Anti-Fraud Policy

The Anti-Fraud Policy provides guidelines to employees to understand their responsibilities in prevention, detection and reporting of fraud or financial irregularities. This is important to uphold the ethics and integrity company wide while ensuring the best for all stakeholders.

This letter template is available for download in Word format.

With this Anti-Fraud Policy template you can:

• Communicate the impact of financial irregularities, data loss and fraud can have on the company
• Set clear expectations on the role of employees in preventing fraud and disclosures
• Promote consistent organizational behavior by following anti-fraud guidelines and code of conduct

In just a few minutes, you will be able to create an anti-fraud policy. This template covers vital information like:

• Responsibility for developing controls for prevention of fraud or to conduct fraud investigations.
• Report of suspected irregularity involving employees or associates who have a business relationship with the company
• Consequences of initiating or participating in fraudulent activities or ignoring knowledge or existing of fraud occurrences.

Anti-Fraud Policy

Objective

The objective of Anti-fraud Policy is to implement monetary and risk controls that will aid in the detection and prevention of fraud against < Company Name Here >. It is the intent of < Company Name Here > to promote consistent organizational behavior and to uphold highest standards of moral and ethics while conducting business.

Scope and Applicability

This policy applies to all employees as well as shareholders, consultants, vendors, contractors, outside agencies doing business with employees of such agencies, and/or any other parties with a business relationship with < Company Name Here > (also called the ‘Company’).

The Anti-fraud Policy is applicable to any and all act(s) or omission(s) that constitutes fraudulent or suspected fraudulent activity that includes, but not limited to, monetary items such as cash, funds, stock, proprietary information, intellectual properties, material of value, content, data, assets, properties, consumables, office articles and supplies including stationery, deals, contracts, bribes, gifts, favours, influencing, undue prioritisation, etc., for personal gains either individually or collectively by its employees or associates of the Company.

This policy is owned by < Name of the Person > and reachable @ < Contact Number > and < email address >

Policy / Process

Policy

Management is responsible for the detection and prevention of fraud, misappropriations, and other irregularities. Fraud is defined as the intentional, false representation or concealment of a material fact for the purpose of self gain, profiteering or inducing another to perform fraudulent acts alone or in partnership. It is a breach of trust and gross violation of the Code of Conduct.

Any irregularity that is detected or suspected must be reported immediately to the < Designated person > of < Company Name Here >, who coordinates all investigations with the Legal Department for taking appropriate action.

Actions Constituting Fraud

The terms misappropriation and other fiscal irregularities refer to, but are not limited to:

• Any dishonest or fraudulent act, including forgery, falsification of documents and instruments, misrepresentation, impersonation and other activities.
• Misappropriation of funds, securities, supplies or other assets
• Impropriety in handling or reporting of money or financial transactions
• Profiteering as a result of insider knowledge of company activities
• Disclosing confidential and proprietary information to outside parties
• Disclosing to other persons the security activities engaged in or contemplated by the company
• Accepting or seeking anything of material value from contractors, vendors or persons providing services / materials to the Company.
• Destruction, removal or inappropriate use of records, furniture, fixtures and equipment and/or
• Any similar or related irregularity

Investigation Responsibilities

The < Department or team name > has the primary responsibility for the investigation of all suspected fraudulent acts as defined in the policy. If the investigation substantiates that fraudulent activities have occurred, the < Department or team name > will issue reports to appropriate designated personnel and, if appropriate, to the Board of Directors through the Audit Committee.

Decisions to prosecute or refer the investigation results to the appropriate law enforcement and/or regulatory agencies for independent investigation will be made in conjunction with legal counsel and senior management, as will final decisions on disposition of the case.

Confidentiality

The < Department or team name > treats all information received confidentially. Any employee who suspects dishonest or fraudulent activity will notify the < Department or team name > immediately and should not attempt to personally conduct investigations or interview / interrogation related to any suspected fraudulent act. Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. This is important in order to avoid damaging the reputation of persons suspected but subsequently found innocent of wrongful conduct and to protect the Company.

Authorization for Investigating Suspected Fraud

Members of the Investigation team will have:

• Free and unrestricted access to all Company records and premises, whether owned or rented; and
• The authority to examine, copy, and/or remove all or any portion of the contents of files, desks, cabinets, and other storage facilities on the premises without prior knowledge or consent of any individual who might use or have custody of any such items or facilities when it is within the scope of their investigation.
• Employees under investigation may be asked not to enter Company premises or to access any Company web pages, drives or links either personally or through colleagues or other means, until the investigations are complete.
• Company reserves the right to question the employee’s colleagues, friends, relatives, associates, outside service providers, etc., whom the Company or its investigating team suspects of their involvement.

Reporting Procedures

Great care must be taken in the investigation of suspected improprieties or irregularities so as to avoid mistaken accusations or alerting suspected individuals that an investigation is underway. An employee who discovers or suspects fraudulent activity will contact the < Department or team name > immediately. The employee or other complainant may remain anonymous. All inquiries concerning the activity under investigation from the suspected individual, his or her attorney or representative or any other inquirer should be directed to the Investigations team or the Legal Department. No information concerning the status of an investigation will be given out.

The individual who reports a fraud should be made aware of the following:

• Do not contact the suspected individual in an effort to determine facts or demand restitution.
• Do not discuss the case, facts, suspicions, or allegations with anyone unless specifically asked to do so by the Legal Department or < Department or team name >

Termination

If an investigation results in a recommendation to terminate an individual, the recommendation from the Investigating team will be reviewed for approval by Human Resources and the Legal Department and, if necessary, by outside counsel, before any such action is taken. The decision to terminate an employee is made by the Management.

Special Circumstance and Exception'

Any Deviation to this policy has to be approved by Management. Any changes to the policy have to be approved by Legal and Compliance.

Non-compliance and Consequence

Violation of this policy is subject to disciplinary action, up to and including termination.