We are fully committed to exposing and disciplining any acts of fraud. These might include any intentional breach of the law, or of Gemalto’s internal policies, carried out by an employee to benefit himself/herself, third parties or the Company.
In 2007, with the help of an external consultant, Gemalto launched a Group Fraud Risk Assessment in a post-merger background and as part of a global “Internal control” project. This led to a new senior management structure – the “anti-fraud commission”. Its charter was approved by management on 18 August 2008 and amended on 22 June 2009. It meets formally each quarter, as well as on an “ad hoc” basis.
The commission comprises the Group General Counsel, the EVP Human Resources, the Chief Information Officer, the Quality, HSE1Security and WCE2 Director and the Internal Audit Director. Its first objective was to coordinate the various programs already in place within the Company. Later priorities have included continuous fraud risk assessment, our anti-fraud policy and procedures and determining Company response in the event of fraud. Key elements of the commission’s work include:
- the publication of Gemalto’s anti-fraud policy in 2009, which was complemented in 2011 with the release of the Investigation Protocol, providing guidance on how to run and manage the investigation work in the case of suspicion and/or fraud, and in 2012 with the release of the fraud reporting process;
- a series of training sessions on fraud related matters. In 2012 we organized 66 awareness and training sessions for 945 people. These covered subjects such as internal control, anti-fraud, and the segregation of duties and business practices (for example with reference to ethics and competition).
- the engagement in 2010 of two specialized forensic firms, also contracted in 2011 and 2012, to handle forensics surveys when needed.
As our risk landscape had been evolving over the past five years, it was decided in 2012 to redo a full up-to-date assessment of the key fraud risks, with specific attention to the risks which could have an impact on the objectives and/or the reputation of the Group. 88 managers were involved in this exercise. Results were presented to management and then to the Board at the end of 2012.
Of all the internal audits we conducted during the year, 25 in 2012 (vs. 22 in 2011) were either focused specifically on fraud risk or partially motivated by fraud concerns. In addition from 2010, Internal Audit introduced data mining exercises in order to improve sampling and detect errors and irregularities.
We also communicate widely to our employees about fraud prevention and detection. For example, the newsletter “Your Internal Control Network” – issued fortnightly – covers anti-fraud issues on a regular basis.
Tackling bribery and corruption
As part of its commitment to tackling fraud, bribery and corruption, the Board has also established a “whistle blower” tool and procedure. It encourages the prompt reporting and handling of any employee complaints about financial irregularities, or suspicions of improper conduct relating to the Gemalto Group.
In 2010, we published the
Gemalto Purchasing CSR charter, which applies to both Gemalto and our suppliers. The Charter clearly states our obligation to fight corruption in all its forms. As a minimum, Gemalto also encourages its suppliers to join the United Nations Global Compact. In 2011 we developed a supplier CSR self-assessment questionnaire (SAQ) which we improve continuously. The aim of the SAQ is to establish whether suppliers have CSR policies and procedures in place, and to elicit information necessary to assess their performance against targets. Furthermore, some CSR audits were performed on suppliers in 2012.
In 2012 the “Agents’ selection and relationship management” policy was revised. It specifies standards for how employees should manage agent relationships including selection, commitment, follow-up and payment.
The Agent’s policy reinforces two key principles. Firstly, it states that corruption is a serious criminal offence in all jurisdictions and can involve sanctions for individuals, as well as legal entities. It also makes clear that Gemalto does not deal with any agents who use corrupt practices either to gain or retain business.
In 2012 we launched two eLearning programs, one on competition laws and another one on expense reports. Another program, this time on fraud (which includes corruption and bribery) was launched in January 2013.