THE COPENHAGEN COMPLIANCE® CODEX on Bribery Fraud and Corruption

MISSION

The primary mission of the Copenhagen Codex on Bribery, Fraud and Corruption (BFC) is to deliver independent and integrated certification and recommendations to its members and stakeholders.

The secondary mission is to enable the management of participating companies and organisations to prevent, identify, and manage the risk of bribery, fraud, theft, and corruption and address internal irregularities within the organisation.

OBJECTIVES

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

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 organisations:

OBJECTIVES

The codex provides you with recommendations for the development and provisioning of;

• Develop and implement processes and procedures that will assist with promptly detecting fraud risks and incidents.
• 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
• Prioritise, investigate and report on the identified and reported international incidents to establish the material facts, collate the relevant evidence and recommend appropriate actions.
• Liaise with the appropriate criminal and regulatory law enforcement authorities to facilitate the institution of proper criminal action.
• Liaise with significant internal parties to minimise the reputational risk to its members of such fraud issues and incidents.
• Implement measures in the recovery of stolen assets
• Provide all stakeholders with integrated intelligence on the risk of fraud, theft, corruption and associated irregularities.
• Advice on how to create and maintain a controlled 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 are 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

ACCOUNTABILITY

The Copenhagen Compliance organisation will discharge their duties and be accountable to its members and stakeholders, incl. processes, update of the annual anti-fraud strategic plan and coordination of BFC activities.

The Copenhagen Codex accountability incl. processes, an update of the annual anti-fraud strategic plan and coordination of BFC activities.

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

INDEPENDENCE

To provide for the independence required in its role, Copenhagen Codex personnel report to the Board of Directors and will have unrestricted access to the Managing Director and Chairman of the Audit, Risk or Compliance Committee, should the need arise.

Copenhagen Compliance Codex personnel report to the Board of Directors to provide the independence required.

We believe that independence is a condition for successful certification that provides value to the Board, management and the entire organisation. We will work closely with The Audit, Risk or Compliance Committee and make sure that the platform of our independence includes the following:

• Approve the overall Corruption and Fraud Codex
• Approve the strategy and related plan for the year
• Receive quarterly communications from the Copenhagen Codex 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 scope restrictions or budgetary limitations impede the ability to execute their responsibilities.

FUNCTIONS AND RESPONSIBILITIES

The functions and responsibilities of the codex must be detailed in the Best Practice Notes, Standards and Guidelines for Corruption and Fraud Investigations. Where investigations involving allegations relating to any senior manager are conducted, written notifications of the nature of these allegations will be sent to the Board of directors or the audit committee.

AUTHORITY

To achieve actual value and integrated improvements, we suggest that The Copenhagen Compliance Codex is certified to, depending on the circumstances and situation to:

Based on our experience, actual value and integrated improvements, depending on the circumstances and situation, are achieved when:

The Copenhagen Compliance Codex on BFC can recommend allocating resources, setting frequencies, selecting subjects, and determining the scope of work of investigations and fraud risk assessments without intervention or restriction from the staff of its business units. However, further to improve on Detection and Recovery, we should:

• Cover full and unrestricted access to the information and personnel required to conduct or institute investigations and corruption and fraud risk assessments on the initiative of its members.
• Apply the techniques required to accomplish its functions and responsibilities in this Codex 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 the Business Units of its members and other specialised services from within or outside its members.

The scope of such investigations and formal reports will be issued confidentially once such studies are completed.

TRANSPARENCY

MANAGEMENT RESPONSIBILITY

Management must provide unrestricted access to functions, records, property, and personnel and facilitate the necessary assistance, co-operation and support in connection with the certification process if there is a requirement for additional efforts other than self-assessment.

When an investigation, audit or incident is under investigation, members must report related or suspected incidents of fraud, theft, corruption and dishonesty involving staff in connection with the certification process.

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

Management must provide unrestricted access to all functions, records, property, and personnel and facilitate the necessary assistance, co-operation and support to enable the investigation to be conducted professionally and adequately and fulfil their functions and responsibilities in this Codex.

RESOURCING

Our recommendations on BFC are focused and based on our co-operation with industry-specific specialist investigative service providers. Our relationships with external experts is governed by appropriate legal documentation and confidentiality undertakings for 3rd party engagements. We provide ad hoc project management solutions that can work together with your internal resources. Specialist services in case of an emergency/crisis will receive top priority.

STANDARDS OF PROFESSIONAL CONDUCT

All investigations, forensics and audits will follow the Copenhagen Codex Code of Ethics based on the Global Code of Professional Standards and Ethics.

Contact us for additional information on the above Principles and codex on Bribery, Fraud or Corruption Certification issues.