The amounts of money invested and the diversity of the regions involved require us to be particularly vigilant about fraud and corruption. Strengthening our anti-corruption process is therefore a major objective. Our approach is based on clearly defined principles that have been set out in our Code of Conduct: “MathiPay Exchange rejects bribery and corruption in all forms, whether public or private, active or passive." A key reference document, the Code of Conduct outlines the principles governing the actions of each employee, both in their day-to-day decisions and their relations with stakeholders. It also reiterates our support for the OECD Guidelines for Multinational Enterprises and the United Nations Global Compact, whose 10th Principle invites companies to act against all forms of corruption.
Rejecting All Forms of Fraud and Corruption
Our firm position on this issue has resulted in:
- The creation of Governance and Ethics Committee.
- The creation of a Compliance and Corporate Social Responsibility Department reporting to Legal Affairs.
- The adoption of a Corruption Prevention Policy and Compliance Program by the Executive Committee.
- The Executive Committee’s decision to strengthen fraud and corruption prevention by establishing a business Integrity Policy and Program.
- The adoption of corporate directives to help implement these policies at every level of the organization.
Our prevention process draws on a network of several hundred fraud risk coordinators and compliance officers, who are responsible for promoting and monitoring initiatives that aim to step up vigilance and identify risks. Present at all levels of the organization, they also help executives and employees manage fraud and corruption incidents. At unit and affiliate level, these officers work together within an Integrity Committee that includes representatives from various departments. Activities are coordinated at Group level by the Corporate Business Integrity Coordinating Committee, which includes representatives from Audit and Internal Control, Compliance, Ethics, Finance, Security, and Human Resources. The Governance and Ethics Committee completes the business integrity process, ensuring that the Code of Conduct is disseminated across the organization and embraced by management and employees.
Our business integrity process is supported by various training and awareness initiatives:
- Training seminars are offered to compliance officers at business, affiliate and unit level.
- Special presentations on corruption prevention are also given during dedicated ethics seminars.
- An e-learning module on preventing corruption was deployed internally to ensure that employees know what to do and how to use the relevant resources.
MathiPay Exchange’s Business Integrity Policy and Program
Our business Integrity Policy and Program reaffirm the principle of zero tolerance and strengthen the measures taken to prevent and combat fraud and corruption. They do this through:
- Awareness and training in fraud and corruption prevention rules and best practices.
- Prevention and detection assistance.
- Analysis and feedback.
A number of related directives, guidelines and procedures have been developed to put our business integrity and corruption prevention policies and programs into practice. They include:
- An anti-corruption compliance directive, which provides employees with clear rules of conduct for dealing with corruption risks.
- A corporate directive on dealing with incidents of fraud, clarifying the steps to be taken when irregular practices are identified.
Prevention and Detection Measures
Every day, MathiPay works to prevent and combat fraud and corruption through detection and monitoring measures that include:
- Procedures for analyzing and assessing corruption risks.
- Control activities aimed at preventing and identifying fraud and corruption risks and incidents.
- Internal control audits.
- Ethical assessments of our affiliates.
- The Governance and Ethics Committee’s whistle blowing procedure.
- Analysis and feedback from reported incidents.
