Developed by the City of Toronto

A fraud/dishonest activities policy sets out specific guidelines and responsibilities regarding appropriate actions that must be followed for investigation of dishonest activities such as fraud and other similar irregularities.

A fraud/dishonest activities policy is an important part of risk management and internal control. It ensures that the Board of Directors and all employees and agents of the corporation understand what the Board of Directors considers dishonest activity, what actions to take when inappropriate activity is suspected, and what the consequences will be for any member of the Board, staff or agent who engages in inappropriate activity.

The Board of Directors must establish a policy for the corporation that clearly communicates the behaviour expected of themselves, staff and agents when doing corporation business.

Creating and maintaining your fraud/dishonest activities policy

  • Follow the steps below and tailor it to your organization’s needs.
  • All members of the Board of Directors, staff, and agents of the corporation should review the policy annually, and make any necessary revisions. They should declare, in writing, that they have reviewed the policy.
  • Ensure your policy includes the requirement to report fraud/dishonest activities to the City of Toronto and others as required, as explained below in the General Policy and Responsibilities section
  • Ask to see written declarations that staff and agents have reviewed the corporation’s fraud/dishonest activities policy.