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 Solihealth Limited. It is the intent of Solihealth Limited to promote consistent organizational behaviour 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 Solihealth Limited (also called the ‘Company’). 

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. 

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 Chief Executive of Solihealth Limited, who coordinates all investigations with the relevant authorities 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 securities 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 Chief Executive 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 Chief Executive will issue reports to appropriate designated personnel and, if appropriate, to the Board of Directors. 

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 Chief Executive treats all information received confidentially. Any employee who suspects dishonest or fraudulent activity will notify the Chief Executive 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 reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the Company. 

Authorisation 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 Chief Executive immediately. The employee or other complainant may remain anonymous. All inquiries concerning the activity under investigation from the suspected individual, his or her legal 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 Chief Executive 

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.