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Foreword

[Company Name] initiates this Anti-Fraud Policy to show our compliance with the maximum standards of honesty, clarity, transparency, and accountability in all things we do and are responsible for. We hereby stand to prevent, report and remediate any kind of fraud or corruption that may take place within this company. We promise to withhold a culture of ethics and virtue while guaranteeing individual and collective responsibility.

This Anti-Fraud Policy applies to all employees working as a part of this company regardless of the positions or titles they hold.

Aim

• To prevent fraud or any kind of corruption
• To educate employees about different kinds of fraud and its consequences
• To train and allow employees to act upon suspicions
• To provide ramifications if possible in case of any suspicions

Definitions

Fraud is defined as “wrongful or criminal deception intended to result in financial or personal gain”. What is considered fraud by [Company Name] may involve:

• Alteration or manipulation of any kind of records or documentation
• Mismanagement or mishandling of assets
• Theft of company property including data and information
• Bribery and corruption
• Using company interests for personal gain
• Manipulation of company information for personal gain
• Conducting inappropriate payments on behalf of the company
• Disclosure of confidential information
• Manipulation or recording transactions without substance

There is no threshold to determine whether any of the above actions is considered fraud or not. For an action to be determined as fraud or correct, it need not be in its successful state, initiation alone would be enough. These definitions apply equally to all members of the company. These definitions also apply equally in all countries that the company operates in or does business in.

Regulations

Any allegations against an employee for fraud must be reported directly to the HR or the Manager in charge.

All reports will be made anonymously and the identity of the person reporting it will be confidential.

After reporting, all further investigations will be taken care of by the Audit Committee.

The Audit Committee will be responsible for retaining all relevant information, examining the allegations, and planning the further investigation.

The Audit Committee will make sure that the persons making the allegations face no consequences.

The results of the investigation should be directly reported to the Audit Committee.

The action plan as a result of the investigation should be agreed upon by the Audit Committee, the CFO, and the CEO.

The action plan must be discussed, documented, and distributed in an appropriate manner.

Certification

I hereby certify that I have received a copy of the Anti-Fraud policy of [Company name].