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TITLE: PREVENTION OF FRAUD/CORRUPTION AND OTHER
IRREGULARITIES
Policy Number
Effective Date
0015
April 2011
Next Revision Date 2013
APPROVED 30/03/2011
1.
PREAMBLE:
A Policy on Prevention of Fraud/Corruption and other
Irregularities is supportive of good corporate governance practices.
1.1
The purpose of this Policy is to set out the responsibilities of the employees and members of the public, with regard to
Anti-Fraud and Corruption as well as Fraud and Corruption
Prevention Plan and the action that will be taken by the
1.2
1.3
Waterberg FET College in the event of any contravention.
This policy is about changing organisational features that allow the events to occur and possibly go unnoticed or unreported. The strategies incorporated in the Fraud and
Corruption Prevention Plan address issues such as accountability, transparency, efficiency, effective and clean administration. Further, these strategies focus on improving systems and procedures, changing the attitudes of the staff and members of the public and improving the overall integrity and performance of or as we are attempting here, to incorporate in several such as Anti-Fraud and Anti- Corruption policy, Fraud and Prevention Plan and Code of Ethics etc.
The Anti-Fraud and Corruption Policy covers the prevention, detection and management of fraud and corruption and for fair dealing in matters pertaining to fraud and corruption. It aims
1.4
1.5
1.6
to raise the awareness of fraud and corruption and its prevention in the Waterberg FET College environment and to give guidance to both the reporting of suspected fraud and corruption and how the investigation of that report will proceed.
The Waterberg FET College has a duty to protect the public funds under its control against fraud and corruption both from within the Municipality and from external sources. This Anti-
Fraud and Corruption Policy is part of the Municipality’s commitment to sound corporate governance.
The Waterberg FET College expects all employees at all levels to lead by example in the achievement of probity and accountability by ensuring adherence to legal requirements, regulations, rules, procedures, policies and practices.
The Waterberg FET College also expects that individuals and organizations (e.g. suppliers, contractors and partners, etc) with whom it comes into contact, will act with integrity and without intent or actions to commit fraud or corruption or any other dishonest activities of a similar nature against the
Municipality.

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1.7
1.8
1.9
This policy is intended to set down the stance of Waterberg
FET College to fraud and corruption as well as to reinforce existing systems, policies, procedures, rules and regulations of Waterberg FET College aimed at deterring, preventing, detecting, reacting to and reducing the impact of fraud and corruption.
The Waterberg FET College recognizes the fact that acts of fraud and corruption by its employees and external stakeholders affect the quality and quantity of service delivery because of limited resources, thus resulting in the
Waterberg FET College not meeting its objectives.
Fraud and corruption is an ever-present threat to these resources and hence must be a concern to all employees and persons employed in a similar capacity. Fraud and corruption may occur internally or externally and may be perpetrated by anybody including employees, members of the public, councillors, consultants, suppliers, contractors or development partners, individually or in collusion with others.
2.
SCOPE OF THE POLICY:
2.1
2.1.1
2.1.2
2.1.3
Scope:
To contribute to cost effective service delivery
To comply with legislation
To contribute to a fair and just administration;
2.1.4
2.1.5
2.1.6
To contribute to the welfare of the communities it serves
To promote the effective attainment
To promote effective and efficient fraud and corruption
Management 2.1.7
2.2
2.2.1
2.2.2
2.2.3
2.2.4
2.2.5
2.3
The key principles underlying the policy are the following:
Fairness
Value for money
Efficiency and effectiveness
Consistency accountability
2.3.1
2.3.2
2.3.3
Adherence to the Policy will enable Council to :
Recognise and reward good service
Promote a secure working environment
Channel funds saved, into training and development opportunities for the betterment of all employed at the
Institution.
2.4
2.4.1
2.4.2
2.4.3
2.4.4
Non-compliance will:
Cause job losses
Cause the Institution to incure serious financial losses
Negative service delivery
Adversely affect the College image in the community and in the market place.

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3.
LEGAL FRAMEWORK:
3.1
The following legislation, amongst others, deal with corruption in South Africa:
 Corruption Act 94 of 1992
 Public Finance Management Act,1 of 1999
 Treasury Regulations
 Protected Disclosure Act
 King Report
 Code of Conduct Waterberg FET College
3.2
3.2.1
It is the responsibility of the Council, Management,
Employees and Students at the Waterberg FET College to adhere to the Code of Ethics and Conduct and other policies to assist the institution in the prevention and perpetration of fraud/corruption and other irregularities.
3.3
3.3.1
All forms of fraud/corruption and other irregularities, prejudicial or beneficial to Waterberg FET College, are prohibited and would be dealt with in accordance with the
Disciplinary Code for Employees and students respectively.
When dealing with allegations of fraud/corruption and any other irregularities at Waterberg FET College, the
Institution will strive to protect the rights of all parties involved in terms of the Constitution and the Laws of the
Republic of South Africa.
4.
DEFINITIONS:
4.1
4.1.1
4.1.2
4.1.3
Conflict of Interest: refers to situations in which:
Financial or other personal
Considerations may compromise,
Or have the appearance of com-
4.1.4
4.1.5
4.1.6
4.1.7
4.2
Promising, an employee’s professional judgement in administration, management, instruction, research and other professional activities.
4.2.1
4.2.2
4.2.3
4.2.3.1
4.2.3.1.1
Corruption in terms of section 3 of the Prevention and
Combating of Corrupt Activities Act 12 of 2004 is committed by any person who, directly or indirectly
Accepts or agrees or offers to accept any
Gratification from any other person, whether for the benefit of himself or herself or for the benefit of another person
Gives or agrees or offers to give any other person any gratification, whether for the benefit of that other person or for the benefit of another person, in order to act, personally or by influencing another person to act in a manner:
That amounts to the: illegal, dishonest, unauthorised, incomplete or biased: or

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4.2.3.1.2
4.2.3.2
4.2.3.2.1
4.2.3.2.2
4.2.3.2.3
misuse or selling of information or material acquired in the course of the, exercise, carrying out or performance of any powers. Duties or functions arising out of a constitutional, statutory, contractual or any legal obligation;
That amounts to; the abuse of a position of authority breach of trust; or the violation of a legal duty or a set of rules designed to achieve an unjustified result; or that amounts to any other unauthorised or improper inducement to do or not to do anything that is guilty of the offence of corruption.
4.3
4.3.1
4.3.2
4.3.3
4.3.4
4.3.5
4.3.6
4.3.6.1
4.3.6.2
4.3.6.3
4.3.6.4
The legal definition of fraud, theft and corruption in defined according to the common law of South Africa, and is summarised as:
Fraud: is defined as the unlawful act or omission by which misrepresentation is made with the intention to defraud or making a misrepresentation which causes actual prejudice or which is potentially prejudicial to another.
Theft is defined according to the common law of South Africa, and is summarized as: The unlawful misappropriation of movable property or money with the intention to steal.
Corruption: Corruption is defined according to the
Corruption Act, 94 of 1992 of South Africa, and as amended, and in summary prohibits the abuse of a position of employment by; the offering or acceptance of a benefit that is not legally due, for the commission of an act in connection with that position of employment
Immediate family : In this context it includes a spouse, if any, parents and any natural or adopted siblings or children, stepchildren, parents-in-law, brothers, sisters and all inlaws. “Spouse’ includes any male or female person with whom the employee is cohabiting as habitual partners.
Irregularity: Means any conduct that is in contravention of any approved policy of Waterberg FET College, including, amongst others, fraud.
Corruption takes various forms in the public sector and elsewhere in society.
The following are examples of different types of corruption:
Bribery: the promise, offering or giving benefits that improperly affects the actions or decisions of staff.
Example: traffic officer receiving cash for not issuing a fine
Embezzlement: theft of resources by persons entrusted with the authority and control of such resources;
Example: staff selling medicine from hospitals and selling to private pharmacists
Fraud: actions that fools others into providing a benefit
Extortion: coercing a person or entity to provide a benefit to a staff member, another person or an entity in exchange for acting in a particular manner.

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4.3.6.5
4.3.6.6
4.3.6.7
Abuse of power: using vested authority to improperly benefit another employee- (Manager request that a certain person receive the tender)
Conflict of interest: failing to act or disclose his/her interest
Abuse of privileged information: the use of information and knowledge that a staff member possesses and uses for
4.3.6.8
hi/her advantage to obtain a benefit
Favouritism: the provision of services or resources according to personal affiliation (example political, religious, ethnic group receiving preference over other groups
Nepotism: An employee ensures that family members are 4.3.6.9
appointed in positions or those family members receives tenders, etc.
5.
INDICATORS OF FRAUD AND CORRUPTION:
5.1
The following indicators (RED FLAGS) that could be an indication of the potential existence of fraud and corruption:
5.1.1
5.1.2
5.1.3
5.1.4
5.1.5
5.1.6
Unusually high personal debts
Living beyond one’s means
Excessive gambling habits
Alcohol /drug problems
Undue family or peer pressure to succeed
Feeling of being underpaid
5.1.7
5.1.8
5.1.9
5.1.10
5.1.11
5.1.12
5.1.13
Feeling of insufficient recognition for job performance
Close association with suppliers
Wheeler-and –dealer attitude
Desire to “beat the system”
Criminal record
Not taking vacations
Not allowing someone access to area of responsibility
Undisclosed conflict of interest and;
Rationalization for conflicting behavioural problems
5.1.14
5.1.15
5.2
5.2.1
5.2.2
5.2.3
5.2.4
5.2.5
5.2.6
Indicators of opportunities to commit fraud:
Rapid turnover of key employees through resignation or dismissal
Dishonest and dominant management
Inadequate training programmes
Complex business structures
No effective internal audit function
Continious problems with regulatory agencies and
The above illustration of the manifestation of corruption is by no means complete or exhaustive. Corruption appears in various permutations and degrees
6.
MISCONDUCT THAT CONSTITUTES CORRUPTION AND OTHER IRREGULARITIES
AT WATERBERG FET COLLEGE:
6.1.1
Misappropriation or misuse of funds and property that belongs to the Waterberg FET College.

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6.1.2
6.1.3
6.1.4
6.1.5
6.1.6
6.1.7
6.1.8
6.1.9
6.1.10
6.1.11
6.1.12
6.1.13
6.1.14
6.1.15
6.1.16
6.1.17
6.1.18
Destruction, removal or concealment of Waterberg FET College property
Alteration or falsification of documents prejudicial to
Waterberg FET College, or any party conducting business with the College.
Presenting any false claim for reimbursement by any party associated with Waterberg FET College.
Theft of property in any form, corporeal, from Waterberg FET
College.
Knowingly creating, condoning or presenting inaccurate
Financial statements contrary to proper financial controls and generally accepted accounting principles (GAAP)
Reporting standards adhered to at Waterberg FET College.
Colluding, for a benefit, with any party (internal or
External) in any manner that creates actual or potential
Prejudice to Waterberg FET College.
Improper handling or reporting of financial transactions.
Knowingly giving authority for the payment of or signing for fictitious goods and services.
Knowingly submitting or authorizing false overtime and making any misrepresentative travel claims
The use of or authorizing the use of any Waterberg FET
College logo or trademarks in any manner that causes prejudice to the institution.
Exercising or failing to exercise any power of authority
Delegated to the individual as a Waterberg FET College employee resulting in the employee or his/her immediate family obtaining a personal benefit.
Failing to disclose any vested interest where there is likely to be any conflict of interest while conducting Waterberg FET
College business.
Making any misrepresentation of facts that result in actual or potential prejudice against a party at the College.
Failure to comply with the provisions of any policy and/or procedure duly approved by Council in a manner that causes prejudice to the institution.
Failure to act or refrain from acting in reasonable manner, where such conduct or omission is not regulated by policy, causing prejudice to the College.
6.2
6.2.1
6.2.2
6.2.3
In view of the legal framework and government policies:
It is the Policy of the Waterberg FET College that fraud, corruption, theft, maladministration and or any other dishonest activities of a similar nature will not be tolerated. In addition these will be investigated and followed up by the application of all remedies available within the full extent of the law.
Appropriate prevention and detection controls will be applied. These include the controls and checking mechanisms as prescribed in existing policies, procedures and other relevant prescripts.
It is the responsibility of all employees to report all instances of fraud, corruption, theft, maladministration or

Page 7 of 13 any other dishonest activities of a similar nature to his/her immediate supervisor.
7.
FRAUD/CORRUPTION AND OTHER IRREGULARITIES PREVENTION PLAN:
7.1
A major step in the avoidance of losses is when the Council acknowledges that fraud control is one of the building blocks
7.2
7.2.1
of good governance.
Treasury Regulation 3.2.1 states:
“The Accounting Officer must ensure that a risk assessment is conducted regularly to identify emerging risks to the
Institution. A risk management strategy, which must include a Fraud Prevention Plan, must be used to detect direct
7.3
7.3.1
7.3.2
internal audit effort and priority, and to determine the skills required of managers and staff to improve controls and to manage these risks. The strategy must be clearly communicated to a;; officials to ensure that the risk management strategy is incorporated into the language and the culture of the Institution”
Waterberg FET College will implement the following strategy for the prevention of fraud/corruption and other irregularities:
Prevention: activities intended to prevent the fraud from occurring
Detection: activities intended to uncover the existence of fraud that could not be prevented
7.3.3
7.3.4
7.3.5
7.3.6
7.3.7
7.3.8
Investigation: a systematic examination of facts surrounding the detected incident.
Correction: is the action of addressing the root causes of what allowed the fraud/corruption or irregularities to occur and would include control improvements, sanctions and redress.
Deterrence: is the stopping of fraud before it is attempted.
This would be attributed to fear of being caught and punished as well as the difficulty aspect of perpetrating the fraud.
Fraud risk assessment: Management to assess the vulnerability of the College every 18-24 months. This is done by traditionally evaluating the type of risk/fraud, the likelihood of its occurrence, the potential impact of the fraud
Accountability: Management, line managers and staff should have a matrix which lists the anti-fraud functions and which staff have primary, secondary or a shared responsibility. The
Code of Conduct must be signed by all staff members where it is stated that they understood the document and will adhere hereto. This will prevent them from claiming ignorance.
Controls: After the fraud assessment Management must determine whether there are controls in place to mitigate the identified fraud risks or if additional emphasis should be placed on existing controls.

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7.4
Fraud Deterrence Lifecycle:
Prevention
Correction
Fraud
Deterrence
Lifecycle
Detection
Investigation
8.1
8.
ENVIRONMENT AND CULTURE:
The management must create an environment and culture in which employees believe that dishonest acts will be detected and
8.1.1
investigated. To this end, they must: participate in in-house training program covering fraud and corruption detection, fraud and corruption prevention and training on the code of ethics;
8.1.2
8.1.3
ensure that staff understand that the internal controls are designed and intended to prevent and detect fraud and corruption or any other dishonest activities of a similar nature; encourage staff to report suspected fraud and corruption directly to those responsible for investigation without fear
8.1.4
of disclosure or retribution; and require vendors and contractors to agree in writing as a part of the contract process, to abide by the Waterberg FET
College policies and procedures, and thereby avoid any conflict of interest.
8.2
modified.
9.
PROCEDURES FOR REPORTING FRAUDULENT AND OR CORRUPTIVE
ACTIVITIES:
9.1
Measures to prevent fraud and corruption should be continually monitored, reviewed and developed particularly as new systems, programs, contracting or arrangements are introduced or
Consistent with the Auditor General’s guidelines, line managers are responsible for daily operations and for the internal control systems within their organisational responsibility. Where managers do not have the expertise to evaluate internal controls they should call upon the support from Internal Audit.

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9.2
It is the responsibility of members of the employees
(including line managers) to report all incidents of fraud, corruption or any other dishonest activities of a similar nature.
10.
INVESTIGATION OF COMPLAINTS:
10.1
10.2
The Office of the Head: Investigations will investigate all complaints of fraud and corruption with the assistance of different Units/Departments and individuals.
The Human Resources Unit must provide adequately qualified prosecutor (initiator) and presiding officers to deal with disciplinary enquiries relating to serious misconduct.
10.3
10.3.1
For the purpose of this policy “serious misconduct” means
Theft, unauthorized possession of or malicious damage to the employer’s property.
Any act of gross dishonesty. 10.3.2
10.3.3
10.3.4
10.3.5
10.3.6
Gross negligence
Wrongful disclosure of privileged information.
Any act of fraud, corruption or bribery.
Any other act of misconduct that would constitute just cause for dismissal for a first offence.
11.
PROTECTION OF WHISTLE-BLOWERS:
11.1
The Protected Disclosures Act, Act 26 of 2000 makes provisions for procedures in terms of which employees may disclose information regarding unlawful or irregular conduct by their employers or other employees in the employ of their employers without fear of victimization.
11.2
11.2.1
11.2.2
11.2.3
11.2.3.1
A person shall therefore not: prejudice, or threaten to prejudice, the safety or career of; or intimidate or harass, or threaten to intimidate or harass; or do any act that is, or is likely to be, to the detriment of, another person because the other person:- has assisted, is assisting or will or may in the future
11.2.3.2
11.2.3.3
11.2.3.4
assist The Office of the Head: Investigations or any Law
Enforcement Agency in the performance of its functions; or has furnished, is furnishing or will or may in the future furnish information to The Office of the Head:
Investigations or any Law Enforcement Agency; or has been or is, or has been or is employed by or acting on behalf of, an independent agency or appropriate authority to whom or which an allegation has been referred; or has exercised a power, or performed a duty, conferred or imposed on the other person or is exercising or performing, or will or may in the future exercise or perform, any such power or duty."

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11.2.4
11.2.5
All whistle-blowers’ identities will remain confidential or anonymous to prevent victimization.
Action to cover up the wrongdoing and or to retaliate against, or victimise witnesses is strictly forbidden, and such action constitute a conduct within the jurisdiction of the Waterberg FET College, which is punishable.
The Whistle-blowing Policy supplementing this policy will be 11.2.6
prepared by the Ombudsperson and Head: Investigations and be cascaded to all employees after having been approved by the
Executive Council of Waterberg FET College.
12.
CONFIDENTIALITY AND DISCRETION:
12.1
12.2
The Office of the Head: Investigations will treat all information that it collects or receives in confidence except as is necessary for a thorough investigation and resolution of the complaint and/or as required by law or a standard of ethical conduct.
People will be made aware of the issue and the investigation only on a limited need-to-know basis.
12.3
In order to avoid damaging the reputations of innocent persons initially suspected of wrongful conduct, the results of investigations will not be disclosed or discussed by anyone other than those who have a legitimate need to know.
13.
STAFF DEVELOPMENT AND TRAINING:
13.1
13.2
In order to deal with fraud and corruption challenges, continuous learning, development and the sharing of good practice will result in highly skilled Anti-Fraud Officers working in a professional framework to the highest standards of performance and integrity.
Courses/workshops on the topic of fraud and corruption detection and prevention, will in each year be co-ordinated by
The Office of the Head: Investigations to empower the Anti-
Fraud Officers to be able to combat fraud and corruption.
13.3
14.2
The training on the Code of Ethics as a preventive measure on fraud and corruption will be rolled out to the Management and employees by The Office of the Head: Investigations in conjunction with the Skills and Development Unit.
14.
RESOLUTION OF REPORTED INCIDENTS:
14.1
Allegations of fraud and corruption or any other dishonest activities of a similar nature that are reported by members of the public or employees will be investigated by Office of the
Ombudsperson and Head: Investigations and/or referred to the relevant agencies, depending on the nature of the incident.
Members of the Ombudsman or Head Investigations shall have free and unrestricted access to all College records and premises, whether owned or rented; and the authority to examine, copy, and/or remove all or any portion of the content of files, desks, cabinets, computers and other storage facilities on the premises without prior knowledge or consent

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14.3
14.4
14.4.1
14.4.2
14.4.3
of any individual who may use or have custody of any such items when it is within the scope of their investigation.
All employees must promptly co-operate and comply with requests from The Office of the Head: Investigations with regards to information required to assist investigation.
Where an investigation has revealed that an employee has committed fraud, corruption or any other related incidents, the following may be recommended by the Head of
Investigations:
Taking disciplinary action;
Instituting recovery of financial losses;
Initiating criminal investigation process by reporting the matter to the appropriate law enforcement agencies;
Identifying internal controls to be improved;
Any other appropriate action available.
14.4.4
14.4.5
14.5
14.6
15.4
The Head of the Unit/Department, upon receiving the report from The Office of the Head: Investigations shall acknowledge such and inform The Office of the Head: Investigations of their intentions with respect to the recommendations of the report within 10 days.
In respect of all reported incidents of fraud, corruption, or any other related incidents, the managers of respective
Units/Departments must review and improve the effectiveness of internal controls which have been breached within a reasonable period in order to prevent similar irregularities from
14.7
College as a result of all reported acts of fraud or corruption or any other dishonest activities of a similar nature committed by an employee or any other person in their own units/departments, are recovered from such an employee or other person if he/she is found to be liable.
15.
IMPLEMENTATION OF THE POLICY:
15.1
occurring in the future.
The Heads of Units/Department and their respective managers must ensure that losses or damages suffered by Waterberg FET
It is the responsibility of all Deputy Managers and Heads of
Units/Department (including managers at all levels) to ensure that all employees are made aware of and receive appropriate education and training on Anti-Fraud and Corruption Plans and
Code of Ethics/Conduct and that such has been cascaded.
15.2
15.3
The Office of the Head: Investigations with the assistance of the Communications Unit shall be responsible for communicating the relevant sections of this policy and plan thereto to the members of the public and other external stakeholders.
Once the Anti-Fraud and Corruption policy and Fraud plan are in place, the Manager and Head: Investigation will establish the Corruption and Fraud Prevention Committee, which will be responsible for the ongoing maintenance and review of fraud plan/strategy.
The scope of this committee should include but not limited to:

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15.4.1
15.4.2
15.4.3
The evaluation of reports of fraud and corruption and highlighting of areas of risks within Waterberg FET College;
The consideration of fraud and corruption threats to the
Waterberg FET College and making of recommendations to appropriate structures;
Monitoring of actions taken to implement recommendations relating to incidents of fraud and corruption or other
15.4.4
15.4.5
similar or related inappropriate conduct;
Keeping of Integrity Personnel Data for all disciplined employees and External Stakeholders.
Reviewing and making of appropriate amendments to the antifraud and corruption policy and fraud plan should they be required and
15.4.6
Ensuring that ongoing implementation strategies are developed and carried out.
16.
CONSEQUENCES FOR BREACHING THE PROVISIONS OF ANTI-FRAUD AND ANTI-
CORRUPTION POLICY:
16.1
Breach of any provisions of this policy by any Waterberg FET
College employee or any person having dealings with Waterberg
FET College shall amount to misconduct and shall lead to disciplinary action and/or laying of criminal charges with dismissal consequences.
17.
PUBLICATION OF SANCTION:
17.1
A brief and anonymised summary of the circumstances will be published in order to send a deterrent message to other employees but the CEO or Accounting Officer or Information
Officer will decide whether it is just for any information relating to corrective actions taken or sanctions imposed regarding incidences of fraud, corruption or any other dishonest activities of a similar nature, should be brought to the direct attention of any person or made public through any means.
17.2
All Anti- Fraud and Corruption activities, including the adoption of this policy, will be publicized to make employees and the public aware of the Council’s commitment to taking action on fraud and corruption, when it occurs.
18.
CONCLUSION:
18.1
18.2
The Waterberg FET College has a clear commitment to minimizing the possibility of fraud, corruption or any other dishonest activities of a similar nature. It pledges not only to prevent fraud and corruption or any other dishonest activities of a similar nature but to take all action necessary to identify such and pursue the recovery of losses and the punishment of those responsible.
The Waterberg FET College employees are expected to have the highest standards of conduct and to be vigilant in combating fraud and corruption or any other dishonest activities of a similar nature in all its guises.

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18.3
The Waterberg FET College has embarked on implementing a clear network of systems and procedures to assist in the fight against fraud and corruption or any other dishonest activities of a similar nature. The Anti Fraud and Corruption Prevention
Plan and awareness campaigns will keep pace with any future developments, in both preventative and detection techniques regarding fraudulent or corrupt activities or any other
19.
APPROVAL AND EFFECTIVE DATE OF THE POLICY: dishonest activities of a similar nature that may affect its operations.
The Anti-Fraud and Corruption Policy and Fraud Plan shall come into effect immediately upon approval by the Council of Waterberg
FET College.
20.
FRAUD ACTION PLAN SCHEDULE:
ACTIVITY RESPONSIBLE PERSON DUE DATE
Incorporation of a Fraud
Prevention Committee
Development of a Fraud
Policy
CEO
Internal Auditor
Promotion of a Code of
Conduct for all employees
Information session on
Corporate Governance in the
Public Sector
Strengthening disciplinary processes
Introduction of employee screening before appointment
Already exist - let it be signed
Human Resource
Human Resource
Human Resource
Inform all staff of the
Protected Disclosure Act
Promoting whistle blowing channels
Compile a fraud risk map
Internal audit
Audit Committee
CEO