Anti-Fraud and Corruption

Transcription

1 NEC Version: 3.0 Date: 1 Aug 2016 Author: W. Woon Internal Use Only

2 Contents 1. Introduction Commitment Risk management and benefits Scope 3 2. Basic Policies Zero tolerance of fraud and corruption Ethical and responsible behaviour at all times Maintain a culture of honesty, integrity and accountability Awareness of the types of fraud Responsibility for reporting fraud and other irregularities Delegations Governance & support Implementation... 4 Document ID: NEC Issue 3 Internal Use Only Page 2 of 6

3 1. Introduction 1.1 Commitment NEC Australia recognises that the success of the company is dependent on the commitment and ethical conduct of all employees. NEC s business reputation is one of honesty and integrity, and we expect the best from our employees. One of the most critical challenges the organisation faces is preventing losses caused by unethical, illegal and irresponsible acts of employees. NEC Australia is committed to the highest possible standards of openness, probity and accountability in all its affairs. NEC Australia is determined to maintain a culture of honesty and opposition to fraud and corruption. This Anti-Fraud Programme is designed to establish procedures and measures for NEC Australia and its employees for fraud and corruption prevention strategies. 1.2 Risk management and benefits This Anti-Fraud Policy is to define NEC Australia s position and commitment against fraud and corruption practices and to prevent unethical employees behaviour in business dealings with, or on behalf of the company. 1.3 Scope This policy complements the NEC Code of Conduct and applies to all Business Groups of NEC Australia. If required, investigative activity will be conducted without regard to employee s length of service, position/title, or relationship. 2. Basic Policies 2.1 Zero tolerance of fraud and corruption NEC Australia s attitude towards fraud and corruption is Zero Tolerance 2.2 Ethical and responsible behaviour at all times NEC Australia recognises that the success of the company is dependent on the commitment and ethical conduct of all employees. NEC s business reputation is one of honesty and integrity, and we expect the best from our employees. One of the most critical challenges the organisation faces is preventing losses caused by unethical, illegal and irresponsible acts of employees. All employees (including contractors and agents) are expected to behave ethically and responsibly at all times during business dealings with or on behalf of NEC Australia. Document ID: NEC Issue 3 Internal Use Only Page 3 of 6

4 2.3 Maintain a culture of honesty, integrity and accountability NEC Australia is committed to the highest possible standards of openness, probity and accountability in all its affairs. NEC Australia is determined to create and maintain a culture of honesty and opposition to fraud and corruption. 2.4 Awareness of the types of fraud Each employee should be aware and be familiar with the types of fraud that might occur within his or her area of responsibility and be alert for any indication of irregularity. Refer to NEC-SP for programme information and guidelines. 2.3 Responsibility for reporting fraud and other irregularities All employees (including contractors and agents) are responsible for reporting incidents of theft, misappropriation, and other irregularities that may occur in their area of work or in the company. Refer to NEC for Whistleblowing Policy 3. Delegations 3.1 Governance & support The General Counsel is responsible for the: o o o Development and maintenance of this Policy Administration of the Anti-Fraud Programme Analysis and investigation of all reported incidents and consulting with Senior Management regarding appropriate resolutions 3.2 Implementation Employees All NEC Australia s employees (including contractors and agents) are responsible for detecting theft, misappropriation, and other irregularities that may occur in the organisation. Each employee should be familiar with the types of fraud that might occur within his or her area of responsibility and be alert for any indication of irregularity. Refer NEC-SP Programme. Document ID: NEC Issue 3 Internal Use Only Page 4 of 6

5 Document Information Criteria Document Title Document Owner File Name Details Legal & Risk Compliance NEC Amendment History Version Date Description Author 1b 18/7/2008 Previously published as part of A. McLeish 2 15/4/2013 Update policy to include NEC IT Solutions and reissued under new companywide structure 3 1/8/2016 Policy due for review after 3 years. Update to new Policy template and Annex-B. No changes made to basic policies. Changed MD to current COO title. W. Woon W. Woon Review and Approval Role Name & Position Title Digital Signature Originator Wilson Woon Senior Manager Risk & Compliance Office Reviewer Paul Reed General Manager Legal & Risk Compliance Approver Mike Barber Chief Operating Officer NEC Australia Pty Ltd Document ID: NEC Issue 3 Internal Use Only Page 5 of 6

6 Reference Material Reference NEC NEC Details NEC Code of Conduct Whistleblowing Policy Acronyms NEC/J NEC/A Description NEC Corporation, Japan NEC Australia Terms NEC Australia Fraud Description All sites and offices of NEC Australia, irrespective of ABN s or geographical locations Dishonest activity causing actual or potential financial loss to any person or entity including theft of moneys or other property by employees or person external to the entity and where deception is used at the time, immediately before or immediately following the activity. This also includes the deliberate falsification, concealment, destruction or use of falsified documentation used or intended for use for a normal business purpose or the improper use of information or position for personal financial benefit. Corruption Dishonest activity in which a director, executive, manager, employee or contractor of an entity act contrary to the interests of the entity and abuses his/her position of trust in order to achieve some personal gain or advantage for him or herself or for another person or entity. The concept of Corruption can also involve corrupt conduct by the entity, or a person purporting to act on behalf of and in the interests of the entity, in order to secure some form of improper advantage for the entity either directory or indirectly. Copyright 2016 NEC Australia Pty Ltd: This document is protected by the Australian Copyright Act 1968 and International laws of copyright. Do not copy, distribute or modify in any form or manner without prior written consent of NEC Australia. Classification: The information contained herein is classed as Internal Use Only Version Control: The document is maintained and published on the NEC intranet for reference. Printed copies are uncontrolled Document ID: NEC Issue 3 Internal Use Only Page 6 of 6