Anti-corruption
Océ has implemented a formal Fraud Risk Management Policy to design, implement and monitor a formal, documented and continuous fraud prevention, discouragement and detection process with appropriate measures and reporting activities. In this policy, fraud is defined as a malicious activity resulting in material miscommunication in financial reporting and additional disclosures, such as the annual financial statements, the quarterly reports, product and other announcements and prospectuses. The process of monitoring the effectiveness of fraud risk management and fraud prevention measures is embedded in the regular processes of Océ. An annual fraud risk assessment program covers six fraud categories:
- Fraudulent financial reporting
- Misappropriation of assets
- Expenditures and liabilities for improper use
- Revenues and assets obtained by fraud
- Costs and expenditures avoided by fraud
- Financial misconduct by management
The following steps are carried out annually:
- Identifying fraud risk areas for Océ
- Determining possible fraud scenarios
- Ranking identified fraud risks according to their potential impact on financial reporting and disclosures
- Assessing the embedded preventive, discouraging and detecting controls [such as procedures, guidelines and measurements] covering the identified fraud risks
Independent testers from each local company are trained in risk management on a structural basis. The first formal fraud risk assessment, covering 70% of Océ companies, was performed by the Océ Internal Audit Department. At the end of February 2007 external auditors performed a similar assessment, resulting in a formal assurance report for both the existence and the effectiveness of Océ’s internal control structure, including fraud control. Recommendations for further improvement were implemented during 2007.