Global Economic Crime Survey - Engineering and

Transcription

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Global Economic Crime Survey
March 2010
Engineering and construction
sector summary
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Introduction
Key findings of report:
• 24% of E&C companies have
experienced economic crime in
the last year;
• more sophisticated frauds such as
accounting fraud and bribery and
corruption are on the increase;
• bribery and corruption is more
prevalent in the E&C sector than
in the wider business world, 29%
of those reporting crimes for the
E&C sector versus 13% across all
industries were impacted by it;
• whilst the financial impact of
fraud was consistent with other
sectors, employee morale is more
damaged in the E&C sector than
in other sectors;
• over a third of E&C companies
had not performed a fraud risk
assessment in the last twelve
months and another third had
not increased the frequency of
those reviews; and
• the significant majority (69%) of
reported economic crime in the
E&C sector is committed from
within organisations.
Engineering and construction sector summary • March 2010
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We are delighted to present our fourth Engineering and Construction
(E&C) sector Global Economic Crime Survey. Our survey scrutinises
fraud and associated integrity risks during a period in which most
territories around the world experienced either a dramatic economic
downturn or at the very least a significant slowdown. Against this
backdrop, the survey investigates the root causes of economic crime
and the way in which it affects businesses worldwide.
Economic crime is a truly global phenomenon. This year over 3,000
senior representatives from organisations across 54 countries
completed our web based survey. The E&C sector was well
represented, with 226 respondents spread across 43 countries. These
responses were received from a cross section of management levels,
from board members to managers, and their companies varied widely
both in size and in ownership structure. Of the 226 E&C respondents,
36% came from listed companies, 62% from organisations trading in
multiple countries and 62% from organisations with an employee base
in excess of 200.
This year’s survey asked respondents to focus their responses
specifically on their experiences over the last twelve months, with a
view to developing an understanding of the fraud threats that emerge
during an economic downturn. The responses suggest that the E&C
sector continues to face the effects of the economic downturn, with
65% of respondents stating their organisations had experienced a
decline in financial performance over the last twelve months. Many
E&C respondents, nearly a quarter (24%), also reported they have been
contending with economic crime during this period.
In addition to investigating the root causes of economic crime and the
way in which it affects businesses within the E&C sector, this summary
also examines the changing trends in economic crime within the E&C
sector worldwide during a time of unprecedented economic and
regulatory change. We hope that the findings will encourage business
leaders within the E&C sector to review their companies’ anti-fraud
policies and procedures, and to consider whether they are appropriate
for the dynamic business environment.
PricewaterhouseCoopers 1
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Bribery and corruption –
a perennial problem in the
E&C sector
Asset misappropriation has remained
the most common economic crime in
each of our surveys since 2003, and the
E&C sector remains particularly vulnerable
to this type of fraud. Given the nature
of many engineering and construction
projects, personnel often have remote
and sometimes unsupervised access
to valuable plant and materials. The
misappropriation of these items remains
a real problem for the industry, in spite
of efforts to ‘chip’ or use tracking devices.
In addition, the large quantities of
materials used on many engineering and
construction projects, combined with
the difficulty in estimating accurately
the quantity of materials required for
construction, makes E&C organisations
susceptible to over-ordering and
subsequent re-selling of construction
materials from site.
The E&C sector has a number of
characteristics which makes it particularly
vulnerable to economic crime. These
include projects with multiple contractual
arrangements, often across geographic
borders, use of agents and a heavy
involvement with governments and
state-owned organisations.
The industry has also under-invested in
systems and preventative controls and
lacked standardisation of process.
Asset misappropriation,
accounting fraud, bribery
and corruption
The prevalence of accounting fraud within
the E&C sector has increased significantly
since our last survey in 2007. This type of
fraud includes accounting manipulations,
fraudulent borrowing/raising of finance,
fraudulent applications for credit and
unauthorised transactions/rogue trading.
The 2009 survey found that overall the
three most common types of economic
crimes experienced in the last twelve
months in the E&C sector were asset
misappropriation, accounting fraud and
bribery and corruption.
Figure 1: Trends in reported frauds for the E&C sector
Asset misappropriation
64
20
Accounting fraud
38
38
Bribery and corruption
0
10
20
30
40
47
50
% companies
2007
68
2009
% respondents who experienced economic crimes
60
70
80
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Figure 2: Reported frauds for the E&C sector versus all industries
64
Asset misappropriation
67
38
38
Accounting fraud
Bribery and corruption
47
27
IP infringement, including
theft of data
15
15
4
Money laundering
Illegal insider trading
4
Espionage
3
Market fraud involving cartels
colluding to fix prices
3
Tax fraud
12
6
6
6
5
0
9
10
20
30
40
50
60
70
80
% reported frauds
E&C sector
All industries
% respondents who experienced economic crimes
This may well be linked to the economic
downturn. Current economic conditions
may have exacerbated an existing trend.
As can be seen in Figure 1, which
shows a trend in reported frauds for
the E&C sector, the percentage of those
respondents reporting ‘accounting fraud’
has been steadily rising over time,
increasing from 20% in 2007 to 38% in
2009. While asset misappropriation will
continue to be a major concern for the
E&C sector, fraudsters are also becoming
more sophisticated and branching out into
other types of economic crime.
Figure 1 highlights that the rate of ‘bribery
and corruption’ for the E&C sector has
been on the upswing over time, increasing
from 38% in 2007 to 47% in 2009. The
bribery and corruption figure for the
E&C sector (47% in 2009) was the largest
of any sector and well above the average
across all industries (27% in 2009)
(see figure 2).
The E&C sector has a history of bribes
being paid to those procuring or having
influence over the procurement of
construction works so as to either avoid
competitive tendering, gain higher
margins, or reduce tendering costs.
Additionally, in the complex world of
construction pricing and competitive
tendering, there is often a lack of
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transparency in relation to risk pricing,
overhead recovery, contingency
allowances and profit margins. This lack
of transparency, combined with the
pressures of the competitive tendering
process, make the construction industry
particularly susceptible to corruption. The
E&C sector has exposure to corruption
risks through large-scale contracts, often
for the public sector, frequently in the
more lucrative emerging markets, and
typically involving complex supply chains
and increasingly cut-throat competition.
Organisations in the E&C sector need to
exercise a heightened awareness of this
area as the consequences for
organisations found guilty of corruption
can be far reaching and long lasting.
Transparency International – the global
anti-corruption organisation – publishes
Bribery & corruption
A multinational company discovered it
was paying overseas agents sales
commissions of up to 50% of the sales
value in some territories. It was unclear
what services the agents were providing,
whether they had the required expertise
and whether their services were being
provided at a fair market value. There
were no anti-bribery provisions in the
agency contracts that required the
agents to conduct themselves in line
with regulations, nor was there any
provision for transparency and access to
agents’ books.
Recommended remediation process:
annually ‘The Bribe Payers Index’, which
in 2009 showed that construction
companies are amongst the most likely to
pay bribes when dealing with the public
sector, ahead of the arms, defence, and
oil and gas industries. Construction
companies were also found to be the
most likely to exert undue influence on
governments’ policies, decisions and
practices and, along with those in heavy
engineering, were seen to be the most
likely to bribe government officials.
The risk of bribery and corruption is
present in most transactions and
territories in which organisations operate.
Of particular concern are dealings with
government officials in emerging markets,
where bribery and corruption can be more
prevalent, and where the organisation
uses sales agents, reducing internal
• Standardised agency agreements to
include anti-bribery representations
and warranties
• Monitored the performance of
overseas agents
• Issued clear policy on what
constitutes unacceptable behaviour
• Trained employees on the impact
of international anti-corruption
regulation
• Installed internal control procedures
requiring pre-authorisation for any
commissions paid on third party
agency agreements
• Performed due diligence on overseas
agents and their services
control over the procurement process.
Sixty-two percent of E&C respondents
stated their organisations had offices
in more than one country; many of these
offices fall into one or both categories.
The consequential increase in fraud
risk exposure needs to be appropriately
managed.
The sector is typified by customised
contracts, suffers from a lack of relevant
cost benchmarks and continually faces
challenges around the levels of governance
expected and specified in relation to supply
chain performance. The consequence is a
wealth of opportunities for value leakage
and waste. Owners, procurement agencies
and funders need to press the sector for
increased transparency of cost elements and
enhanced management accountability within
their conditions of contract, to remove the
ability of suppliers to hide uneconomic costs
as part of the overall construction costs.
The sector needs ‘intelligent’ clients with
integrity to lead this process of change
in order to make the processes credible
and transparent. We are seeing a trend
emerging in certain sectors of the industry
for project owners to seek additional
specificity and transparency in contract
commercial terms, despite the objections
of contractors seeking to maintain flexibility
in their contracting approach through more
ambiguous commercial terms.
Regulation
In recent years there have been changes
in attitudes towards bribery and
corruption globally, resulting in increased
regulatory enforcement. This trend is likely
to continue as more territories introduce
or strengthen anti-corruption legislation
and/or strengthen enforcement in
response to global pressures.
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E&C companies should consider:
• Performing financial, technical and
operational due diligence on their
business partners, personnel and
contracts involved in a new-market
expansion;
• Issuing clear company policy
on what constitutes unacceptable
behaviour, and enforcing the
prescribed consequences;
• Thoroughly (and annually) training
employees to address the impacts
of international anti-corruption
standards;
• Reinforcing ethics and compliance
by top down communications and
requirements for periodic written
statements of compliance from
key employees;
• Performing random field tests/
inspections to determine whether
employees understand company
compliance policy;
• Streamlining and integrating
payment systems to make it easier
to identify where, why and how
much money is being spent; and
• Regularly testing payment
systems and controls to assess
the proper accounting of all
project expenditures.
With many parts of the global economy flat
or still in recession, pressure on
governments to better control spending on
public works is likely to continue. Coupled
with the introduction of new industry
regulation, this means that E&C companies
face an increasingly competitive outlook.
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Contributory factors
The global economic downturn has
significantly increased pressures on
organisations and individuals to improve
efficiency and reduce costs, creating
more incentives and opportunities for
fraudsters. Respondents to the survey
were asked what they felt the most likely
reason for greater risk of fraud was, in the
current economic environment, based on
the three components of the fraud triangle;
opportunity, incentive and rationalisation.
The fraud triangle describes the
interconnected conditions that act as
harbingers to fraud: opportunity to
commit fraud, incentive (or pressure) to
commit fraud, and the ability of the
perpetrator to rationalise the act.
Figure 3: Fraud triangle
E&C sector
Incentive or Pressure
72%
!
17%
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‘The belief is that competitors are
paying bribes to win work. That this
may be influencing behaviour is
concerning and could create a
downward spiral unless reisisted’
Jonathan Hook
Global E&C leader
Far more respondents (72%) see increased
pressure and incentives to commit fraud
as the most likely reason for a greater risk
of fraud within their organisation. Many
All industries
organisations are
indeed facing tough
times, with 65% of respondents stating
Incentive or Pressure
that their organisations
68% had experienced a
decline in financial performance over the
last twelve months.
!
FRAUD RISK
Opportunity
E&C sector could run the risk of reduced
governance as a result of redundancies
and streamlining. Relatively few
respondents see increased opportunity
as a serious issue. However, given the
pressures of the economic downturn,
many companies have downsized or
abolished central procurement functions,
and are now delegating responsibility for
material ordering to site managers in a
drive to reduce overheads and remain
competitive. An individual site manager
may consequently be responsible for all
stages of procurement, from ordering
through to certifying payment. Such
changes do, in our view, increase the
opportunity for fraud.
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Attitude/
Rationalisation
11%
% companies
Only 17% of respondents believe the
increased risk of fraud is due to increased
opportunities for fraud in the current
economic environment, as costs are cut
and gaps appear in control systems.
This perspective suggests that the
Survey respondents report that the two
most important issues contributing to the
increasing pressure and incentive to
commit fraud in the current economic
FRAUD RISK
environment are;
targets have become
more difficult to achieve (50%)
Attitude/ and fears
Opportunity
Rationalisation
over job loss
(40%).
These
factors provide
18%
14% increase
further insight into the significant
in accounting fraud
in the E&C sector that
% companies
we noted earlier.
Of those respondents who cite increased
pressures and incentives as the most
likely reason for greater risk of fraud, a
significantly higher proportion of E&C
respondents attributed this to the belief
that competitors are paying bribes to win
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contracts. Indeed, as governments cut
back on capital spend, the pressure to
achieve turnover targets, maintain
profit margins and fill order books will
only increase.
When compared with the average across
other industry sectors, more than twice
the number of respondents (29% versus
13%) from the E&C sector say that there
is a belief that competitors are paying
bribes. This stems from the historic
prevalence of bribery within the sector
which is continually reinforced with
cases of corruption publicised on an
increasingly regular basis.
Beyond the financial
consequences
Of the E&C respondents that reported
incidences of fraud over the last twelve
months, eleven companies said that the
direct financial impact of this exposure
was more than US$500,000 and two
others reported an impact of over
US$5million. Perhaps more significantly,
our survey revealed that E&C companies
are proportionately more susceptible to
the collateral damage caused by
economic crime.
This is likely to reflect a tough environment
for bidding on work and maybe an element
of rationalisation by companies who have
lost bids. However it also reflects some of
the negative publicity the sector has
received and shows that even within the
industry, at a minimum, there is a serious
perception problem with regards to
instances of paying bribes to win work.
Reputation and business relationships are
considered to be particularly vulnerable in
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Figure 4: Factors contributing towards increased incentives/pressures to commit fraud
Financial targets more difficult to achieve
47
Fear of losing jobs
37
24
Desire to earn personal performance bonuses
For senior management to achieve
desired financial results
18
There is a belief that competitors are
paying bribes to win contracts
26
29
13
5
Others
0
29
29
23
Maintain financial performance to ensure
lenders do not cancel debt facilities
40
27
25
Bonuses not paid this year
50
14
10
20
30
40
50
% Incentives/pressures
E&C sector
All industries
% respondents who believe increased incentives/pressures are the most
likely reason for greater risk of economic crime in a downturn
the E&C sector and in a low margin
industry like construction, where there are
high value contracts, the financial
consequences may have had more impact
on the overall financial health of those
organisations and lost jobs. This is
perhaps inevitable when considering the
nature of the industry with a complex
supply chain where owners rely heavily
upon past experience and a track record
of delivery on time and on budget. If there
is a view that corruption is endemic in a
sector, individuals may fear for their own
reputations, or be uneasy about pressure
to manipulate results or pursue unethical
courses of action.
Perhaps even more striking is that 55%
of E&C respondents found that the
economic crimes experienced by their
companies had a significant impact on
employee morale, compared with 32%
in all industries (see figure 5). In addition
to damaging employee morale, economic
crime has long lasting impacts on
business relationships and can lead to
a complete erosion of trust. Success in
the construction sector relies heavily on
developing leadership skills, teamworking
and the ability to sustain relationships
with a variety of suppliers of goods and
services. Therefore the impact of fraud
on businesses within the sector can
be significant.
The cost of collateral damage should be
of real concern to organisations. Headlines
about fraud within the sector affect not
only the employees of the organisation;
our survey results suggest there are further
impacts on investors, suppliers, customers
and potential recruits (see figure 5).
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Figure 5: Collateral damage
Figure 6: Detection methods for the E&C sector from 2009 and 2007 surveys
Employee morale
55
32
Business relationships
Reputation and brand
Internal audit
31
23
Share prices
4
0
4
4
Corporate security
13
6
13
1
Suspicious transaction reporting
16
16
Relationships with regulators
1
Rotation of personnel
7
2
11
3
16
Tip-off (internal)
10
20
30
40
50
60
% all respondents
E&C sector
All industries
% respondents who experienced economic crimes in the last 12 months
Detection methods
This year’s survey showed that the
majority of frauds across all industries
were detected by internal audit.
In the E&C sector, 26% of frauds reported
were detected by internal audit in 2009
(see figure 6). This represents a significant
increase from a level of 16% in 2007.
In the E&C sector, economic crimes
discovered by chance, through tip-offs
or by accident, reduced from 47% in
2007 to 31% in 2009. This is a positive
change for the sector and may highlight
a greater awareness of the value of
preventative measures.
Our survey also found that there was
a correlation between the level of
economic crime experienced and
how often a risk assessment had been
performed, with those that carried out
regular fraud risk assessments reporting
more fraud. Put another way, more
6
Tip-off (external)
Whistle-blowing system
8
Within the E&C sector, 67% of respondents
said that the frequency of conducting risk
assessments had not changed compared
to twelve months ago. More than a third,
(35%) of E&C respondents have not
performed a fraud risk assessment at all
in the last twelve months.
Organisations need to be continually
assessing fraud risks and the importance
of addressing fraud risks needs to be
conveyed from the top of an organisation.
In addition, as construction projects tend
to combine different companies and
people within project teams, there is
an increased need to review the threats
and weaknesses in project management
systems, especially when joint ventures
are formed or new business relationships
established.
9
9
9
0
4
5
Other detection methods
effort expended looking for fraud
results in more fraud being found.
23
15
By accident
By law enforcement
26
16
Fraud risk management
29
19
Impact of other areas
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0
16
5
10
15
20
25
30
% reported frauds
2009
2007
% respondents who experienced economic crimes in the last 12 months for 2009;
and in the last two years for 2007
A comprehensive fraud risk assessment
should:
• Identify the potential inherent fraud
risks and likely “gateways” to fraud.
• Assess the likelihood and
significance of occurrence of the
identified fraud risks.
• Evaluate which people and
departments are most likely to
commit fraud and identify the
methods they are likely to use.
• Identify and map existing preventive
and detective controls to the relevant
fraud risks.
• Evaluate whether relevant controls
and processes are effectively
designed to address identified
fraud risks
• Identify and assess residual fraud
risks resulting from ineffective or
non-existent controls.
• Respond to residual fraud risks.
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Know your enemy
would normally have the greatest
opportunity to commit fraud within an
organisation. They know what controls
are operating within the business and
know when effective authorisation of
expenditure checks may not be carried
out. This is also consistent with the trend
towards more complex accounting
manipulation and bribery and corruption
frauds, rather than more straightforward
asset misappropriation.
E&C organisations that have suffered from
economic crime report that a substantially
higher level has been committed by
internal fraudsters (69%) compared with
the average of all industries (53%).
The survey also highlighted that the profile
of the internal fraudster has changed.
Economic crimes committed by middle
managers have nearly doubled from a
level of 25% in 2007 to 45% in 2009 (see
figure 8). If we consider the fraud triangle
discussed previously, this is perhaps
unsurprising as it is middle managers that
Despite this, there is a widely held belief
amongst respondents in the E&C sector
that the majority of economic crimes to
be committed over the next twelve
Figure 7: Detection methods for the E&C sector in comparison with all industries surveyed
Internal audit
13
Fraud risk management
4
Suspicious transaction reporting
2
Corporate security
14
5
5
Rotation of personnel
11
5
16
16
Tip-off (internal)
6
Tip-off (external)
Whistle-blowing system
11
7
9
9
By accident
By law enforcement
26
17
0
Other detection methods
3
4
0
13
5
5
10
15
20
% reported frauds
E&C sector
All industries
% respondents who experienced economic crimes in the last 12 months
25
30
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Figure 8: Trends in the profile of internal fraudsters in E&C sector
34
Junior staff members
Middle management
52
45
25
21
Senior executives
0
10
20
23
30
40
50
60
% reported frauds
2007
2009
% respondents who reported that an internal employee was the main perpetrator of fraud
Fraud in construction
A fast-growing contractor had sublet
the construction of foundations for two
tower blocks to a specialist subcontractor.
Only when the tower blocks were nearly
completed did they realise that the
property was not constructed in line
with expected standards. It came to
light that the subcontractor had cut
corners in constructing the majority
of bored-piles supporting the towers to
avoid large penalties for late-completion.
The tower blocks needed to be
completely demolished. The directors
and staff of the subcontractor faced
criminal prosecution for conspiracy to
defraud. The main contractor’s business
collapsed as a consequence of a
massive damages claim against it in
civil arbitration.
months will be perpetrated by external
parties. This highlights a gap between
perception and reality which E&C
organisations need to address.
If organisations do not properly
understand the risk of fraud inherent
in their business, they will be unable to
Measures that would have helped to
prevent this type of fraud include:
• Assessing the risks of subcontracting
decisions and assigning the
appropriate levels of supervision
• Undertaking due diligence on
subcontractors and employees
• Considering the corporate and
personal incentives to defraud,
including disproportionately large
penalties for late completion
• Considering the opportunities
to defraud, particularly in
specialist work
develop adequate detective and
preventative internal procedures.
The lack of awareness of fraud risk is
also linked to a lack of awareness of
the necessary investment and resources
required to apply effective governance
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over the management and delivery of
large complex capital projects. There is a
growing appreciation that a combination
of leadership, people competency
and strong management systems are
required to deliver successful projects.
In the E&C sector, cost-benefit analysis
techniques of varying complexities are
commonly used to guide decision making
and the economic appraisal of options.
However, the difficulty with fraud risk is
the decision as to whether or not to
undertake dedicated programmes of
fraud risk assessment/identification.
This stems from the difficulty associated
with estimating the ‘true cost’ of fraud
and it is therefore inherently difficult to
assess whether it makes good economic
sense to pursue a fraud assessment/
identification programme.
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‘At a minimum, organisations should undertake an annual
fraud risk assessment. Building an appropriate compliance
framework won’t stop every instance of economic crime,
but it will have an impact. It is also an important part of your
defence and mitigation in the event of regulatory investigation’
Jonathan Hook
Global E&C leader
Conclusion
The results of our survey show quite
clearly that economic crime is real and
is happening within the E&C sector,
with significant consequence for those
involved. A proactive approach to fraud
risk management can protect your
business from the effects of economic
crime. There are signs that the E&C sector
is beginning to utilise the tools available
to mitigate fraud risk, with quantity of
fraud detected by chance, through
tip-offs or by accident, down 16%from
2007 (reduced from 47% in 2007 to
31% in 2009). Greater effort is, however,
still needed as the industry remains
heavily reliant on detection of economic
crime through internal audit. The adoption
of a pro-active, risk assessment, based
approach to the management and
detection of economic crime is
therefore required.
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Terminology
Due to the diverse descriptions of
individual types of economic crime in
countries’ legal statutes, we developed
the following categories for the purposes
of this survey. These descriptions were
defined as such in our survey
questionnaire.
Economic crime or fraud
The intentional use of deceit to deprive
another of money, property or a legal right.
Asset misappropriation (including
embezzlement/deception by
employees)
The theft of assets (including monetary
assets/cash or supplies and equipment)
by directors, others in fiduciary positions
or an employee for their own benefit.
Accounting fraud
Financial statements and/or other
documents are altered or presented in
such a way that they do not reflect the
true value or financial activities of the
organisation. This can involve accounting
manipulations, fraudulent borrowings/
raising of finance, fraudulent application
for credit and unauthorised transactions/
rogue trading.
Corruption and bribery (including
racketeering and extortion)
The unlawful use of an official position to
gain an advantage in contravention of
duty. This can involve the promise of an
economic benefit or other favour, the use
of intimidation or blackmail. It can also
refer to the acceptance of such
inducements.
Money laundering
Actions intended to legitimise the
proceeds of crime by disguising their true
origin.
IP infringement (including trademarks,
patents, counterfeit products and
services)
This includes the illegal copying and/or
distribution of fake goods in breach of
patent or copyright, and the creation of
false currency notes and coins with the
intention of passing them off as genuine.
Illegal insider trading
Illegal insider trading refers generally to
buying or selling a security, in breach of a
fiduciary duty or other relationship of trust
and confidence, while in possession of
material, non-public information about the
security. Insider trading violations may
also include ‘tipping’ such information,
securities trading by the person ‘tipped’,
and securities trading by those who
misappropriate such information.
Espionage
Espionage is the act or practice of spying
or of using spies to obtain secret
information.
Financial performance
This can be defined as measuring the
results of an organisation’s policies and
operations in monetary terms. These
results are reflected in return on
investment, return on assets and value
added; typically, In the private sector,
returns will be measured in terms of
revenue; in the government/state-owned
enterprises, returns will be measured in
terms of service delivery.
Fraud risk assessment
Fraud risk assessments are used to
ascertain whether an organisation has
undertaken an exercise to specifically
consider:
Fraud triangle
Fraud triangle describes the
interconnected conditions that act as
harbingers to fraud: opportunity to commit
fraud, incentive (or pressure) to commit
fraud, and the ability of the perpetrator to
rationalise the act.
Senior executive
The senior executive (for example the
CEO, Managing Director or Executive
Director) is the main decision-maker in the
organisation.
Note: In some cases percentages may not total
100% exactly as respondents were able to provide
multiple answers.
(i) the fraud risks to which operations are
exposed;
(ii) an assessment of the most threatening
risks (i.e. evaluate risks for significance
and likelihood of occurrence);
(iii) identification and evaluation of the
controls (if any) that are in place to
mitigate the key risks;
(iv) assessment of the general anti-fraud
programmes and controls in an
organisation; and
(v) actions to remedy any gaps in
the controls.
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Contacts
If you want to discuss the results of our survey and/or want to know what else your organisation should be doing to mitigate fraud risk.
Please contact us.
Jonathan Hook
(Global Engineering & Construction Leader)
[email protected]
Tel: +44 (0)20 7804 4753
UK
Anthony Morgan
(Forensic Services)
[email protected]
Tel: +44 20 7213 4178
US
Roland Sonnenberg
(Forensic Services)
[email protected]
Tel: +44 (0) 20 780 45162
Kent Goetjen (US Engineering
& Construction Leader)
[email protected]
Tel: +1 (860) 241 7009
Stephen Lechner
(Forensic Services)
[email protected]
Tel: +1 (415) 498 6596
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© 2010 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” and “PwC” refer to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). Each member firm is a separate legal entity and does not act as agent of PwCIL
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Global Economic Crime Survey - Engineering and

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