BAFUT COOPERATIVE CREDIT

UNION

FRAUD POLICY

BREAKING THE FRAUD TRIANGLE

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2016

A) Policy BACKGROUND
i) Bafut Cooperative Credit Union fraud policy is
established to facilitate the development of controls
that will aid in the detection and prevention of fraud
against the Cooperative Credit Union.
ii) It is the intent of Bafut Cooperative Credit Union to
promote consistent organizational behavior by
providing guidelines and assigning responsibility for
the development of controls and conduct of
investigations.

B) SCOPE OF POLICY
i) This policy applies to any irregularity, or suspected
irregularity, involving employees as well as Boards,
committees, consultants, vendors, contractors,
outside agencies doing business with employees of
such agencies, and/or any other parties with a
business relationship with also Bafut Cooperative
Credit Union.
ii) Any investigative activity required will be
conducted without regards to the suspected

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 wrongdoers length of service, position/title, or
relationship to Bafut Cooperative Credit Union.

C) POLICY

i) Management is responsible for the detection and

prevention of fraud, misappropriations, and other
irregularities.
ii) Fraud is defined as the intentional, false
representation or concealment of a material fact for
the purpose of inducing another to act upon it to his
or her injury.
iii) Each member of the management team will be
familiar with the types of improprieties that might
occur within his or her area of responsibility, and be
alert for any indication of irregularity.
iv) Any irregularity that is detected or suspected
must be reported immediately to the Board
Executives that shall then coordinate all
investigations using other organs and officials, both
internal (Internal Auditor supervisory Board) and
external (Apex Structure) and Legal Department if
necessary.

D) ACTIONS CONSTITUTING FRAUD

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The terms defalcation, misappropriation, and other fiscal
irregularities refer to, but are not limited to:

i) Any dishonest or fraudulent act.

ii) Misappropriation of funds, securities, supplies, or
other assets.
iii) Impropriety in the handling or reporting of
money or financial transactions.
iv) Profiteering as a result of insider knowledge of
Bafut Cooperative Credit Unions activities.
v) Destruction of physical documents to conceal
evidence.
vi) Deliberate and unauthorized interference in
software system to clean out information or disrupt
the proper functioning of the system.
vii) Using the manual operations instead of the
software system to conceal fraudulent
transactions.
viii) Violation of accounting principles and procedure
ix) Destruction of property.
x) Engaging in fake transfer of funds and or
fraudulent disbursements.

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 xi) Involvement in the use or peddling of fake bank
notes.
xii) Carrying out transactions in personal accounts
without the expressed authorization of hierarchy.
xiii) Unauthorized movement of funds in accounts.
xiv) Non respect of real time in the posting of funds
received
xv) Disclosing confidential and proprietary
information to outside parties.
xvi) Disclosing to other persons, securities and
activities engaged in or contemplated by Bafut
Cooperative Credit Union.
xvii) Accepting or seeking anything of material value
from contractors, vendors, or persons providing
services/materials to Bafut Cooperative Credit
Union.
xviii) Destruction, removal, or inappropriate use
of records, furniture, fixtures, and equipment;
and/or any similar or related irregularity
E) OTHER IRREGULARITIES
Irregularities concerning an employees moral, ethical, or
behavioral conduct should be resolved by the

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management team and the Vice President (Unit of Human
Resources) rather than the Boards.
F) OTHER FRAUD QUESTIONS
If there is any question as to whether an action
constitutes fraud, contact the Board of Directors and / or
the Apex structure for guidance.
G) INVESTIGATION RESPONSIBILITIES
Management has the primary responsibility for the
investigation of all suspected fraudulent acts as defined
in the policy. If the investigation substantiates that
fraudulent activities have occurred, the Internal Audit
Department (Internal Auditor) will issue reports to the
Board of Directors through the supervisory Board.
Decisions to prosecute or refer the examination results to
the appropriate law enforcement and/or regulatory
agencies for independent investigation will be made in
conjunction with legal counsel, senior management and
the Board of Directors, as will final decisions on
disposition of the case.
H) CONFIDENTIALITY
i) All information received must be treated
confidentially. Any employee who suspects
dishonest or fraudulent activity will notify the
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 Internal audit Department (Internal Auditor)
immediately, and should not attempt to personally
conduct investigations or interviews/interrogations
related to any suspected fraudulent act (see
REPORTING PROCEDURE section below).
ii) Investigation results will not be disclosed or
discussed with anyone other than those who have
a legitimate need to know. This is important in
order to avoid damaging the reputations of
persons suspected but subsequently found
innocent of wrongful conduct and to protect Bafut
Cooperative Credit Union from potential civil
liability.
I) AUTHORIZATION FOR INVESTIGATING
SUSPECTED FRAUD
i) Members of the Investigation Unit(Audit
Department / Apex structure) will have free and
unrestricted access to all Bafut Cooperative Credit
Union records and premises, whether owned or
rented; and
ii) The authority to examine, copy, and/or remove all
or any portion of the contents of files, desks,
cabinets, and other storage facilities on the
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 premises without prior knowledge or consent of
any individual who might use or have custody of
any such items or facilities when it is within the
scope of their investigation
J) REPORTING PROCEDURES
i) Great care must be taken in the investigation of
suspected improprieties or irregularities so as to
avoid mistaken accusations or alerting suspected
individuals that an investigation is under way.
ii) An employee who discovers or suspects fraudulent
activity will contact the Internal audit Department
(Internal Auditor) immediately. The employee or
other complainant may remain anonymous. All
inquiries concerning the activity under
investigation from the suspected individual, his or
her attorney or representative, or any other
inquirer should be directed to the Legal counsel or
the Legal Department. No information concerning
the status of an investigation will be given out. The
proper response to any inquiries is: I am not at
liberty to discuss this matter. Under no
circumstances should any reference be made to
the allegation, the crime, the fraud, the

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 forgery, the misappropriation, or any other
specific reference.
iii) The reporting individual should be informed of the
following:
- Do not contact the suspected individual in an
effort to determine facts or demand restitution.
- Do not discuss the case, facts, suspicions, or
allegations with any-one unless specifically asked
to do so by the Legal Counsel, Legal Department
or Internal audit Department (Internal
Auditor)/Apex Structure.
- Call the attention of your superior/supervisor.
iv) The internal Auditor should observe the following:
- Bring the person or staff concerned under control
- Contact the Board of Directors.
- Call the attention of the supervisory Board and
apex structure.
- Take custody of all records involved and receipt
for them.
- Carefully and diligently carryout the audit. Exploit
all avenues to prove the fraud beyond all
reasonable doubts.

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 - If fraud is established and accepted, obtain
written and signed acknowledgment from the
concerned.
- Prepare a detailed written report and all
necessary recommendations.
- President of the Board of Directors in concert with
Supervisory Board president may convene a
Board meeting for the report to be presented. Any
action to recover fraud remains the responsibility
of the Board of Directors.
K) TERMINATION
If an investigation results in a recommendation to
terminate an individual, the recommendation will be
reviewed for approval by the designated
representatives from Human Resources and the
Board of Directors and, if necessary, by outside Legal
counsel, before any such action is taken. The senior
management does not have the authority to
terminate an employee. The decision to terminate an
employee is made by the Board of Directors after
proper consultation with the legal counsel and the
States Labour department.
L)ADMINISTRATION
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 The Board of Directors is responsible for the
administration, revision, interpretation, and
application of this policy. The policy will be reviewed
annually and revised as need arises.

M) All workers are expected to sign this policy as an

engagement towards Bafut Cooperative Credit Union.

N) APPROVAL
Board of Directors

President of Board of Directors

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I,

.ID No----------------------------------- of
------------------------issued at
have read and
understood the Fraud policy of Bafut Cooperative Credit
Union. Hence, shall abide to the policy without any
reservation.

Signature of Worker.

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