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    Approach Note on Internal Audit

    CA. Deep Kumar Mendiratta

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    Contents

    Sl. No. Particulars Page #

    Section I

    2. ERM Framework 6

    3. Internal Audit Guidelines 9

    4. Internal Audit Process, Approach & Methodology 14

    Section II

    1. Internal Audit - Basics 4

    Page 2

    1. Assessing Risks & Internal Controls 22

    2. Internal Audit Sampling Methodology 29

    3. Internal Audit Tools 32

    4. Reporting and Follow-up 37

    5. Internal Audit & Fraud 40

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    Section I - Why Internal Audit ?

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    Internal Audit- Basics

    Definition of Internal Audit:Internal auditing is an independent,objective assurance and consulting activity designed to add value

    and improve an organizations operations. It helps an organization accomplish its objectives by

    bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk

    management, control, and governance processes.

    Objectives of Internal Audit:

    Risk Management

    Control

    Governance

    Page 4

    Risk:Risk is the potential that a chosen action or activity (including the choice of inaction) will lead to a

    loss (an undesirable outcome). The notion implies that a choice having an influence on the outcome

    sometimes exists (or existed).

    Internal Control:

    Internal Control is a process, effected by an entitys board of directors, management, and otherpersonnel, designed to provide reasonable assurance regarding the achievement of its objectives

    (Operational, Reporting & Compliance).

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    CARO (Companies(Auditors Report

    Order, 2003)

    Require listed companies to have an internal audit system commensuratewith its size and nature of business. To comply with the requirementscompanies may either have an internal audit department or can outsourcethe internal audit function to an external agency.

    Clause 49Requires audit committee role to include oversight of the internal auditfunction as one of the terms of reference. The agreement requires the auditcommittee to review with management performance of internal audit

    Why Internal Audit ?

    function.

    Companies Act,1956 (Section

    224)

    Requires companies to appoint an auditor or auditors at every annualgeneral meeting to hold office from the conclusion of that meeting untilthe conclusion of next annual general meeting.

    Page 5

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    Section I ERM Framework

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    Enterprise Risk Management

    ERM defined:A process, effected by an entity's board of directors, management and other personnel,applied in strategy setting and across the enterprise, designed to identify potential eventsthat may affect the entity, and manage risks to be within its risk appetite, to providereasonable assurance regarding the achievement of entity objectives

    The key to effectively protecting and growing returns for an organizations shareholders is toidentify and manage the risks that could prevent the organization from achieving its business

    objectives. The enterprise risk assessment is an efficient, comprehensive process that provides

    insight on inherent risks from an industry perspective and links them to the organizations

    objectives, initiatives, and business processes.

    Page 7

    Entity objectives can be viewed in the context of four categories:

    Strategic

    Operations

    Reporting

    Compliance

    Enterprise risk management requires an entity to take a portfolio view of risk. Management

    considers how individual risks interrelate and develops a portfolio view from two perspectives:Business unit level

    Entity level

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    Enterprise Risk Management Framework

    Page 8

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    Section I - Internal Audit Guidelines

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    Compliance to Auditing Standards (ICAI)

    Standards on Internal Audits:

    Standard on Internal Audit (SIA) 1, Planning an Internal Audit

    Standard on Internal Audit (SIA) 2, Basic Principles Governing Internal Audit

    Standard on Internal Audit (SIA) 3, Documentation

    Standard on Internal Audit (SIA) 4, Reporting

    Adobe Acrobat

    Page 10

    Standard on Internal Audit (SIA) 5, Sampling

    Standard on Internal Audit (SIA) 6, Analytical Procedures

    Standard on Internal Audit (SIA) 7, Quality Assurance in Internal Audit

    Standard on Internal Audit (SIA) 8, Terms of Internal Audit Engagement

    Standard on Internal Audit (SIA) 9, Communication with Management

    Document

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    Compliance to Auditing Standards (ICAI)

    Standards on Internal Audits:

    Standard on Internal Audit (SIA) 10, Internal Audit Evidence

    Standard on Internal Audit (SIA) 11, Consideration of Fraud in an Internal Audit

    Standard on Internal Audit (SIA) 12, Internal Control Evaluation

    Standard on Internal Audit (SIA) 13, Enterprise Risk Management

    Page 11

    Standard on Internal Audit (SIA) 14, Internal Audit in an Information TechnologyEnvironment

    Standard on Internal Audit (SIA) 15, Knowledge of the Entity and its Environment

    Standard on Internal Audit (SIA) 16, Using the Work of an Expert

    Standard on Internal Audit (SIA) 17, Consideration of Laws and Regulations in anInternal Audit

    Standard on Internal Audit (SIA) 18, Related Parties

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    Compliance to Auditing Standards

    The IIA Standards types:a) Attribute Standards: address the attributes of organizations and individuals

    performing internal audit services. The attributes addressed are:

    Purpose, Authority and Responsibility

    Independence and Objectivity

    Proficiency and Due Professional CareQuality Assurance

    b) Performance Standards: describe the nature of internal audit services and providequality criteria against which the performance of these services can be measured.

    Page 12

    The criteria addressed are:

    Managing Internal Audit Activity

    Nature of Work

    Engagement Planning

    Performing the Engagement

    Communicating Results

    Monitoring ProgressManagements Acceptance of Risk

    c) Implementation Standards: expand upon the Attribute and Performance Standards,providing guidance in specific types of engagements.

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    Compliance to Auditing Standards (illustrative)

    S.N. Title of Standard

    1 1000 - Purpose, Authority, and Responsibility

    2 1010 Recognition of the definition of Internal Auditing, the Code of Ethics, and the Standards inthe Internal Audit Charter

    3 1100 - Independence and Objectivity

    4 1110 - Organizational Independence

    5 1111 Direct Interaction with the Board

    6 1120 - Individual Objectivity

    Page 13

    - mpa rments to n epen ence or ect v ty

    8 1200 - Proficiency and Due Professional Care

    9 1210 - Proficiency

    10 1220 - Due Professional Care

    11 1230 - Continuing Professional Development

    12 1300 - Quality Assurance and Improvement Program

    13 1310 - Quality Program Assessments

    14 1311 - Internal Assessments

    15 1312 - External Assessments

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    Section I - Internal Audit Process

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    IA Process Overview

    1.1Define objectives ofanalysis

    1.2Gain an understandin

    2.1

    Request and receiveData

    2.2Validate Control

    3.1Execute audit steps

    3.2Identify discrepancies

    4.1Document processreproduce data

    1. Define 2. Validate 3. Execute 4. Retain

    Page 15

    1.3Define datarequirements

    o a s

    2.3Perform data qualityAssessment

    3.3Discuss discrepancieswith stakeholders andvalidate errors

    3.4

    Assess impact onobjectives

    4.2Document Retention

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    Execution Process Overview

    ControlEvaluation

    ControlTesting

    Gather Info Understand

    the Process Evaluate

    DevelopTest Plan

    Sampling orCAATs

    TestingConsider

    SubstantiveTesting

    Reass

    Page 16

    SubstantiveTesting

    FormulateFindings

    DevelopTest Plan

    Sampling orCAATs

    Testing

    AssessRootCause

    PrioritizeAgree ActionPlan with theManagement

    ssScope

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    Evaluation Process

    Is a

    Control inPlace?

    Isthere a

    mitigatingControl

    ?

    Missing ControlsNO

    Yes

    NO

    And in the appropriate

    timeframe?

    Yes

    Control ObjectiveRisk

    Microsoft Office

    l 97-2003 Works

    Page 17

    Doesthe controladdress the

    risk? e.g. Are all relevantattributes covered

    Assess MitigationMissing /Mitigated Controls

    Inadequate ControlsNO

    Yes

    Determination on Adequacy of Control Design

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    Risk and Control Matrix

    Sr.No.

    ProcessSub

    Process/Activity

    What Can GoWrong (Risk)

    Control Description Test ProceduresDocuments to beReferred for Test

    Procedures

    Conclusion(Effective /Ineffective)

    1 Client

    Billing

    (Invoicin

    g &

    Collection)

    Quantity

    Assessment

    & Work

    Incorrect quantity

    assessment by the

    billing engineer

    leading to under-

    billing to the client Incorrect quantity

    assessment by the

    billing engineer

    leading to over-

    billing to the client

    Quantity assessment

    is done against the

    schedule of work

    (target billing) and the

    actual work carried outat the site

    The quantity

    assessment is also cross

    checked against the

    MPR/DPR (Prepared by

    the planning

    Obtain the latest

    Project Review Report

    (PRR) and Daily Progress

    Report (DPR) for the

    period under review Select sample RA Bills

    and review whether

    related records certifying

    the completion of

    measured work are

    maintained

    Measurement

    sheets from the site

    PRR and DPR

    Raised RA Bills and

    certified RA Bills

    Page 18

    department who inturn

    get the data fromexecution department

    and sub-contractors/

    vendors)

    Ensure measured works

    are strictly in accordancewith scope of work and

    any variation is

    seperately parked as

    'Extra Work/Item'

    Quantities for billing

    are supported by site

    measurements/Stock

    consumption andissuance records

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    Steps to Follow after identifying a Finding

    Discuss and validate errors with responsible stakeholders and process owners

    Consider whether there are any compensating controls within the process or system,and extend the testing scope, if necessary

    Assess impact - Whether or not the objectives of the test have been met and if alternative measures need to be taken

    Evaluate Exceptions or Errors Identified during Controls Testing for the following:

    Page 19

    . o en a ec on con ro o ec ves

    ii. Incidence, or level of erroriii. Cause of the control breakdown

    iv. Actual Effect, if applicable

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    Elements of a Finding

    Criteria:Provides a context for evaluating evidence and understanding the findings (Control Objectives)

    Policies & Procedures (Expectations of what should exist)

    Contracts & Agreements

    Laws & Regulations

    Standards & Benchmarks

    Defined business practices or measures which performance is compared or evaluated against

    Condition:

    Page 20

    on t on s a s tuat on t at ex sts or w at was occurr ng w en t e contro wea ness was ent e

    i.e. The Exception or Deficiency

    Cause:

    Identifies the reason for the condition or the factor(s) responsible for the difference between the

    situation that exists (condition) and the required or desired state (criteria), Common factors

    include; poorly designed policies, procedures, or criteria, inconsistent, incomplete, or incorrect

    implementation, segregation of duties or business conditions.

    Effect or Risk Impact:

    A clear, logical link to establish the impact or potential impact of the difference between the

    situation that exists (condition) and the required or desired state (criteria), which identifies the

    outcomes or consequences of the condition. Effect or risk impact may be used to demonstrate the

    need for corrective action in response to identified condition.

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    Recommendations

    Should address the root cause not just the symptoms

    Be relevant and practical

    Compare the benefits to costs

    More than 1 recommendation may be required to completely address an issue

    Use best practices as a source for creative insight, adapting to the needs of the

    organization

    Example:

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    Audit Objective: Evaluate and Document Credit limit Increase Procedures

    Risk/Control Objective: Credit Limit Increase are manually reviewed andapproved prior to processing the request in the system

    Sample Selection: 15 credit limit increase accounts from a systemgenerated report

    Documents Obtained: Credit limit increase MIS and the credit limit increasedelegation of authority and Income documents

    Exceptions noted: 3 of 15 credit limits increases were not reviewedand approved per the delegation of authority and excesscredit limit was granted to customers.

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    Section II - Assessing Risks & Internal Controls

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    Internal Control Structure

    Monitoring: Monthly reviews of performance reports

    Internal audit function

    Control Activities:

    Information & Communication: Vision and values

    Issue resolution calls

    Reporting

    Corporate communications (e-

    mail, meetings)

    In many cases, you perform controlsand interact with the control

    structure every day

    MONITORING

    INFORMATION ANDCOMMUNICATION

    CONTROL ACTIVITIES

    Page 23

    Approvals Security

    Block Codes /

    policies

    Risk Assessment: Monthly Risk Control meetings

    Internal audit risk assessment

    Control Environment: Tone from the top

    Corporate Policies

    Organizational

    authority

    An internal control structure is simply a different way of viewing the business

    a perspective that focuses on doing the right things in the right way.

    RISK ASSESSMENT

    CONTROL ENVIRONMENT

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    Concepts and Objectives

    Control definition reflects certain fundamental concepts:

    Internal control is a process

    Internal control is effected by people. It's not merely policy manuals and forms,

    but people at every level of an organization.

    Internal control can be expected to provide only reasonable assurance, not

    absolute assurance, to an entity's management and board.

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    Objectives of Internal Control

    Internal controls are established to further strengthen:

    The reliability and integrity of information.

    Compliance with policies, plans, procedures, laws and regulations.

    The safeguarding of assets. The economical and efficient use of resources.

    The accomplishment of established objectives and goals for operations or programs.

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    Control TechniquesPrevention techniques are designed to provide reasonable assurance that only validtransactions are recognized, approved and submitted for processing. Therefore, many of

    the preventive techniques are applied before the processing activity occurs. In most

    situations, preventive techniques are likely to be more effective in a strong control

    environment, when management authorization criteria are well-defined and properly

    communicated.

    Control type definitions:Preventive - Manual

    Preventive - System

    Page 25

    Examples of preventive controls include:

    Segregation of duties (Preventive-Manual) Business systems integrity and continuity controls, e.g., application design standards,

    change controls, security controls, systems backup and recovery (Preventive System) Physical safeguard and access restriction controls (human, financial, physical and

    information assets) (Preventive-Manual) Effective "whistle blowing" processes (Preventive-Manual)

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    Control TechniquesDetection techniques are designed to provide reasonable assurance that errors andirregularities are discovered and corrected on a timely basis. Detection techniques normally

    are performed after processing has been completed. They are particularly important in an

    environment that has relatively weak preventive techniques. That is, when front-end

    approval and processing techniques do not provide reasonable assurance that unacceptable

    transactions are prevented from being processed or do not assure that all approved

    transactions are processed accurately. In this case, after-the-fact techniques become moreimportant in detecting and correcting processing errors.

    Control type definitions:Detective - Manual

    Page 26

    Detective - System

    Examples of detection techniques include:

    Reconciliation of batch balance reports to control logs maintained by originating

    departments. (Detective Manual) Review and approval of reference file maintenance (was-is) reports. (Detective

    Manual) Reconciliation of interface amounts exiting one system and entering another.

    (Detective System) Review of on-line access and transaction logs. (Detective System)

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    Risk Analysis

    RiskManagement RiskMonitoringRiskAssessment

    Risk Analysis

    Page 27

    Control It

    Share orTransfer It

    Diversify orAvoid It

    rocess

    Level

    ActivityLevel

    Entity Level

    Identification

    Measurement

    Prioritization

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    Role of a Process Owner

    General Expectations Acknowledge the responsibility for the design, implementation and maintenance

    of the control structure within the business processes

    Contribute direction to identify, prioritize and review risks and controls

    Remove obstacles for compliance; remedy control deficiencies Continue or begin a program of self-assessment and testing to monitor the

    controls within the processes

    Quarterly

    Page 28

    - confirm key controls are implemented and effective

    - maintain documentation to support this assessment

    Immediate Action Items

    Educate personnel about the requirements and effort

    Reinforce internal focus on controls within the process

    Surface any risks, concerns or issues promptly to allow adequate attention for

    correction (dont wait for an audit)

    Fix control gaps within reasonable timescales

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    Section II - Internal Audit Sampling

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    Sampling

    Population:The entire set of universe from which a sample is selected & reviewed, and about which the auditor

    wishes to draw conclusions.

    Data availability for population:

    An important aspect in sample selection is the availability of data. Depending upon the population,

    entire data may or may not be available. In cases where entire data is not available, same should

    be brought to the attention of the Management, be agreed with the stakeholders and be clearly

    mentioned as a scope limitation.

    Systematic selection:

    A systematic approach is used by the auditor to select items, to minimize any potential human

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    judgment or bias. Every nth item within the population is selected in accordance with a defined

    sampling interval.

    Haphazard selection:

    The auditor, without any conscious bias, selects sample items randomly, i.e., without any special

    reason for including or omitting items from the sample

    Stratification:

    Prior to carrying out analytical procedures, it is important to stratify / classify the data into

    separate logical sections. This classification would not only help in analyzing trends unique to that

    particular category but would also help in assessing materiality while selecting a sample.

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    Sampling

    Perform Analytical procedures:Analytical procedure is defined as an evaluation of financial information made by a study of

    plausible relationships among both financial and non-financial data

    Analyse abnormal transactions:

    If the analytical procedures highlight certain abnormal transactions (where there are significant

    aberrations), they should be separated and reviewed separately. Such transactions should bereviewed in addition to the regular sample selected.

    Using Excel / CAAT:

    In case the testing objective can be applied by using excel / CAAT on the entire population, audit

    Page 31

    proce ures s ou e per orme on e en re popu a on e se samp es s ou e se ec e or

    testingDetermining sample size and selecting sample:

    The sample size will depend on the frequency of the control being tested and the level of evidence

    that is judged to be necessary, by the client and the engagement team. For this purpose the

    engagement team should define the areas under scope as either High or Low risk

    Performing audit procedures and Evaluating Test results:When weaknesses in internal controls are identified we should consider whether there are any

    compensating controls within the process or system. If we believe there are appropriate

    compensating controls, we should extend the testing scope to include testing of these compensating

    controls.

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    Section II - Internal Audit Tools

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    Need for Mathematical Tools

    To recognize early warning bells, as part of audit procedures, andprotect business against fraud or error.

    Identify transactions that are indicative of fraud or error using

    tested and proven fraud & error detection techniques

    Scientific sample selection through automated procedures

    Page 33

    e uce epen ence on ran om samp ng

    To Identify red flags at Financial Statements Level.

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    Using Excel as a Tool

    IF

    IF in combination with AND

    IF in Combination with AND & OR

    CountIF and SUMIF

    SUMIFS

    Page 34

    Pivot Table Function

    Setting Filters

    Formula Auditing

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    Using Excel as a Tool (illustrative)

    Statistical Functions:

    COUNT Computes the number of numbers in a range

    COUNTA Computes the number of entries, including text entries in a

    range

    AVERAGE Sums the numbers in a range and divides the total by the number

    of numbers

    Page 35

    MEDIAN Computes the middle value in a range of numbers

    MODE Computes the value that occurs most frequently

    VLOOKUP Searches for a value in the leftmost column of a table, and then

    returns a value in the same row from a column you specify in thetable.

    PIVOT Summarizes the columns of information in a database

    relationship to each other.

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    Analyzing data in IDEA

    Use of data analytics tools facilitates creating a virtual room where all relevantaudit content can be stored and accessed.

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    Section II - Reporting and Follow-up

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    Audit Report Structure

    Covering Letter

    Background/ Function Overview

    Purpose/ Objectives

    Scope of Work

    Audit Approach

    Limitation

    Executive Summary (Significant Findings)

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    Detailed Observations

    Follow Up of Prior Recommendations

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    Audit Report StructureS.N

    o.

    Priority Issue Risk Performance

    ImprovementObservation

    Management

    Response

    Responsibility

    / Timelines

    1 High It was observed that in 48 out of

    60 cases (total population of 850

    cases for credit limit

    enhancement for period March-

    May,2012) the credit limits

    enhanced for existing customerswas not as per the parameters

    defined in the policy. Excess

    credit limit amounting to Rs

    13.22 Lacs was given to

    customers. For details refer

    Annexure 1

    Incorrect credit

    limit offered to

    customer leading

    to increased credit

    risk exposure for

    the Company,which may

    eventually lead to

    higher

    delinquencies.

    The authority &

    responsibility

    within the Risk

    Team should be

    explicitly defined

    & documented forapproving the

    credit limit

    increase

    deviations and the

    same should be

    approved as per

    Adequate steps will be

    taken up to ensure the

    policy adherence by

    having periodic

    process trainings for

    account managementteam. The risk team

    would additionally

    support the training

    requirements of the

    AMU team.

    Risk Team

    March 2013

    Page 39

    .

    2 High Late Payment Charges amounting

    to Rs 1.3 Lacs were short-levied

    on 260 accounts and the same

    was excess levied on 296

    accounts. Further, the Finance

    Charges on these accounts would

    be incorrect as the LPC is not

    accurately levied

    Possibility of

    Revenue leakage

    for LPC and

    Customer

    dissatisfaction /

    negative impact

    on brand /

    reputation

    Business should

    evaluate the

    possibility of

    Implementing

    continuous control

    mechanism

    through data

    analytics tools and

    System Auditshould be carried

    out.

    The implementation of

    the revised LPC tier

    from Rs.700 to Rs.750

    was delayed by ~40

    days due to set up

    miss, later identified

    by pricing team and

    rectified on 12th

    November 2012.

    Marketing

    Team

    March 2013

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    Section II - Internal Audit and Fraud

    d l k

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    Anti Fraud Control Framework

    Code of conduct Ethics policy Gifts and hospitality Agents Facilitation payments

    Policy Tone from top Zero tolerance

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    Process

    Roles and responsibilities Accountability Annual sign off

    Self assessment Testing

    People

    Board

    responsibilities Due diligence

    Training Education

    Voice

    Disclosure

    Openness Employee/ suppliers

    F d P i S

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    Fraud Prevention Strategy

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    Thank You

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