Report an IncidentReporta un Incidente

Please provide a description of the incident you are reporting. Location, program, names, dates and times are very important for investigative purposes. We appreciate your assistance. Por favor comparte con nosotros los detalles del incidente que deseas reportar. La ubicación, campaña, nombre de los involucrados, fecha y hora son sumamente importantes para poder investigar el incidente. Agradecemos tu apoyo.

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Qualfon HotlinesLínea directa de Qualfon

Report a concern to the Qualfon Business Ethics & Values Hotline (all reports can be made anonymously): Reporta una preocupación a la línea directa de valores y ética de de Qualfon (todos los reportes pueden ser anónimos):

800.245.7770 or 855.457.1392

Philippines - +63 35 532 9055

Guyana - 265-7055

Mexico - +52 55 2122 9755

USA - 800.245.7770 or 855.457.1392

Dear Qualfon Team Members,


Recently, AT&T was fined $25 million by the United States government for fraudulent acts concerning the theft of customer information. These acts were committed by agents at several other BPO companies servicing AT&T. Hundreds of agents at those companies are losing their jobs over this and those BPO providers are going to be paying the government fines for AT&T.

Dishonest acts of fraud and theft are real. They happen everywhere–including Qualfon. (Last year Qualfon spent over $1 million on fines, penalties, and other costs associated with fraud. As terrible as this sounds, it could have been much more.) The perpetrators of these acts can cause great harm to their coworkers, the families of their coworkers, their local communities, and their employer. Acts of fraud and theft can result in hundreds or thousands of lost jobs. If that occurred at any of our Qualfon locations, it would be devastating to our employees, our families and the communities in which we work.

We all need to be aware of fraud, help identify these criminals and put them in jail where they belong. Each and every one of us has a moral and ethical obligation to get involved. We owe it to our coworkers, our families and our communities. If we suspect fraud or theft and we don't speak up, we are in effect condoning the detestable actions of the criminals. Criminals do not care about us or our families. We should have no hesitation at all about blowing the whistle on them.

To help create a safer and more secure environment for all of Qualfon, we are revamping the Qualfon Fraud Awareness and Prevention Program (FAPP). The program will help all of us to better understand the terrible consequences of fraud and theft and how we can help to prevent it and what to do when we see it happening.

Included in FAPP will be a secure and private process to report fraud and theft either by phone and/or online.

Our goal is to make lives better at Qualfon. Ignoring criminal acts or just looking the other way jeopardizes our ability to help make lives better.

Our STRIDES shield is our true protection against criminals. The "T" in our S.T.R.I.D.E.S values is for Teamwork. The "I" is for Integrity. The "D" is for Dignity. I am certain that when we take an active role to prevent fraud and theft we are living these values. I encourage everyone to take fraud and theft seriously and to actively help create a safe and secure environment at our second home that we call Qualfon. Please take the time to study the materials being distributed which have more details on FAPP.

Thank you for all you do to make Qualfon the Best BPO and Make People’s Lives Better.

-Mike Marrow
CEO

Introduction
The corporate fraud policy is established to facilitate the development of controls that will aid in the detection and prevention of fraud against Qualfon Corporation and its Subsidiaries. It is the intent of Qualfon Corporation to promote consistent organizational behavior by providing guidelines and assigning responsibility for the development of controls and conduct of investigations.

Policy Scope
This policy applies to any irregularity, or suspected irregularity, involving employees as well as consultants, vendors, contractors, outside agencies doing business with employees of such agencies, and/or any other parties with a business relationship with Qualfon Corporation and its Subsidiaries (also called the Company).

Any investigative activity required will be conducted without regard to the suspected wrongdoer’s length of service, position/title, or relationship to the Company.

Policy
Management is responsible for the detection and prevention of fraud, misappropriations, and other irregularities. Fraud is defined as the intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her injury. Each member of the management team will be familiar with the types of improprieties that might occur within his or her area of responsibility, and be alert for any indication of irregularity.

Any irregularity that is detected or suspected must be reported immediately to HD via email address, who coordinates all investigations with the Legal Department and other affected areas, both internal and external.

Fraudulent Actions
The terms defalcation, misappropriation, and other fiscal irregularities refer to, but are not limited to:

  • Any dishonest or fraudulent act
  • Misappropriation of funds, securities, supplies, or other assets
  • Misappropriation of client or client-customer funds, securities, supplies, or other assets
  • Impropriety in the handling or reporting of money or financial transactions
  • Profiteering as a result of insider knowledge of company activities
  • Disclosing confidential and proprietary information to outside parties
  • Disclosing to other persons securities activities engaged in or contemplated by the company
  • Accepting or seeking anything of material value from contractors, vendors, or persons providing services/materials to the Company. Exception: Gifts less than $50 in value.
  • Destruction, removal, or inappropriate use of records, furniture, fixtures, and equipment; and/or
  • Any similar or related irregularity

Other Irregularities
Irregularities concerning an employee’s moral, ethical, or behavioral conduct should be resolved by departmental management and the local Human Development team.

If there is any question as to whether an action constitutes fraud, contact the HD office and Legal for guidance.

Investigation Responsibility
The local Human Development team, in collaboration with the Site Director, has the primary responsibility for the investigation of all suspected fraudulent acts as defined in the policy. This team will work with Corporate Legal as required.

If the investigation substantiates that fraudulent activities have occurred, the Human Development team will issue reports to local and corporate management personnel.
Decisions to prosecute or refer the examination results to the appropriate law enforcement and/or regulatory agencies for independent investigation will be made in conjunction with legal counsel and senior management, as will final decisions on disposition of the case.

Confidentiality
The Human Development team treats all information received confidentially.

Any employee who suspects dishonest or fraudulent activity will notify senior management immediately via http://youmatter.qualfon.com/report or calling the local fraud report line immediately. should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act.

Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the Company from potential civil liability.

Authorization for Investigating Suspected Fraud
Members of the Human Development Investigation team will have:

  • Free and unrestricted access to all Company records and premises, whether owned or rented; and
  • The authority to examine, copy, and/or remove all or any portion of the contents of files, desks, cabinets, and other storage facilities on the premises without prior knowledge or consent of any individual who might use or have custody of any such items or facilities when it is within the scope of their investigation.

Reporting Procedures
Great care must be taken in the investigation of suspected improprieties or irregularities so as to avoid mistaken accusations or alerting suspected individuals that an investigation is under way.

An employee who discovers or suspects fraudulent activity will contact senior management immediately via http://youmatter.qualfon.com/report or calling the local fraud report line immediately. The employee or other complainant may remain anonymous. All inquiries concerning the activity under investigation from the suspected individual, his or her attorney or representative, or any other inquirer should be directed to the Human Development team and the Legal Department.

No information concerning the status of an investigation will be given out. The proper response to any inquiries is: “I am not at liberty to discuss this matter.? Under no circumstances should any reference be made to “the allegation,? “the crime,? “the fraud,? “the forgery,? “the misappropriation,? or any other specific reference.

The reporting individual should be informed of the following:

  • Do not contact the suspected individual in an effort to determine facts or demand restitution.
  • Do not discuss the case, facts, suspicions, or allegations with any-one unless specifically asked to do so by the Legal Department or Human Development team.
In cases of terminable offenses, the reported individual shall be preventatively suspended from duties pending the outcome of the formal investigation.

Termination
If an investigation results in a recommendation to terminate an individual, the recommendation will be reviewed for approval by the designated representatives from Human Development and the Legal Department and, if necessary, by outside counsel, before any such action is taken.

The Human Development does not have the authority to terminate an employee. The decision to terminate an employee is made by the employee’s Country VP Manager, Site director, Local HD and another member from the local MANCOM and communicated to employee´s management. Should the employee´s management team believe that the management local team decision inappropriate for the facts presented, the facts will be presented to executive level management for a decision.

Administration
The Chief People Officer is responsible for the administration, revision, interpretation, and application of this policy. The policy will be reviewed annually and revised as needed.

Approval

Alejandro Sotelo4/10/15
CEO/COO/ExecutiveDate