery is especially relevant in cases of mergers and acquisitions, wherein health checks need to be conducted in multiple countries to ensure that there are no potential corruption liabilities involved in the acquisition process. Rapid proliferation of connected devices will also compel organizations to deploy mobile e-discovery, since it aims to address the challenges posed by multiple privacy laws and data-protection directives. Conclusion While the world continues in its path toward digitization, the risks associated with it will also increase. Therefore, prevention, detection, mitigation and resolution are imperative to deter instances of fraud and cybercrime, which are seeping across all levels in corporate organizations. In order to manage the complexities of digitization and prepare for the risks of tomorrow, organizations will need to adopt diverse and innovative technology. This will also ensure the creation of a robust and secure foundation in enterprises, which can help them combat fraud and corruption. Forensic Outlook

12 Whistleblowing for greater awareness EY s viewpoint Jagdeep Singh, Partner, Fraud Investigation & Dispute Services at EY, provides an overview of the intrinsic need for an organization to frame a robust whistleblowing mechanism. In light of the recent Companies Act 2013, which mandates that organizations implement such vigil mechanisms, this will provide a formal channel for various stakeholders to voice their concerns with respect to wrongdoing or fraud in organizations. Crusading for greater fraudparency The Companies Act 2013 is set to get the ball rolling toward enhanced standards of transparency, leading to prevention and deterrence of fraud in corporate India. This is primarily because the Act includes a provision, which makes it mandatory for listed entities to establish a vigil mechanism to report genuine concerns. Implementation of such a framework is expected to propel organizations toward actually deep-diving in the event of wrongdoing, rather than merely considering it a tick in the box. Not just compliance, but good governance As a first step, organizations need to realize that a vigil mechanism is not just a matter of compliance but good governance, and is in line with global leading practices. Management should proactively set up the requisite platform and define the appropriate channel for employees (as well as partners) to raise their concerns. A formal whistleblowing mechanism is a step toward good corporate governance, leading to reduction of fraud and misconduct, while at the same time promoting an ethical culture. 12 Forensic Outlook 2014

13 Protect the reporter and allow anonymity An important factor for the success of a whistleblowing mechanism is the extent to which an organization can defend the interests of reporters. This could be against any sort of victimization, harassment or retaliation, which could be a threat to his or her personal as well as professional life. Even the Companies Act 2013 (and draft rules published under it) requires that there are adequate safeguards against victimization of individuals that deploy such a mechanism. Many employees are afraid to come forward, reveal their names and disclose information regarding fraud because of a possible backlash. Industry surveys reveal that almost 50% more employees will come forward if they are allowed the choice of remaining anonymous. Therefore, as a best practice, a whistleblower should be provided with the option of remaining unidentified. Outlining critical success factors To reiterate, with the Companies Act 2013 in place, organizations are mandated by law to institute an adequate and functional vigil mechanism. However, this will be effective to the extent it is supplemented with policies and a practical fraud response plan (matrix on suggested action, guidance on investigation, disciplinary action and documentation). Additionally, it is crucial to appoint a cross-functional committee and sub-committees to assess complaints, decide on the way forward, initiate disciplinary action and steps to remediate controls gaps, and provide regular reports to auditors or regulators. Greater scrutiny by IDs It is the responsibility of IDs (stated under Schedule IV) to ascertain and ensure that their organizations have in place adequate and functional vigil mechanisms and that the interests of employees using these are not harmed. They are also entrusted with the task of flagging and reporting concerns relating to actual or suspected fraud or violation of their companies codes of conduct or ethics policies. Consequently, they should periodically review any issues escalated by their audit committees, investigations initiated, and corrective action and reporting, if any. Conclusion Compulsory implementation of vigil mechanisms comes at an opportune time when there is a rapid increase in fraud- and corruption-related risks. Such vigil mechanisms enable organizations to safeguard their assets, and mitigate losses relating to their reputation, productivity and monetary damage. At the same time, they clearly reflect organizations commitment to sound governance, including in their ethical values and transparency. They are also help companies achieve long-term sustainability and drive their overall profitability. Awareness the key To spread awareness among employees and other stakeholders, organizations should also conduct specific training at regular intervals. These sessions need to be strategized in terms of their mode, language (may need to be in the vernacular) and content to achieve maximum and appropriate awareness. The training should outline the scope of the framework, and clearly specify what the mechanism can and cannot be used for. The latter is important to reduce complaints that are not really a subject matter to be reported through a vigil mechanism. The training content should also include the operational aspects of the mechanism from a reporter s perspective, a brief of companies internal processes, assurance that he or she will be protected and the consequences of frivolous reporting. At the end of the day, all employees should know their rights and be reassured that they can reach out to their organizations hotlines and report suspicious incidents. Forensic Outlook

14 About Ernst & Young s Fraud Investigation & Dispute Services (FIDS) Dealing with complex issues of fraud, regulatory compliance and business disputes can detract from your efforts to achieve your company s potential. Enhanced management of fraud risk and compliance is a critical business priority whatever the industry sector. With our more than 2000 fraud investigation and dispute professionals around the world, we will assemble the right multi-disciplinary and culturally aligned team to work with you and your legal advisors. In addition, we will provide you the benefit of our broad sector experience, our deep subject matter knowledge and the latest insights from our global activities. FIDS India Deep competencies: Our FIDS team has specific domain knowledge along with wide industry experience. Forensic technology: We use sophisticated tools and established forensic techniques to provide requisite services to address individual client challenges. Our services: Anti-fraud and fraud risk assessment Fraud investigation Dispute advisory services Forensic technology and discovery services Regulatory compliance Forensic business intelligence Anti-bribery program Third-party due diligence Whistle-blowing services Competition and trade services Supply chain and compliance integrity Global exposure: Our team members have been trained on international engagements and have had global exposure to fraud scenarios. Market intelligence: We have dedicated field professionals, who are specifically experienced and trained in corporate intelligence, and are capable of conducting extensive market intelligence and background studies on various subjects, industries, companies and people. Thought leadership: We serve a variety of leading clients, which gives us deep insight into a wide range of issues affecting our clients and business globally. Qualified professionals: We have a qualified and experienced mix of chartered accountants, certified fraud examiners, lawyers, CIAs, CISAs, engineers, MBAs and forensic computer professionals. 14 Forensic Outlook 2014

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16 Ernst & Young LLP EY Assurance Tax Transactions Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com. Ernst & Young LLP is one of the Indian client serving member firms of EYGM Limited. For more information about our organization, please visit Ernst & Young LLP is a Limited Liability Partnership, registered under the Limited Liability Partnership Act, 2008 in India, having its registered office at 22 Camac Street, 3rd Floor, Block C, Kolkata Ernst & Young LLP. Published in India. All Rights Reserved. EYIN ED None This publication contains information in summary form and is therefore intended for general guidance only. It is not intended to be a substitute for detailed research or the exercise of professional judgment. Neither Ernst & Young LLP nor any other member of the global Ernst & Young organization can accept any responsibility for loss occasioned to any person acting or refraining from action as a result of any material in this publication. On any specific matter, reference should be made to the appropriate advisor. YTG YEARS OF EXCELLENCE IN PROFESSIONAL SERVICES EY refers to the global organization, and/or one or more of the independent member firms of Ernst & Young Global Limited