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This Policy is intended to provide direction and help to any employees, officers of the Company, temporary workers, consultants and contractors, who find themselves suspecting cases of theft, fraud or corruption. The Company has a commitment to maintaining high legal, ethical and moral standards. All members of staff are expected to share this commitment. This policy is established to facilitate the development of procedures, which will aid in the investigation of fraud and related offences.
The Anti-Fraud and Corruption Policy is supported by the directors and management team who are committed to implementing effective measures to prevent, monitor and eliminate fraud and corruption. Implementation of the policy is the duty of Line Managers. All employees are expected to comply.
This policy applies to all employees and officers of the Company, and to temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, the Company (“associated persons”) within the UK and overseas. Every employee and associated person acting for, or on behalf of, the Company is responsible for maintaining the highest standards of business conduct. Any breach of this policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of the Company.
The Company already has procedures in place that reduce the likelihood of fraud occurring. These include procedures and documented systems of internal control and risk assessment. In addition, the Company tries to ensure that a risk and fraud awareness culture exists in this organisation.
This Anti-Fraud and Corruption Policy applies to any irregularity, or suspected irregularity, involving employees as well as consultants, vendors, contractors, and/or any other parties with a business relationship with this organisation. Any investigative activity required will be conducted without regard to any person’s relationship to this organisation, position or length of service.
Actions and activities constituting fraud comprises both the use of deception to obtain an unjust or illegal financial advantage and intentional misrepresentations affecting the financial statements by one or more individuals among management, staff or third parties.
All employees have a duty to familiarise themselves with the types of improprieties that might be expected to occur
within their areas of responsibility and to be alert for any indications or irregularity.
In the event of discovery or suspicion of fraud or corruption a member of staff should immediately report any concerns they may have to the Managing Director without fear of prejudice or harassment. This applies to concerns relating to fraud and to any other concerns within the context of the Public Interest Disclosure Act 1998.
Concerns about the actions of internal employees and officers of the Company, temporary workers, consultants, contractors, agents and subsidiaries, which should be reported include, but are not limited to, committing or attempting to commit:
Concerns about external organisations’ actions which should be reported include, but are not limited to:
The Company’s employees, officers of the Company, temporary workers, consultants, contractors, must have, and be seen to have, the highest standards of honesty and integrity in the exercise of their duties and are responsible for acting with propriety in the use of company resources, in the handling of payment systems, receipts, dealing with contractors or suppliers; and reporting details of any suspected fraud, impropriety or other dishonest activity immediately to the Managing Director. The directors and management team are committed to maintaining an honest, open and well-intentioned atmosphere within the organisation to encourage anyone having reasonable suspicions of fraud to report them. It is also committed to the elimination of any fraud within the organisation, and to the rigorous investigation of any such cases.
The Company’s policy which will be rigorously enforced, is that no employee will suffer in any way as a result of reporting any reasonably held suspicion. For these purposes reasonably held “suspicions” shall mean any suspicions other than those which are raised maliciously and found to be groundless.
Whilst all employees are expected to comply with the policies in order to minimise the risk of claims against the company and individual employees, they are not contractually binding. The policies will be revised on a regular basis to ensure compliance with current legislation and best practice.