Clarien is committed to maintaining the highest ethical standards in everything we do. The Fraud & Ethics Hotline serves as a critical tool in this effort by providing a way for employees, shareholders, directors, contractors, vendors, agents, and other third parties to anonymously report suspected illegal, unethical, or unsafe activity in connection with Clarien’s business operations.
What types of items should I report?
Reportable activities include, but are not limited to, the following:
◦ Actions that are improper or contrary to Group policy or standard accounting practice when handling or reporting money or financial transactions
◦ Forging, altering or misappropriating of any bank instrument or security
◦ Forging or altering any document or account without proper authorization
◦ Falsifying payroll records
◦ Falsifying travel and entertainment expenses and/or utilizing bank funds to pay for personal expenses
◦ Financial report misrepresentation (improper earnings management, improper revenue recognition, overstatement of assets, understatement of liabilities, misapplication of generally accepted accounting principles)
◦ Misappropriation of Group assets
◦ Unauthorized non-business acquisition, use, or disposition of funds, inventory, furniture, fixtures, equipment, records, or other assets
◦ Unauthorized destruction, removal, or inappropriate use of funds, securities, supplies, inventory, or any other asset including furniture, computers, fixtures or equipment
◦ Authorizing or receiving payments for hours not worked
◦ Accepting or seeking anything of material value from contractors, vendors, or persons providing services/materials that may be construed as an attempt to influence or bribe the performance of an Employee’s official duty in the scope of employment
◦ Kickbacks or other offers in exchange for granting of business
◦ Falsifying information contained in loan documents, such as identification, employment, income or appraisal documents
◦ Theft of custodial funds
◦ Misrepresentation of collateral in loan or other documents
What types of items should I NOT use the Hotline to report?
It would not be appropriate to use the Hotline to report the following:
◦ Emergencies or other immediate public safety concerns (Call 911)
◦ Complaints against business processes and/or products
◦ Other issues that do not involve CLARIEN operations or employees
When can I use the Hotline?
The Fraud & Ethics Hotline operates 24 hours a day, 7 days a week, 365 days a year.
Can I remain anonymous?
Yes! You do not have to give your name and the Hotline service does not provide CLARIEN any other identifying information.
Who can I call for more information about the Fraud & Ethics Hotline?
Contact the Head of Internal Audit at 441.294.5199, the Bank’s Legal Counsel at 441.294.5181, or the Chief Risk Officer at 441.294.3145.
You may contact the Head of Internal Audit, the Bank’s Legal Counsel or the Chief Risk Officer directly at any time to report actual and/or suspected fraud or related misconduct. We will protect your confidentiality and anonymity to the extent permitted by law.