Policy 2.3.11: Fraud and Theft

Effective: April 1, 1999
Responsibility: Vice-President and Chief Financial Officer

STATEMENT OF POLICY

  1. The term fraud and theft usually refers to acts committed with the intent to deceive and/or conceal the misappropriation of assets, or for other purposes including personal gain. It could involve:
  • The misappropriation of assets
  • The intentional misrepresentations of expense claims and/or purchases of goods and/or services
  • The misrepresentation of financial information
  1. It is the responsibility of all employees and managers:
  • To ensure the safety and security of CBC/Radio-Canada property through the establishment and maintenance of adequate internal controls appropriate to their functions and areas of responsibility;
  • To immediately report to their supervisor and Senior Financial Officer and assist in the investigation of all losses of CBC/Radio-Canada property.

Investigations of suspected acts of fraud or theft are to be conducted in strict confidence, under the guiding principle of presumed innocence.

At the discretion of senior management, those found to be directly responsible for fraud or theft will be subject to any or all of the following:

  • The requirement to make full restitution of all direct and related costs;
  • Prosecution to the full extent of the law;
  • Discipline that may include termination of employment with the CBC/Radio-Canada.

Finance and Administration is responsible for the coordinating of investigations, reporting of findings and making recommendations to senior management on the implementation of controls to prevent future occurrence.

Investigations may include the participation of representatives from Finance and Administration, the Law Department, Internal Audit, local management, Human Resources and any other resources deemed necessary.

HISTORY

  • This policy was updated November 2003.
  • This was originally Corporate Finance and Administration Policy 104.10 - Fraud and Theft.


REFERENCES

Corporate Policy:
2.2.3 - Conflict of Interest and Ethics


PERSON RESPONSIBLE FOR INTERPRETATION AND APPLICATION

All questions pertaining to the interpretation or application of this policy should be referred to the Director, Policy and Internal Control.

DEPARTMENT RESPONSIBLE TO UPDATE THIS WEBPAGE

Corporate Secretariat.

APPENDIX A
Detailed Instructions

1. APPARENT FRAUD OR THEFT BY CBC/RADIO-CANADA PERSONNEL

1.1 Immediate Action

Once it has come to the attention of supervisors that there has been an apparent fraud or theft by a CBC/Radio-Canada employee, which may also have been discovered as a result of an audit review, they must review the facts and report them to their line manager.

The manager and/or auditor is required to advise the local senior financial officer, who will:

  • Immediately form and chair an investigation committee comprised of representatives from:
    • CBC/Radio-Canada Law Department
    • Human Resources, and when appropriate, Industrial Relations
    • Audit Department
    • Local Management
  • Convene an urgent meeting, either in person or by telephone, and prepare a brief report of the matter.
  • Inform the local police, as required, following advice from the investigation committee.
  • Inform the senior location officer (VP or Regional Director) and the Vice President and Chief Financial Officer of the facts, actions taken and planned.
  • Inform the Senior Director, Strategic Initiatives and Resource Planning of minimum details in preparation for a possible insurance claim.

The Vice President and Chief Financial Officer will advise the appropriate Senior Vice-Presidents.

1.2 Further Action

The investigation committee will review the facts and gather more information as required and advise the senior financial officer on recommended course(s) of action, including:

  • Informing the local police
  • Suspending the employee with or without pay
  • Cancelling all delegation of authorities of the employee involved
  • Cancelling passwords, collecting keys and credit cards
  • Further investigation work
  • Calendar of future action

The senior financial officer will, where applicable, send preliminary and final reports to the:

  • Senior location officer
  • Vice President and Chief Financial Officer
  • VP Human Resources
  • Internal Audit department
  • Law Department
  • Senior Director, Strategic Initiatives and Resource Planning


2. APPARENT FRAUD OR THEFT BY OTHERS

2.1 Immediate Action

Once it has come to the attention of supervisors that there has been an apparent fraud or theft by persons other than CBC/Radio-Canada employees, which may also have been discovered as a result of an audit review, they must review the facts and report them to their line manager.

The manager and/or Auditor is required to advise the local senior financial officer, who will:

  • Immediately form and chair an investigation committee comprised of representatives from:
    • CBC/Radio-Canada Law Department
    • Internal Audit
    • Local Management
  • Convene an urgent meeting, either in person or by telephone, and prepare a brief report of the matter.
  • Inform the local police, as required, following advice from the investigation committee.
  • Inform the senior location officer (VP or Regional Director) and the Vice President and Chief Financial Officer of the facts, and actions taken and planned.
  • Inform the Senior Director, Strategic Initiatives and Resource Planning of minimum details in preparation for a possible insurance claim.

The Vice President and Chief Financial Officer will advise the appropriate Senior Vice-Presidents.

2.2 Further Action

The investigation committee will review the facts and gather more information as required and advise the senior financial officer on recommended course(s) of action including:

  • Further investigation work
  • Calendar of future action

The senior financial officer will, where applicable, send preliminary and final reports to:

  • Senior Location Officer
  • Vice President and Chief Financial Officer
  • Internal Audit
  • Law Department
  • Senior Director, Strategic Initiatives and Resource Planning

3. SUPPLEMENTARY ACTIVITIES (BOTH CATEGORIES)

These will result from directives issued by the Vice President and Chief Financial Officer.

The Senior Director, Strategic Initiatives and Resource Planning will:

  • Ensure that insurance claims have been filed, where applicable.
  • Report the incident to the RCMP, Ottawa (as required for their statistics).

The Director, Policy and Internal Control will review local internal control policies and practices with the senior financial officer to preclude any recurrence.

4. RESPONSIBILITY OF SENIOR OFFICERS

Local senior finance and administration officers will:

  • Be responsible for coordinating the investigation of reports of suspected incidents of fraud or theft in their locations, and for reporting the findings and recommendations of the investigating committee.
  • Ensure that the necessary co-ordination, actions, and reporting take place within a reasonable time.
  • Ensure that investigations are conducted in strictest confidence
  • Provide access to related financial records required by the committee, and retain information and files resulting from the investigation.
  • Ensure that recommended controls designed to prevent a recurrence of the specific situation under investigation, and incidents of fraud and theft in general, are implemented.
  • Ensure that local CBC/Radio-Canada employees and managers are aware of their responsibilities with respect to policies on fraud and theft.

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