Anti Fraud Policy

1. Purpose:

The purpose of this Anti-Fraud Policy is to establish guidelines and procedures to prevent, detect, and respond to fraudulent activities within the company. This policy aims to protect the company’s assets, reputation, and interests, as well as ensure ethical conduct and compliance with applicable laws and regulations.

2. Scope:

This policy applies to all employees, contractors, vendors, partners, and individuals acting on behalf of the company.

3. Definition of Fraud:

Fraud refers to any intentional act of deception, misrepresentation, or manipulation aimed at obtaining financial or personal gain, causing financial loss to the company, or misleading stakeholders.

4. Prohibited Activities:

The following activities are strictly prohibited and constitute fraud under this policy:

  1. Falsification, alteration, or manipulation of financial records, documents, or reports.
  2. Theft or misappropriation of company funds, assets, or intellectual property.
  3. Unauthorized use or disclosure of confidential or sensitive information.
  4. Acceptance or solicitation of bribes, kickbacks, or illegal payments.
  5. Unauthorized alteration, destruction, or removal of company records or data.
  6. Embezzlement or misappropriation of company funds or assets.
  7. False reporting of hours worked, expenses incurred, or business transactions.
  8. Insider trading or unauthorized disclosure of non-public information.
  9. Engaging in conflicts of interest without proper disclosure and approval.
  10. Forgery or falsification of documents, including contracts or agreements.
  11. Knowingly making false statements or providing false information.
  12. Any other fraudulent activity that violates applicable laws or company policies.

5. Prevention Measures:

The company will implement the following measures to prevent and deter fraud:

  1. Clearly communicate and promote ethical standards and the importance of fraud prevention.
  2. Establish and enforce strong internal controls and segregation of duties.
  3. Conduct regular risk assessments and internal audits to identify potential fraud risks.
  4. Implement fraud detection tools, systems, and monitoring mechanisms.
  5. Provide regular training and awareness programs on fraud prevention and reporting.
  6. Encourage an open and transparent reporting culture, with mechanisms for anonymous reporting.
  7. Conduct thorough background checks on employees, contractors, and vendors.
  8. Implement robust information security measures to protect against unauthorized access and data breaches.
  9. Review and update policies and procedures regularly to address emerging fraud risks.

6. Reporting and Investigation:

Employees and stakeholders have a responsibility to promptly report any suspected or observed fraudulent activities. The company will ensure that all reports are treated confidentially, and no retaliation will be taken against those reporting in good faith. An investigation will be conducted promptly and impartially, and appropriate actions will be taken based on the investigation’s findings.

7. Consequences of Fraud:

Any employee or individual found engaging in fraudulent activities will be subject to disciplinary action, up to and including termination of employment or legal prosecution, as deemed appropriate. The company may also pursue recovery of damages or losses incurred as a result of the fraud.

8. Compliance with Laws and Regulations:

This Anti-Fraud Policy is intended to supplement and work in conjunction with other company policies, as well as applicable laws and regulations related to fraud prevention and detection.

9. Policy Review:

This policy will be reviewed periodically to ensure its effectiveness and alignment with evolving business needs and regulatory requirements.

By adhering to this Anti-Fraud Policy, we demonstrate our commitment to maintaining a culture of integrity, honesty, and transparency in all our business activities.

(Last revised: 30/03/2022)