Fraud Tracking Procedures
The Legal department has developed a formal process for reporting and tracking alleged violations. Each year it reports on the number of complaints and their nature. This report goes to the audit committee for review. There have been very few fraud-related incidents reported or detected during the past five years.
Risk Analysis
In 2005, PotashCorp hired a consultant to perform a Fraud Vulnerability Assessment. This was a high-level review to identify potential fraud vulnerabilities and make recommendations to mitigate the risk and impact of any identified threats or vulnerabilities. The assessment determined that the risk of a fraud-related event occurring at PotashCorp is low.
Incidents of Legal Violations
No PotashCorp employees were dismissed or disciplined for corruption in 2007.
There were no instances in 2007 where contracts with business partners were not renewed due to violations related to corruption.
There were no concluded legal cases regarding corrupt practices brought against the company or its employees in 2007.
No significant fines or non-monetary sanctions were levied against PotashCorp in 2007 related to accounting fraud or corruption.
Anti-Competitive Behavior
In 2007, there were no legal cases pending or completed regarding anti-competitive behavior or violations of antitrust and monopoly legislation in which PotashCorp was identified as a participant.