Infographic Template Galleries

Created with Fabric.js 1.4.5 Building Strong T&E Controls Case Review of Bruker Corporation What Went Wrong? Controls ADI has in place 1. Inadequate monitoring: Bruker failed to adequately monitor and supervise the seniorexecutives at the Bruker China office to ensure that they kept accurate recordsconcerning payments to Chinese government officials. 2. Management override: Bruker failed to tailor its pre-approval processes for conditions in China, instead allowing the Bruker China offices approval over itemssuch as non-employee travel and changes to contracts.3. Lack of intervention: Bruker also failed to have an independent compliance staff or internal audit function to intervene into management decisions and take remedial actions. 1. Management has established policies and procedures governing employee business travel and expense reimbursement and such policies are updated frequently and communicated to employees.2. Travel is booked through the approved travel agency, approved by the employee's immediate supervisor and allowable per the terms of the contract.3. Pre-approval of expenses over a certain threshold. 4. Travel policy requires documented business purpose, location, attendees, dates and employees must provide receipts for any travel expenses over $75. The Case 1. Continue to promote responsibilities supervisors responsibilities to only approve expense reports that comply with CPM requirements, and to perform their review timely.2. To increase the likelihood that expense reports capture all required data consistently, the Manufacturing Controller should replace QuickPay with Concur.3. The Manufacturing Controller should modify the CPM to require submission of expense reports within 60 days of being incurred. Also, expense reports submitted 360 days after the expense was incurred should only be approved to be reimbursed by a Vice President. Outstanding Items On December 15, 2014, Bruker Corp., the Billerica-based scientific instruments manufacturer, has agreed to pay $2.4 million to settle SEC’s charges that it violated the Foreign Corrupt Practices Act by bribing Chinese government officials in an effort to win sales contracts from at least 2005 through 2011. The SEC said Bruker "lacked sufficient internal controls to prevent and detect approximately $230,000 in improper payments out of its China-based offices that falsely recorded them in books and records as legitimate business and marketing expenses."
Create Your Free Infographic!