RECOMMENDATIONS

Specific

 The Board should not be chaired by the Chief Executive Officer. If there will be
nobody to observe the actions of the CEO, it'll give the latter the chance to
commit fraud.

Measurable

 Legal division of the corporate should be strong and active. Further, lawyers
should be consulted on most matters to supply employees job protection, if they
revert to whistle blowing.
 The company must increase the experience and depth of its financial
management and accounting personnel.
 Review, monitoring and oversight of the worldwide units to be increased.

Achievable

 The top management should also attempt to ensure that realistic targets are set
for the lower management. If the targets seem to idealistic, the pressure may
encourage management to report a false picture.

Relevant

 To try to enhance the employees’ ethical values and encourage them to act
responsibly by the time fraudulent activities come to their notice, the company’s
organizational culture should even be made consistent throughout the firm.
 The company should make sure that all the external auditors are given the data
what they require, and these external auditors should be independent of the
company’s influence.
 The company must implement procedures and controls to review, monitor, and
maintain book of account accounts.
  Significant improvement has to be made in segregation of duties, responsibilities
and management review controls.

Time-based

 A corporate code of conduct should be established to guide the behaviors of all

employees, including Chief Financial Officer and Chief Executive Officer, within
which there's not only principles providing basic guidelines to follow like the
consistency, sincerity and honesties applying to a company’s operation, but also
rules providing specific boundaries which behavior is nott allowed or will suffer
from penalties that help maintain a well and behavioral corporate culture.