Managing Conflict of Interest - Organisation for Economic Co ...

Codes of Conduct in the Private Sector 173Figure 3: Antifraud Programs and ControlsAFPC = antifraud programs and controls, ICFR = internal control over financial reporting.top down. Directors and officers set the “tone at the top” for ethicalbehavior within any organization. Management cannot act oneway and expect others within the organization to behave differently.Management must show employees through its words and actionsthat dishonest or unethical behavior will not be tolerated.In addition to leading by example, management must createa positive work environment that rewards good behavior andvalues its employees. Research indicates that wrongdoing occursless frequently when employees feel valued than when they feelabused, threatened, or ignored. Negative factors that increase therisk of fraud include:•••••Perceived apathy of top management;Lack of rewards for appropriate behavior;Negative feedback or lack of recognition for jobperformance;Perceived inequities in the organization;Autocratic, rather than participative, management;ADB/OECD Anti-Corruption Initiative for Asia and the Pacific