1. Sharing Ideas: Detection and Prevention DII Best Practices Forum Charlie Chadwick Karen Clapsaddle June 5, 2014

2. 2 Session Structure Poll audience on three topics: –Supply Chain –Recording Transactions –Retaliation in the Workplace Assign one of three topics to each table –15 minutes for discussion –Each table assigns a scribe. Scribe will email key discussion points to: dgiardina@crowell.com dgiardina@crowell.com Include “Detection and Prevention” in the subject line A compilation of notes will be posted to the DII web site. Review polling question results. 10-min debrief on each topic, highlighting best practices. Chatham House Rule applies.

3. 3 Discussion Topics Supply Chain –Gaps identified and controls put in place to prevent and detect noncompliance and fraud. Recording Transactions –Gaps identified and controls put in place to prevent and detect both intentional and non-intentional inaccurate recording of labor and other costs Workplace Retaliation –Gaps identified and controls put in place to prevent and detect negative possible retaliation against reporting parties

4. 4 Topic Assignments by Table Supply Chain : Tables 1-10 Recording Transactions : Tables 11-21 Retaliation : Tables 22- 30+

5. 5 Supply Chain Poll What percentage of your ethics inquiries (helpline/in person/web based) concern supply chain issues? A.less than 5% B.6-15% C.16-25% D.greater than 25%

6. 6 Supply Chain Poll Do Primes require you, or if you are Prime do you require Suppliers, to comply with the Prime’s Code of Conduct? A.Yes, the relevant sections are included in the Purchase Order. B.Yes, Primes provides Suppliers with copies of Prime’s code. C.No, but Primes confirm that Suppliers have a Code of Conduct. D.I’m not really sure.

7. 7 Recording Transactions Poll How great a concern is labor mischarging in your organization? A.We have it under control B.We get allegations but don't consider the number to be alarming C.Enough allegations are received to make it a focus area D.It's a major problem for us

8. 8 Recording Transactions Poll How great a concern is financial mischarging (other than labor) in your organization? A.We have it under control B.We get allegations but don't consider the number to be alarming C.Enough allegations are received to make it a focus area D.It's a major problem for us

9. 9 Fear of Retaliation Poll Is retaliation a concern in your company? A.We have it under control B.We get some allegations but don't consider the number to be alarming C.Enough allegations are received to make it a focus area D.It's a major problem for us

10. 10 Fear of Retaliation Poll Do you have a formal set of controls to prevent retaliation in your company? A.Yes B.No

11. 11 Supply Chain Discussion Questions With an increased focus on compliance and fraud prevention in the supply chain, what specific controls has your organization implemented? As either a supplier or a prime contractor, what controls are in place to address supplier due diligence? From both perspectives (supplier and prime) what compliance practices have a beneficial cost/benefit ratio?

12. 12 Recording Transactions Discussion Questions What controls (including automated controls) do you have in place to prevent failures in recording financial transactions? What obstacles or gaps do you face in controlling improper financial transactions? What organizations within your company are responsible for investigation improper transactions and how do these organizations interact?

13. 13 Workplace Retaliation Discussion Questions What controls are in place at your company to prevent and/or detect retaliation against reporting parties who have raised an ethics or compliance issue? How are your ethics officers specifically trained to detect and investigated potential retaliation? How do you engage leadership to increase transparency and help mitigate the risk of perceived retaliation among employees?

14. 14 Topic Debriefs And Poll Results Supply Chain : Tables 1-10 Recording Transactions : Tables 11-21 Retaliation : Tables 22- 30+