Professional Documents
Culture Documents
1. Corruption/Collusion:
Collusion between project managers and vendors/subcontractors
including kickback schemes, bid rigging at the subcontractor level,
conflicts of interest, bribery, etc.
2. Billing:
Substitution of materials while billing for higher quality, falsification of
pay applications and billing for uncompleted work, incorrect labor
rates, etc.
3. Expense reimbursement:
Falsifying invoices for expense reimbursements, inappropriate use of
company credit cards and gas cards.
4. Noncash misappropriation:
Stealing the noncash assets of a company assets such as job site
supplies, equipment, scrap metal and other materials, etc.
5. Check and payment tampering:
Office employees may have the opportunity to write checks to
fictitious vendors or collect checks from customers and hide the
activity through entries to the general ledger.Bribery/corruption
6. Often collusion by two parties entering into a secret agreement
whereby a financial incentive is made for securing a particular
outcome. Examples include the awarding of a public or private
contract or purchasing property on ‘favourable’ terms.
7. Fictitious vendors
8. These are created by falsifying payment applications, covering up
the purchase of personal items or diverting money to a phantom
company. Activity is often controlled by an employee but can also
be done by external entities through falsified company
documentation or email addresses.
9. Change order manipulation
10. Diverting lump-sum cost to time and material cost by initially
budgeting expenses as a lump sum then billing for time and
materials related to change orders.
11. Theft or substitution of materials
12. Taking material from the work site for personal use or using
lower-grade material than quoted, which might result in
subsequent repairing or replacement.
13. False representation
14. This might involve using undocumented workers; falsifying
minority content reports, test results or insurance certificates; non-
compliance with environmental regulations; and misrepresentation
of small business status.
15. Money laundering/tax avoidance
16. This is activity to legitimise money gained illegally. In real
estate it could include making down payments on property and
selling at a later date to give the money a legitimate origin. Tax
avoidance can involve commonplace activity such as paying cash-
in-hand for labour.
17. Charging for superior materials, but using sub-par materials
18. Padding timesheets
19. Skimping on safety, for employees and clients
20. Changing salary terms
21. Bribing inspectors and potential clients/representatives
22. Treating workers unfairly
23. Not following environmental regulations
24. False variation claims
Solution:
Establish strong internal controls and enforce them: