report that their financial impact of all fraud, corruption and/or money laundering incidents is over per incident

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Week of Integrity 2017 1 9 December 2017 Results Integrity Management survey 90% of respondents consider the risk of bribery/corruption and fraud applicable to their business 73% of respondents report that their financial impact of all fraud, corruption and/or money laundering incidents is over 25.000 per incident

The Compliance & Integrity Survey provides insight in awareness and the level of integrity Week of Integrity Survey EY & ICC Publication Factsheet An initiative of the International Chamber of Commerce Netherlands (ICC) to raise awareness and promote ethical behaviour in both the workplace and in the boardroom To gain insight in the level of integrity awareness in organizations. Identify actual integrity risks organizations are facing in different industries and sectors The survey was distributed to (compliance) professionals working in both the public and private sector and included a wide range of questions covering integrity and compliance elements In this factsheet we report on primary results of the survey Participants Private sector Public sector Public sector 5% Private sector 95% Financial sector 46% Non-financial sector 54% Government 33% Semi-Government 67% 53% of the respondents are Compliance Officers

Integrity and compliance remain of crucial and increasing importance for organizations 96% of respondents indicate that integrity risks are evaluated in their organization 84% of respondents indicate that the risk assessment leads to appropriate mitigating measures 85% of respondents indicate that there is an integrity training program in place for the employees in their organization Most applicable integrity risks to business recognized by respondents 90% 90% 90% 95% 48% 50% 52% 60% 65% 5% Other Terrorism Financing Fiscal fraud Market manipulation Sanctions Money Laundering Bribery and Corruption Internal / Socially External fraud unacceptable behaviour Conflict of Interest

Integrity breaches and incidents are on top of mind of the respondents of the survey 85% of respondents have faced a (suspicion) of fraud, corruption or money laundering My company has an incident management process in place The respondents indicated 58 integrity incidents per year on average. However, there was one respondent who noted that he faces 4.000 incidents a year Yes 84% No 16% 8% 34% Most common integrity breaches 37% Other External fraud Interpersonal misconduct 42% Data leakage 45% 61% Internal fraud Policy breaches 60% view the number of incidents over time as stable taking into account current cases of fraud, corruption and/or money laundering

There is a huge opportunity to use Data Analytics in compliance control 48% of respondents do not use data analytics on a regular basis to assess integrity risks 54% of respondents indicate that their organization uses data analytics to monitor the effectiveness of compliance controls Data components captured to monitor effectiveness of integrity framework 75% 75% Customer data Data extracted from general ledger 88% 88% Travel & entertainment expenses Transaction data The outcome of the survey and the increasing pressure from both regulators and Boards of Directors will require management to demonstrate an effective compliance program which includes antifraud, bribery and corruption initiatives. Effective and efficient solutions are needed to gain insight in the ever-increasing amount of structured- and unstructured data that companies are generating nowadays. The use of data science can allow a more timely and thorough response. More crossreferential insights can be given by using a variety of statistical and visual techniques from modelling, machine learning, and data mining that analyze current and historical facts. These drive useful insights into potential patterns and behavioral trends that were not previously apparent. The use of data science can optimize compliance programs and transaction monitoring activities. Besides that, it is cost efficient since it reduces manual intervention. This approach should enable companies to further confidently expand their business operations taking into account the relevant Financial Economic Crime risks.

Integrity risks are hard to detect, but can cause significant impact to organizations Any (international) operating organisation may face integrity risks often unintentional and sometimes even unknown to management. These may remain unidentified due to a lack of transparency. An event, related to these integrity risks may end up in financial losses, loss of clients or even damage to the reputation of the organisation and its management. This can harm the organization and in some cases it may result in serious trust issues with your stakeholders. Geographical risk Client Risk Transaction / product risk Your starting point should be a proper risk assessment, in which the different integrity risks are assessed, taking into account multiple risk factors. Third party / agent risk Employee risk Does this apply to me? Some key questions to find out: System / data risk 1. Are we operating on an international level? 2. Are we active in countries with an increased risk for sanctions, bribery or money laundering? 3. Do we know the key facts and circumstances of our buyers and suppliers or other parties involved in the process? 4. How are my systems and (client) data protected? By identifying the key risks it is possible to define mitigating measures which should help you to prevent these risks, such as: Policies and procedures, including sanctions policy framework Transaction filtering and monitoring Due diligence on third parties Incident management process Whistleblowing policy Employee training and awareness System security controls Data analytics / data science

Feel free to contact us! Michelle Fisser Senior Manager + 31 6 21 25 18 31 Michelle.Fisser@nl.ey.com Dirk de Hen Executive Director + 31 6 29 08 38 05 Dirk.de.Hen@nl.ey.com Marijke Wolfs Director ICC Netherlands Initiator & Organizer Week of Integrity Wolfs@icc.nl ICC Netherlands is part of ICC The world business organization, the largest business organization in the world with more than 6.5 million members in 134 countries. ICC, established in 1919 by entrepreneurs, promotes rule based trade and investment. The Week of Integrity is an initiative of ICC Netherlands. ICC has been a pioneer in the fight against corruption, issuing its first version of the ICC Rules of Conduct to combat Extortion and Bribery in 1977. ICC is at the forefront of the development of ethics, anti-corruption and corporate responsibility advocacy codes and guidelines, providing a lead voice for the business community in this rapidly changing field. www.icc.nl www.weekofintegrity.nl 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. About EY s Fraud Investigation & Dispute Services Dealing with complex issues of fraud, regulatory compliance and business disputes can detract from efforts to succeed. Better management of fraud risk and compliance exposure is a critical business priority no matter the size or industry sector. With over 4,500 fraud investigation and dispute professionals around the world, we will assemble the right multidisciplinary and culturally aligned team to work with you and your legal advisors. We work to give you the benefit of our broad sector experience, our deep subject matter knowledge and the latest insights from our work worldwide. 2017 EYGM Limited. All Rights Reserved. EYG no: 04005-172GBL ED None This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax or other professional advice. Please refer to your advisors for specific advice.