Principles

MISSION

The primary mission of the Copenhagen CHARTER on Fraud and Corruption is to deliver independent and integrated certification and recommendations to its members and stakeholders.

This is achieved in several ways, depending on the organizations and its current phase, situation and requirements. Our primary focus will be on disseminating knowledge and information on corruption and fraud intelligence through awareness, detection, and investigative functions.

The secondary mission is to enable the management of participating companies and organizations to prevent, identify and manage the risk of fraud, theft and corruption, as well as internal irregularities within the organization.

OBJECTIVES

The core objective is related to the managing of the fraud and corruption risks and deviations. We focus on incidents and related material (internal) issues and irregularities for identified problem areas in the Member Company or Organization.

The secondary objective is to recommend how to be proactive, effective and efficient in the areas that are of interest and importance to the member companies and organizations:

• Develop and implement processes and procedures that will assist with the detection of fraud risks and incidents in a timely manner
• Develop and implement ongoing fraud risk awareness, training and communication programs and campaigns that will result in staff awareness and the effective prevention of such incidents
• Prioritize, investigate and report on the identified and reported international incidents with the aim of establishing the material facts, collating the relevant evidence and recommending appropriate actions
• Liaise with the appropriate criminal and regulatory law enforcement authorities in order to facilitate the institution of appropriate criminal action
• Liaise with the significant internal parties to ensure that the reputational risk to its members of such fraud issues and incidents is minimized
• Implement measures in the recovery of stolen assets
• Provide integrated intelligence on the risk of fraud, theft, corruption and associated irregularities to all stakeholders.

The primary value adding objectives in respect of managing the risk of incidents of fraud, theft, corruption and material internal irregularities, we will provide with recommendation for the development and provisioning of;

• Advice on how to create and maintain a control environment that will reduce and control such incidents
• Best Practice Notes, Standards and Guidelines for Fraud Investigations
• Detailed processes and procedures adopted by Its members for achieving these core and value-add objectives is set out in the following documents:
• Assistance to the members to leverage the specialist expertise in forensic audits
• Report integrated intelligence on the risk of fraud, theft, corruption and associated internal irregularities
• Procedures and Policies on Fraud, Bribery and Dishonesty

RESOURCING

We can provide ad hoc project management solutions together with the internal resources of the member companies and organization. Specialist services to any member of The Copenhagen Charter in case of an emergency, will receive top priority.

When members seek to source services from external service providers, we will provide a recommendation, focused and industry specific specialist investigative service providers.

Our relationships with external experts will be governed by appropriate legal documentation, which includes confidentiality undertakings, also for 3rd party engagements.

ACCOUNTABILITY

The Copenhagen Charter organization will discharge their duties, and will be accountable to its members and stakeholders:

• Report significant issues related to the processes for managing fraud risk, including recommending improvements to those processes, and providing information concerning such issues through active engagement and with the view to constructive resolution
• Periodically provide information on the status and results of the annual anti-fraud strategic plan.
• Co-ordinate the activities of different departments with other control and monitoring functions in the organization (including compliance, legal, company secretary, internal and external audit, risk management).

INDEPENDENCE

To provide for the independence required in terms of its role, Copenhagen Charter personnel report to the Board of Directors.

The Copenhagen Charter personnel will have unrestricted access to the Managing Director and Chairman of the Audit, Risk or Compliance Committee.
The Audit, Risk and Compliance Committee will:

• Approve the overall Corruption and Fraud Charter
• Approve the strategy and related plan for the year
• Receive quarterly communications from the Copenhagen Charter Managers on the results of their corruption or fraud investigation activities or other matters that they determine necessary, including private meetings without Executive Management present
• Make appropriate inquiries to determine whether there are scope restrictions or budgetary limitations that impede the ability to execute their responsibilities.

FUNCTIONS AND RESPONSIBILITIES

The specific responsibilities are detailed in the Best Practice Notes, Standards and Guidelines for Corrruption and Fraud Investigations.

Where investigations are conducted that involve allegations relating to any senior manager, written notifications setting out the nature of these allegations will be sent to the Board or the audit committee.

The scope of such investigations and formal reports will be issued in a confidential manner once such investigations are completed.

AUTHORITY

The Copenhagen Charter staff must be authorized to:

• Member organization will allocate resources, set frequencies, select subjects, and determine the scope of work of investigations and fraud risk assessments without intervention or restriction from the staff of its business units.
• Have full and free access to the information and personnel required to conduct or institute investigations and corruption and fraud risk assessments on the initiative of its member. Apply the techniques required to accomplish its functions and responsibilities as set out in this Charter and the approved Best Practice Notes, Standards and Guidelines for Fraud Investigations
• Have unrestricted access to all Its members functions, records, property, and personnel;
• Obtain the necessary assistance from staff in Business Units of its members, as well as from other specialized services from within or outside its members.

MANAGEMENT RESPONSIBILITY

When an investigation, audit or an incident is under investigation, Its members must report related or suspected incidents of fraud, theft, corruption and dishonesty involving staff as soon as they have a reasonable suspicion that such an incident has occurred.

Similarly, the member must report all suspected incidents of fraud, theft, corruption and dishonesty of a claims related nature involving suppliers, third parties involved and brokers.

Management must provide unrestricted access to all functions, records, property, and personnel, and facilitate the necessary assistance, co-operation and support in this regard to enable the investigation to be conducted in a proper and professional manner and fulfill their functions and responsibilities in terms of this Charter.

STANDARDS OF PROFESSIONAL CONDUCT

All investigations, forensics and audits will be carried out in accordance with the Copenhagen Charter Code of Ethics which is based on the Code of Professional Standards and the Code of Professional Ethics of the Association of Certified Fraud Examiners.