They are written for the honest employees who require a certain level of accepted and shared values and beliefs. As such, fraud policies that meet minimal legal requirements are inadequate because they lack sufficient value defining statements. The first and foremost element of any fraud policy should be an assurance that anyone involved in a fraud or dishonest act will be referred to the criminal justice system. Next, policy must overcome the perception that reporting fraud and misconduct is not socially unacceptable. The people who commit fraud and dishonest acts have a real problem that does not deserve the loyalty and protection of honest people.
Honest people have to pro-actively create a work culture that fits their shared values.
As with all documents a balance must also be presented. Baseless Allegations are those made with reckless disregard for the truth or falsity. Baseless allegations are not situations where, for example, the allegation cannot be substantiated in the investigation. The concept of accountability might be somewhat diluted from the manager of the past. The concept of accountability must be shifted to and shared by everyone.