Gemalto's anti-fraud framework is designed to prevent, detect, deter and respond to any fraudulent activities. It is overseen by the anti-fraud Commission, which comprises six senior managers and is responsible for the continuous assessment of our fraud risks and development of our anti-fraud policy. Managers must inform the Commission of any suspicion of fraud. Additionally, employees can also use the Gemalto whistleblower line to raise concerns about financial irregularities. In 2015, 16 of our 43 internal audits were either focused on fraud risk or were partially motivated by fraud concerns. In addition, we trained some 880 key people in anti-fraud, anti-bribery, anti-trust and ethics; and some 2,050 employees in CFIUS and trade compliance topics.
We extend our anti-fraud focus to relevant third parties. Our Purchasing CSR Charter clearly states obligations relating to identifying, addressing and monitoring corruption concerns or verified practices (see page 22).
In some locations we work with agents and other intermediaries who promote our solutions and services. Our Agents Policy categorically prohibits us from dealing with those who have used, or are suspected of using, corrupt practices and behaviors to gain or retain business.