Management is on the front line and in the best position to both

            Create a culture of honesty and integrity

            Assess and mitigate the risk of fraud

Most frauds occur at lower levels, preventing & detecting must occur there to be most effective

Management participation in fraud is not uncommon (larger frauds)

            set a good example - very important

            be aware of not only subordinates, but other managers

Management has a responsibility to not only prevent fraud against the organization, but to stand up when there is fraud by the organization