The term “fraud”, used in this Policy, refers generally to any intentional act committed to secure an unfair or unlawful gain including, but not limited to, fraud, corruption, theft and other similar irregularities that reflect actual or potential:
- Misrepresentation in ECC’s publicly released financial statements or other public disclosures;
- Misappropriation or theft of ECC’s asset such as cash, inventories, corporate certificate, plant blueprints, material documents, equipment, tools or supplies;
- Unlawfully obtained revenue, expenses and assets or unlawful avoidance of costs and expenses;
- Claiming reimbursement for fictitious expenses;
- Commercial bribery or bribery of a government official or other violation of anti-corruption laws; or
- Improper payment schemes such as employees or Directors of ECC seeking or accepting from, paying or offering to, suppliers or business partners, kickbacks or gifts intended to or which may appear to influence business judgment.