Fraud and Corruption Prevention Guide

 Note: The bank’s adherence to this manual represents a fundamental step towards a fair and safe banking environment.

1. Scope:-
   This procedure applies to all employees in the departments and branches of the Iraqi Islamic Commercial Bank. 
   
   
2. Objective:-
   This manual aims to help the bank develop and implement an effective framework to combat fraud and corruption, in line with local and international standards, and to enhance public confidence in the banking system.
   
   
3. Definitions:-
   • Fraud: Any deliberate act intended to achieve an unlawful benefit, including, for example, theft, forgery, acceptance of gifts, bribery, embezzlement, data manipulation, or the use of inside information for personal purposes.
   • Corruption: The misuse of public authority or position to achieve private benefits, including bribery, favoritism, abuse of influence, and extortion.
     
     
4. Responsibilities:-
   Employees working in the Legal Department. 
   
   
5. Work Methodology:- 

General Principles for Combating Fraud and Corruption

1. Commitment to integrity and transparency.
2. Accountability at all administrative levels.
3. Application of the principle of segregation of duties.
4. Existence of effective internal control systems.
5. Protection of whistleblowers and ensuring their confidentiality.

1. Institutional commitment.
2. Prevention.
3. Monitoring and reporting.
4.  Investigation.
5. Sanctions.
6. Awareness and training.
7. Continuous review.

Institutional and Organizational Framework

1. Formation of a permanent committee to combat fraud and corruption.
2. Development of a written and clear policy.
3. Integrating anti-corruption into the bank’s overall strategy.

Mechanisms for Detection and Prevention

1. Regular internal control.
2. Periodic review of accounts and procedures.
3. Training employees.
4. Use of technology.
5. Confidential reporting systems. 

Investigation and Handling Procedures

1. Receiving reports.
2. Forming investigation teams.
3. Maintaining confidentiality.
4.  Taking necessary measures.

Cooperation with Regulatory and Judicial Authorities

Evaluation and Updating

1. Periodic review.
2. Updating manuals and policies.
3.  Preparing periodic reports. 

Training and Awareness Plan

1. Organizing workshops and training courses on:
    - Common fraud methods.
   - Methods of detection and reporting.
   - Mechanism for dealing with violations.
2. Preparing periodic awareness bulletins for employees and bank customers .
3.  Engaging new employees in courses upon appointment.

Operating Procedures for Combating Fraud and Corruption

1. Upon receiving a report:
      - Register the report in the designated log.
      - Refer the report to the relevant department (Legal Department, Human Resources Department, Compliance Officer, Risk Management).
      - Form an investigation committee consisting of at least 3 members.
      - Conduct the investigation within a period not exceeding 15 days.
      - Issue recommendations and submit them to senior management.
2. Protection measures:
      - Maintaining the confidentiality of the whistleblower’s identity.
      - No disciplinary action shall be taken against a whistleblower acting in good faith.
3. After completion of the investigation:
      - Taking the necessary legal measures.
      - Informing the official authorities if necessary.

Approved Forms

1. Report Form for a Case of Fraud or Corruption:
      - Name (optional) : ..............................
      - Department : ..............................
      - Details of the report : ...........................
      - Date : ...........................
      - Signature : ..............................
   
   
2. Report Follow-up Form:
      - Report Number : .............................
      - Submission Date : ................................
      - Report Status: (Under Investigation / Resolved / Referred) : ...................................
      - Employee Name : ......................................
      - Recommendations : ......................................

   
   
6. Monitoring and Verification Method: 

• Internal audit team ... when conducting audits of the bank’s departments and branches.
• Quality Management Department

7. Forms: