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https://25iq.com/2015/10/24/a-dozen-things-ive-learned-from-charlie-munger-about-ethics/ “Once you start doing something bad, then it’s easy to take the next step – and in the end, you’re a moral sewer.” After chewing on it for a bit, the right thing to do is to disclose no matter what amount. In law, they(judges?) purposely go out of their way to avoid even the appearance of bias (at least they're suppose to). The difference between $1 and $1m can be explained away like a slow boiling frog, so if it might appear wrong, why do it? If it's really an exception, disclose it at the minimum to the board, and let the board decide if it's really worthy of an exception. Just merely putting up some roadblock (disclosure) to avoid such behaviour is a win in my book. A small price to pay.

D, ideally lower. The fraud and cheating will usually start small but if they get away with it, they are likely to scale up, so it must be dissuaded from the start. I have a friend who ran a private midsize tech company. His cofounder, who oversaw the financial side of the business, hired his secret mistress as an office manager and when they got larger, the controller. Over several years she embezzled many hundreds of thousands, possibly more than a million, including using corporate cards for family vacations and such. The cofounder couldn't do anything because the mistress was blackmailing him, and my friend had no idea until they had an outside audit done. In the end she basically got a slap on the wrist.

I haven't looked into it because I haven't had the need, but IMHO, I would look at the policies at Berkshire corporate office, and Munger, Tolles & Olson LLP as a starting point. They've put in the work to have the 'correct' policies in place, so unless you can find flaws in their policies, you should just adopt them.

I think the optimal play there (if it had been publicly owned) would have been SEC whistleblower. Pays out a portion of fines.

I am assuming the CEO owned the company? If not, contacting majority shareholders would do the trick here. If it is, well he's just stealing from himself so...