EFFECTIVE DATE: APRIL 2024

1. Purpose

The purpose of this Anti-Fraud Policy is to outline the organization’s commitment to preventing, detecting, and addressing fraud. This policy provides a framework for identifying and mitigating fraud risks and ensures that all employees understand their responsibilities in maintaining a fraud-free environment.

2. Scope

This policy applies to all employees, contractors, consultants, and any other individuals or entities engaged in activities on behalf of the organization. It covers all types of fraud, including but not limited to financial fraud, procurement fraud, bribery, corruption, and misrepresentation.

3. Definitions

Fraud: Any deliberate act of deception intended to secure an unfair or unlawful gain. Fraud may involve financial transactions, misappropriation of assets, or manipulation of information.

Financial Fraud: Misrepresentation or falsification of financial records or transactions with the intent to deceive or gain a financial advantage.

Procurement Fraud: Fraudulent practices in the procurement process, including kickbacks, bid rigging, and conflicts of interest.

Bribery: Offering, giving, receiving, or soliciting something of value to influence the actions of others.

Corruption: Abuse of power or position for personal gain or to benefit others inappropriately.

4. Policy Statement

The organization is committed to maintaining the highest standards of integrity and transparency. All forms of fraud are unacceptable and will not be tolerated. The organization will take all necessary actions to prevent, detect, and address fraudulent activities.

5. Responsibilities

Management: Responsible for implementing and enforcing this policy, promoting a culture of integrity, and ensuring that adequate controls are in place to prevent fraud. Management must also support investigations and take appropriate disciplinary action when fraud is detected.

Employees: Required to adhere to this policy, report any suspected fraudulent activities, and cooperate with investigations. Employees must also follow established procedures and controls to minimize fraud risks.

Internal Audit: Responsible for conducting regular audits, assessing fraud risks, and evaluating the effectiveness of anti-fraud measures. Internal audit will also provide recommendations for improving fraud prevention and detection.

Compliance Officer: Oversees compliance with this policy, provides training and guidance on anti-fraud measures, and serves as a point of contact for reporting fraud concerns.

6. Prevention Measures

Internal Controls: Implement robust internal controls to safeguard assets, ensure accurate financial reporting, and prevent unauthorized access to sensitive information. Controls should include segregation of duties, authorization procedures, and regular reconciliations.

Training and Awareness: Provide regular training to employees on recognizing and preventing fraud, understanding their responsibilities, and reporting suspicious activities. Promote awareness of the policy and the importance of ethical behavior.

Code of Conduct: Ensure that all employees are aware of and adhere to the organization’s Code of Conduct, which includes principles related to honesty, integrity, and ethical behavior.

Whistleblowing Mechanism: Establish a confidential whistleblowing mechanism that allows employees and other stakeholders to report suspected fraud or unethical behavior without fear of retaliation. Ensure that reports are investigated promptly and thoroughly.

7. Detection and Investigation

Monitoring and Surveillance: Implement monitoring and surveillance systems to detect unusual or suspicious activities. Regularly review transactions, financial records, and operational processes to identify potential fraud indicators.

Reporting Suspected Fraud: Encourage employees to report any suspected fraudulent activities through established channels. Provide clear instructions on how to report concerns and assure confidentiality and protection for whistleblowers.

Investigation Procedures: When fraud is suspected, conduct a thorough and impartial investigation. Gather evidence, interview relevant parties, and document findings. Involve external experts if necessary and ensure that the investigation is conducted in accordance with legal and regulatory requirements.

8. Response and Disciplinary Action

Corrective Actions: Take appropriate corrective actions to address identified fraud, including recovering stolen assets, improving internal controls, and implementing measures to prevent future occurrences.

Disciplinary Measures: Disciplinary action will be taken against employees involved in fraudulent activities. Actions may include suspension, termination of employment, legal action, and reporting to relevant authorities.

Legal Action: Pursue legal action against individuals or entities involved in fraud, including criminal prosecution and civil lawsuits. Cooperate with law enforcement agencies and regulatory bodies as needed.

9. Review and Update

This policy will be reviewed regularly and updated as necessary to ensure its continued effectiveness and alignment with best practices and legal requirements. Any changes to the policy will be communicated to all employees and relevant stakeholders.

10. Documentation and Record-Keeping

Maintain accurate and comprehensive records of all fraud-related activities, including investigations, corrective actions, and disciplinary measures. Ensure that records are securely stored and accessible for review and audit purposes.

11. Policy Enforcement

The organization is committed to enforcing this policy and ensuring that all employees understand and adhere to its provisions. Non-compliance with the policy will result in disciplinary action and may include termination of employment.

12. Contact Information

For questions about this policy or to report suspected fraud, please contact:

Compliance Officer: Anjali Singh

Phone: +91-9870199117

Email: compliance@innovatiview.com

LAST UPDATED: APRIL 2024