We are committed to conducting business in accordance with the highest ethical, professional and legal standards. Our Anti-Fraud Policy articulates our fraud control principles, mandatory requirements and accountabilities; and it is applicable to all businesses within our group, including our subsidiaries.
We require strict compliance with local legislation in all jurisdictions in which we operate.
We have a ‘zero tolerance’ policy towards fraud, corruption, collusion, money laundering, financing of terrorism and other criminal activities (“Prohibited Conduct”) and will thoroughly investigate and take disciplinary and/or legal action against those who perpetrate, are involved in, or assist with fraudulent or other improper actions in all our activities and related transactions.
Fraud is any act or omission that knowingly or recklessly misleads or deceives a party to obtain a financial advantage or other benefit or to avoid an obligation. The type of events includes acts of omission, theft, the making of false statements or misrepresentation, evasion, manipulation of information and numerous other acts of deception.
Our Key Responsibilities
In accordance to our Anti-Fraud Policy, we are responsible for the following:
- ensuring we have a robust risk management framework with efficient and effective systems, procedures and internal controls in place to enable the prevention and detection of Prohibited Conduct;
- ensuring we identify Prohibited Conduct risks and that all systems, procedures and internal controls are properly implemented and enforced;
- ensuring all members of the operational anti-fraud department have a duty to report any internal and external suspicions or incidents of Prohibited Conduct;
- reviewing continuously our systems, procedures and internal controls through risk management processes and audit arrangements;
- investigating and reporting any suspicions regarding Prohibited Conduct to the relevant regulatory authorities; and
- ensuring we provide all employees with adequate training so that they are aware of their responsibilities and obligations with respect to the prevention, detection and reporting of fraud.