XYZ - Business Ethics Training - English Version

Pre-requisites to the Training Session
► Please avoid the following during the presentation
1. Use of Mobile phones (Switch off / Silent mode)
2. Leaving the presentation area
3. Talking amongst yourselves
4. Tea / Coffee / Cigarette breaks
► Your attendance will be recorded & monitored.
Page
22 May,
1 2008 Page 1 XYZ - Awareness
Fraud Business Ethics
and Business
Training
Ethics Training
XYZ Company
Business Ethics Training

2011
Agenda
► Business Ethics
► Fraud
► Common Red Flags
► Fraud Facts
► Fraud Awareness
► Code of Ethics
► Violations
► Elements of the Code of Ethics
Page
22 May,
and Business
Training
Ethics Training
What are Business Ethics?
► Business Ethics or Corporate Ethics examines the Ethical Principles

and Moral or Ethical Problems that arise in a Business Environment.
► Business Ethics drive in determining What is right and What is

wrong in Business Decision Making.
► Ethical decision making is involved with maintaining the right Ethical

and Moral Values.
► What is moral is what you feel good after, and what is immoral is
what you feel bad after.
- Ernest Hemingway
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22 May,
and Business
Training
Ethics Training
Business Ethics (Cont’d)
How will Business Ethics ensure economic and organizational growth?
Business Ethics is an iterative process, Developing an organizations Values and

Beliefs leads to building of Trust enabling the human capital to become Social Capital
ultimately leading to Economic growth . Compliance requirements will always call for
a more stringent and strict enforcement of organizational Business Ethics Program.
Source : Business Ethics – US Department of Commerce
Page
22 May,
and Business
Training
Ethics Training
Business Ethics (Cont’d)
Why are Business Ethics so important for any

organization?
8 practical reasons why businesses should embrace a
business ethics program.
Business Ethics will ensure
1. Enhanced reputation & Goodwill 5. Enhanced performance, productivity
& competitive position
2. Reduced risks 6. Expanded access to capital, credit &
foreign investment
3. Reduced costs 7. Increased profits & sustained long
term growth
4. Protection from unethical employees 8. Increased International respect
and agents
Source : Business Ethics – US Department of Commerce
Page
22 May,
and Business
Training
Ethics Training
What is Fraud and What is Fraud
Awareness?
Fraud is defined as:
► In the broadest sense, a fraud is an intentional act for personal

gain.
► In organizational terms, a fraud is an attempt to deceive an

organization for personal gain or to cause financial / reputational
damage to an organization.
► Organizational Fraud is “White Collar Crime” and the damages are

significant. Lets look at some fast facts….
Page
22 May,
and Business
Training
Ethics Training
Fast facts about Fraud
► Companies across EMEIA have been struggling with a significant

increase in fraud, bribery and corruption, according to EY’s 11th
Global Fraud Survey. In western Europe, the number of companies
that had experienced a significant instance of fraud in the past two
years increased from 10% to 21%. Fraud levels also remain high in
the Middle East and Africa (18%).
► The Association of Certified Fraud Examiners (ACFE) estimates

that fraud cost the United States more than $994 billion in 2008,
which is up from its estimate of $652 billion in 2006. In comparison,
U.S. Department of Justice estimates that $18.4 billion was lost in
2006 due to violent crime.
Page
22 May,
and Business
Training
Ethics Training
Fraud Awareness
► While no organization is free from fraud, but steps can be taken to

prevent the possibility of fraud and to avoid loss.
► A three-step approach of Training, Understanding Fraud and

Consequences of Fraud, should be established to prevent the
possibility of fraudulent acts.
► A fraudulent act is typically associated with a pressure to commit the

act, a perceived opportunity to get away with the act, and an attitude
that rationalizes the act.
► XYZ is committed to the prevention and detection of fraud and

employees must report RED FLAGS.
Page
22 May,
and Business
Training
Ethics Training
Common types of Fraudulent Activities
► Altering amounts and details on documents
► Writing off recoverable assets or debts
► Unauthorized transactions
► Selling confidential information
► Altering sales records, receipts etc
► Bank cheques issued to false persons
Page
22 May,
and Business
Training
Ethics Training
Common types of Fraudulent Activities
(Cont’d)
► Stealing cash
► Unrecorded transactions
► Using imaging and desktop publishing technology to produce original

invoices
► Bribes
► Running a private business with company assets
Page
22 May,
and Business
Training
Ethics Training
What is a “Code of Ethics”
► According to the International Federation of Accountants, Code of

Ethics are:
“Principles, values, standards, or rules of behavior that guide the
decisions, procedures and systems of an organization in a way that:
(a) contributes to the welfare of its key stakeholders, and

(b) respects the rights of all constituents affected by its
operations.”
Source: International Federation of Accountants (2009)
Page
22 May,
and Business
Training
Ethics Training
Why is the Code of Ethics important for
XYZ ?
► Help in aligning XYZ ’s Mission with its core values of ethically doing
the right thing, the right way, all the time and every time
► Help the employees in better understanding their jobs and ethically
taking the right decisions
► Guide employees towards doing the right thing in everyday work
► More socially responsible organization
► Establish a better corporate work ethics culture
► Improve XYZ 's public image
► To minimize the risk of white collar crime
Page
22 May,
and Business
Training
Ethics Training
Code of Ethics Violations & its effects on
Employees and Employers
► Wellpoint Inc, A US based health insurance company asked their CFO, David
Colby to leave the company after he violated a Wellpoint Code of Ethics. The
shares prices fell 3.5% and Colby ended up losing $1.6 million and a job.
► Beazer Homes, A US based construction company fired their Chief

Accounting Officer for violating the Confidentiality of data clause in their Code
of Ethics. Stock prices for Beazer fell 10% because of this news.
► Shell Oil’s US based logistics subsidiary firm bribed officials in Nigeria,

Kazakhstan & Saudi Arabia and is being investigated by the US Department
of Justice for violations of “Conflicts of Interest’
Page
22 May,
and Business
Training
Ethics Training
Actions taken by XYZ to implement the Code
of Ethics
► XYZ is taking the following steps to create an ethical culture in the
work place:
1.Develop the Corporate Code of Ethics
2.Assigning a Compliance Officer for the Code of Ethics compliance
3.Compliance letter (To be signed by all employees)
4.Code of Ethics & Fraud Awareness training
► The Compliance Officer is responsible for implementation and

compliance with Code of Ethics in XYZ
Page
22 May,
and Business
Training
Ethics Training
A Code of Ethics Manual is a guidance for all XYZ employees
to understand “What’s acceptable and What’s not”
• Refer to Code of Ethics booklet for detailed guidance
• Rules exist for a reason……. If you are not sure … Ask your Manager
Page
22 May,
and Business
Training
Ethics Training
Contents of XYZ Code of Ethics
Whistle Blowing
Personal Conduct
Compliance with Law
and Regulations
Confidentiality,
Administration &
Occupational Disclosure of
Health and Safety Information
XYZ
Code of Ethics
Gifts and
Internal Hospitality
Communications
Policies &
Procedures including Conflict of Interest
Delegation of
Authority
Supplier
& Customer
Relationships
Page
22 May,
and Business
Training
Ethics Training
1. Personal Conduct
Whistle Blowing
Personal Conduct
Compliance with Law
and Regulations
Confidentiality,
Administration &
XYZ
Code of Ethics
Gifts and
Communications
Policies &
Delegation of
Authority
Supplier
& Customer
Relationships
Page
22 May,
and Business
Training
Ethics Training
Personal Conduct
► Personal Conduct is a standard of personal behavior especially based on

moral principles.
► Keep in mind Integrity, Unbiased Judgment and Independence while

performing your duties at XYZ
► Personal Conduct is a key to success
► Always do the right thing even if it doesn’t have any

personal gain
Page
22 May,
and Business
Training
Ethics Training
Do’s
of Personal Conduct
► Refuse to engage in and avoid unethical or inappropriate behavior at all
times
► Protect all company assets against theft, loss or misuse
► Follow your local dress code at work
► Follow office timings
► Consult your manager or HR function if you are facing

personal / financial problems
Page
22 May,
and Business
Training
Ethics Training
Don’ts
of Personal Conduct
► Use XYZ assets & facilities for personal purposes
► Use your position or employment for personal gain
► Lie to avoid difficult situations
► Say one thing and do another
► Give up in pressure situation (Always consult seniors)
Page
22 May,
and Business
Training
Ethics Training
2. Confidentiality, Administration & Disclosure of
Information
Whistle Blowing
Personal Conduct
Compliance with Law
and Regulations
Confidentiality,
Administration &
XYZ
Code of Ethics
Gifts and
Communications
Policies &
Delegation of
Authority
Supplier
& Customer
Relationships
Page
22 May,
and Business
Training
Ethics Training
Confidentiality, Administration & Disclosure
of Information
► Confidentiality is the act of keeping Confidential data confidential.
Confidential data is any data meant to be kept secret with certain individual
or group of people
► Managing Confidential data like business strategy, product pricing etc is

known as Administration of confidential data
► Protecting XYZ ’s confidential data and not revealing sensitive information

to third parties without XYZ ’s consent is known as Disclosure of Information
Page
22 May,
and Business
Training
Ethics Training
Do’s
of Confidentiality, Administration & Disclosure of Information
► Manage confidential records as required
► Take steps to prevent the loss of information
► Keep confidential data confidential
► Avoid to “Speak” before you “think”
Page
22 May,
and Business
Training
Ethics Training
Don'ts
of Confidentiality, Administration & Disclosure of Information
► Be irresponsible with confidential data
► Disclose confidential data to third parties
► Leave your workstation accessible to any one
Page
22 May,
and Business
Training
Ethics Training
3. Gifts and Hospitality
Whistle Blowing
Personal Conduct
Compliance with Law
and Regulations
Confidentiality,
Administration &
XYZ
Code of Ethics
Gifts and
Communications
Policies &
Delegation of
Authority
Supplier
& Customer
Relationships
Page
22 May,
and Business
Training
Ethics Training
Gifts and Hospitality
► Gifts should only be given where it is required to conduct business activity

ethically
► Valuable gifts and services should not be accepted / offered to gain undue
favors
► Gifts and hospitality for favors to / from XYZ should be reported discretely
to your seniors and Compliance Officer
Page
22 May,
and Business
Training
Ethics Training
Do’s
of Gifts and hospitality
► Ensure that any gifts received or offered does not influence
business decisions
► Keep an accurate record of all gifts & hospitality received or offered,

where offering / accepting gifts is an essential part of your job role
► Politely refuse to accept any inappropriate gifts compromising the

company’s policy
Page
22 May,
and Business
Training
Ethics Training
Don’ts
of Gifts and hospitality
► Accept gifts that are of an extraordinary value, If circumstances
justify to keep expensive gifts then seek approval from management
► Accept any gifts for favors in return
► Offer or accept any gift, entertainment and hospitality when

acceptance could influence the recipient
Page
22 May,
and Business
Training
Ethics Training
4. Conflicts of Interest
Whistle Blowing
Personal Conduct
Compliance with Law
and Regulations
Confidentiality,
Administration &
XYZ
Code of Ethics
Gifts and
Communications
Policies &
Delegation of
Authority
Supplier
& Customer
Relationships
Page
22 May,
and Business
Training
Ethics Training
Conflicts of Interest
► A Conflict of Interest is a situation where a person's decision is influenced

by his personal interest
► It is an act that is not in the best interest of the organization
Page
22 May,
and Business
Training
Ethics Training
Do’s
of Conflict of Interest
► Avoid situations where your personal interests conflict with XYZ ’s business
interests.
► Ensure that all your personal interests are lawful and free of conflicts.
► Disclose to your manager any potential or current Conflicts of Interest
Page
22 May,
and Business
Training
Ethics Training
Don’ts
of Conflict of Interest
► Conceal potential conflicts but notify and seek approval from your employer
► Create conflicts of interest for your personal or professional gain
Com
pa
Intere ny
sts
Perso
n
Intere al
sts
Page
22 May,
and Business
Training
Ethics Training
5. Supplier and Customer Relationship
Whistle Blowing
Personal Conduct
Compliance with Law
and Regulations
Confidentiality,
Administration &
XYZ
Code of Ethics
Gifts and
Communications
Policies &
Delegation of
Authority
Supplier
& Customer
Relationships
Page
22 May,
and Business
Training
Ethics Training
Supplier and Customer Relationships
► XYZ values its business relationships
► Know about XYZ ’s “Products and Services”
► “Know your customer” to maximize customer satisfaction
► Always do the “Right thing” to avoid Customer & Supplier dissatisfaction
Page
22 May,
and Business
Training
Ethics Training
Do’s
of Supplier & Customer Relationships
► Be honest , fair and professional
► Ensure the safety and security of Supplier’s & Customer’s products and
services
► Depart from anti-competitive activities related to Supplier’s and Customer’s
► Report any instances of collusion with regards to Customer or Supplier to

Compliance Officer
Page
22 May,
and Business
Training
Ethics Training
Don’ts
of Supplier & Customer Relationships
► Use information regarding Suppliers and Customers for personal gain
► Make promises you can’t keep
► Don’t overstep your authority when dealing with Suppliers & Customers
Page
22 May,
and Business
Training
Ethics Training
6. Adherence to Policies and Procedures &
Delegation of Authority
Whistle Blowing
Personal Conduct
Compliance with Law
and Regulations
Confidentiality,
Administration &
XYZ
Code of Ethics
Gifts and
Communications
Policies &
Delegation of
Authority
Supplier
& Customer
Relationships
Page
22 May,
and Business
Training
Ethics Training
Adherence to Policies and Procedures
including Delegation of Authority
► Policies and procedures are a set of guidelines for all employees to adhere,
as it provides a day to day guidance to fulfill your work obligations
► XYZ ’s management delegates authority to certain managers and

supervisors to undertake specific jobs effectively and efficiently
Page
22 May,
and Business
Training
Ethics Training
Do’s
of Policies & Procedures including Delegation of Authority
► Educate yourself on all XYZ ’s Policies and Procedures applicable to

your department
► Maintain a copy of policies and procedures for ready reference
► Seek clarification from your manager if you have any doubts about
policies and procedures
► Respect the company policies and procedures
► Clearly delegate work with Authority & Power where required
Page
22 May,
and Business
Training
Ethics Training
Don'ts
of Policies & Procedures including Delegation of Authority
► Criticize XYZ ’s policies and procedures
► Misinterpret the policies and procedures
► Make judgments without seeking managers advice on jobs that have specific
policies and procedures
Page
22 May,
and Business
Training
Ethics Training
7. Internal Communication
Whistle Blowing
Personal Conduct
Compliance with Law
and Regulations
Confidentiality,
Administration &
XYZ
Code of Ethics
Gifts and
Communications
Policies &
Delegation of
Authority
Supplier
& Customer
Relationships
Page
22 May,
and Business
Training
Ethics Training
Internal Communication
► Internal Communication includes memos, circulars, emails and

voice- calls to convey important information, changes in regulations
and management etc
► Internal Communication is used to update staff about day to day work

operations
► Internal Communication plays a key role in communicating XYZ ’s

Mission, Vision and Strategies
► Internal Communication helps

employees to understand their
jobs better and perform more effectively
Page
22 May,
and Business
Training
Ethics Training
Do’s
of Internal Communication
► Record and Maintain all internal communication with managers,
supervisors and subordinates
► Keep business communications timely and in a formal manner
► Make sure that you comply with XYZ ’s Internal Communications

Policy
► Think before you type
Page
22 May,
and Business
Training
Ethics Training
Don’ts
of Internal Communication
► Ignore Internal Communications…. If its being communicated its for a reason
► Misuse Internal communication mediums (Email, Telephone, Fax etc)
► Cause intentional damage to Internal Communication mediums
► Speak before you think
Page
22 May,
and Business
Training
Ethics Training
8. Occupational Health and Safety
Whistle Blowing
Personal Conduct
Compliance with Law
and Regulations
Confidentiality,
Administration &
XYZ
Code of Ethics
Gifts and
Communications
Policies &
Delegation of
Authority
Supplier
& Customer
Relationships
Page
22 May,
and Business
Training
Ethics Training
Occupational Health and Safety (OH&S)
► Occupational Health & Safety (OH&S) is concerned with protecting the health
and safety of XYZ employees
► Since XYZ employees are XYZ assets, the health and safety awareness
among XYZ employees is a key to success for XYZ
Page
22 May,
and Business
Training
Ethics Training
Do’s
of Occupational Health and Safety
► Follow and practice all health and safety guidelines
► Immediately notify managers regarding any hindrance to safe working

conditions
► Use all precautions to make the job safe and hazard-free
► Seek guidance from your seniors when in doubt
Page
22 May,
and Business
Training
Ethics Training
Don’ts
of Occupational Health & Safety
► Ignore health and safety issues
► Use faulty equipment
► Forget to consider the safety of others
► Take shortcuts to get the work done fast
Page
22 May,
and Business
Training
Ethics Training
9. Compliance with Laws and Regulations
Whistle Blowing
Personal Conduct
Compliance with Law
and Regulations
Confidentiality,
Administration &
XYZ
Code of Ethics
Gifts and
Communications
Policies &
Delegation of
Authority
Supplier
& Customer
Relationships
Page
22 May,
and Business
Training
Ethics Training
Compliance with Laws & Regulations
► Adherence to all applicable laws and regulations
► Compliance with laws and regulations is done to earn

the highest respect among Customers & Suppliers.
► Always doing the “Right thing” for compliance with laws

and regulations “at XYZ , for XYZ ”
Page
22 May,
and Business
Training
Ethics Training
Do’s
of Compliance with the Laws and Regulations
► Understand the applicable laws and regulations to your department
► Comply with XYZ policies and procedures (Including circulars from head
office)
► Ask your senior for advice about laws and regulations
Page
22 May,
and Business
Training
Ethics Training
Don’ts
of Compliance with the Laws and Regulations
► Disregard or break laws and regulations
► Take chances with the laws and regulations
► Find loopholes in laws and regulations to

avoid doing the “right thing”
Page
22 May,
and Business
Training
Ethics Training
10. Whistleblowing
Whistle Blowing
Personal Conduct
Compliance with Law
and Regulations
Confidentiality,
Administration &
XYZ
Code of Ethics
Gifts and
Communications
Policies &
Delegation of
Authority
Supplier
& Customer
Relationships
Page
22 May,
and Business
Training
Ethics Training
Whistleblowing
► Whistleblowing is a term to describe an action where someone in the

company notifies management about corporate misdeeds /
misconduct
► Whistleblowers can be anyone who reports violation of law &
regulations, direct / indirect threat to public / company interest, fraud,
health & safety violations and corruption
► Whistleblowing is confidentially reported to / investigated by a
Compliance Officer
Page
22 May,
and Business
Training
Ethics Training
Do’s
of Whistleblowing
► Keep calm, note down instances of corporate misconduct & report to
the Compliance Officer
► Keep an eye on suspicious activities
► Seek advice from the Compliance Officer
► Present an unbiased report of

what you saw, what violations were
committed and parties involved
Page
22 May,
and Business
Training
Ethics Training
Don’ts
of Whistleblowing
► Use a whistleblowing mechanism for addressing a personal
grievance
► Ignore obvious signs of corporate misconduct
► Start investigations by yourself
Page
22 May,
and Business
Training
Ethics Training
Whistle Blower Contact Form (page 17)
WHISTLE BLOWER FORM
Report ID: XXX - XX - XXX [System generated tracking number]
Comment:
Please add your comments here………
Whistleblower name and details:
Whistleblowers name and details for information purposes
S UBMIT FORM R ESET FORM
Comments should include the violations The Whistleblowers name and

committed, parties involved and any details will be maintained
other information that will be used to confidentially and not revealed to
take corrective action. any internal parties except the
Compliance Officer.
Page
22 May,
and Business
Training
Ethics Training
Employee participation – A key to success
► Employees are assets and the lifeblood for XYZ
► Employees are the key to success for the XYZ Code of Ethics program
► Love your job and follow the XYZ Code of Ethics
► Take ownership of your job and accept and abide by the XYZ ’s laws and
regulations
► Guide colleagues at work towards doing the right thing.
Page
22 May,
and Business
Training
Ethics Training
Employee participation – A key to success
► Questions to ensure compliance

► Will my actions fully comply with the applicable laws &
regulations and XYZ ’s policies and procedures?
► Could I explain my actions to my family?
► Do I need seek guidance or advice before acting?
►Where to find support

► Follow the chain of command
► Compliance Officer
Page
22 May,
and Business
Training
Ethics Training
Compliance Certificate
Page
22 May,
and Business
Training
Ethics Training
XYZ
- Code of Ethics and Fraud Awareness -
For A better employee &

A better company
Page
22 May,
and Business
Training
Ethics Training
Questions & Answers !!!
Page
22 May,
and Business
Training
Ethics Training
Thank You !!!!!!!!!

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Pre-requisites to the Training Session

► Please avoid the following during the presentation

1. Use of Mobile phones (Switch off / Silent mode)

2. Leaving the presentation area

3. Talking amongst yourselves

4. Tea / Coffee / Cigarette breaks

► Your attendance will be recorded & monitored.

Business Ethics Training

► Business Ethics or Corporate Ethics examines the Ethical Principles

► Business Ethics drive in determining What is right and What is

► Ethical decision making is involved with maintaining the right Ethical

How will Business Ethics ensure economic and organizational growth?

Business Ethics is an iterative process, Developing an organizations Values and

Why are Business Ethics so important for any

Fraud is defined as:

► In the broadest sense, a fraud is an intentional act for personal

► In organizational terms, a fraud is an attempt to deceive an

► Organizational Fraud is “White Collar Crime” and the damages are

► Companies across EMEIA have been struggling with a significant

► The Association of Certified Fraud Examiners (ACFE) estimates

► While no organization is free from fraud, but steps can be taken to

► A three-step approach of Training, Understanding Fraud and

► A fraudulent act is typically associated with a pressure to commit the

► XYZ is committed to the prevention and detection of fraud and

► Altering amounts and details on documents

► Writing off recoverable assets or debts

► Selling confidential information

► Altering sales records, receipts etc

► Bank cheques issued to false persons

► Using imaging and desktop publishing technology to produce original

► Running a private business with company assets

► According to the International Federation of Accountants, Code of

(a) contributes to the welfare of its key stakeholders, and

Source: International Federation of Accountants (2009)

► Beazer Homes, A US based construction company fired their Chief

► Shell Oil’s US based logistics subsidiary firm bribed officials in Nigeria,

1.Develop the Corporate Code of Ethics

2.Assigning a Compliance Officer for the Code of Ethics compliance

3.Compliance letter (To be signed by all employees)

4.Code of Ethics & Fraud Awareness training

► The Compliance Officer is responsible for implementation and

• Refer to Code of Ethics booklet for detailed guidance

► Personal Conduct is a standard of personal behavior especially based on

► Keep in mind Integrity, Unbiased Judgment and Independence while

► Personal Conduct is a key to success

► Always do the right thing even if it doesn’t have any

► Protect all company assets against theft, loss or misuse

► Follow your local dress code at work

► Follow office timings

► Consult your manager or HR function if you are facing

► Use your position or employment for personal gain

► Lie to avoid difficult situations

► Say one thing and do another

► Give up in pressure situation (Always consult seniors)

► Managing Confidential data like business strategy, product pricing etc is

► Protecting XYZ ’s confidential data and not revealing sensitive information

► Manage confidential records as required

► Take steps to prevent the loss of information

► Keep confidential data confidential