Microsoft Word - Anti-Fraud Policy

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NTI

-F

RAUD

OLICY

NTRODUCTION

The Company is committed to ethical behavior and values. It is amongst its first priorities to establish a

corporate and working culture that enhances the value of ethics and promote the individual responsibility

as well. To this effect, the company has established a Code of Business Conduct and Ethics, a Code

of Conduct and Ethics for Corporate Officers and Directors and an Ethics and Compliance Policy, which

set the highest standards for personnel conduct related to ethical behavior and alertness.

The cornerstone in preventing fraud is the creation of an environment that fosters morality, integrity and

business conduct.

1. F

RAUD

EFINITION

Fraud can be defined as: “Any illegal acts characterized by deceit, concealment, or violation of trust.

These acts are not dependent upon the application or threat of violence or of physical force. Fraud is

perpetrated by parties and organizations to obtain money, property, or services; to avoid payment or

loss of services; or to secure personal or business advantage.”

Fraud may involve:

• falsification or alteration of accounting records,

• misappropriation of assets or theft,

• suppression or omission of the effects of transactions from records or recording of transactions

without substance,

• intentional misapplication of accounting policies or willful misrepresentation of transactions or of the

entity’s state of affairs,

• misapplying corporate or bank funds

Fraud may also involve manipulation of information system applications and data for personal

advantage.

2. P

URPOSE

COPE

The purpose of this document is to outline the responsibilities of all the involved parties with respect to

fraud prevention, the actions to be taken if fraud is suspected and the mechanism of verifying suspicion

of fraud, the reporting process and the recovery action plan.

3. R

ESPONSIBILITIES

UDIT

OMMITTEE

The Committee’s duties and responsibilities are included in its Charter and included herein by

reference.

The Audit Committee should ensure that the Company has put in practice an effective ethics and

compliance program and is currently derived and defined by the relevant policy codes referred to

herein. It should be stressed that fraud has been, frequently, attributed to the weaknesses or override

of the internal controls. Therefore, the Audit Committee plays an important role by ensuring that the

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Company has identified the key risk areas and internal controls adequately address and mitigate

those risks.

FFICERS AND

ERSONNEL

The management personnel of the Company constitute the front line of monitoring and preventing

fraud. Managers are responsible to monitor business activities of employees and be aware of and

alert to potential signs of fraud.

Management is accountable to “set the tone at the top”, point out the risks to which the operations

and the systems are exposed, establish an effective system of Internal Controls, Governance and

Risk Management process, and follow up systematically on the implementation of the Company’s

procedures and policies.

TAFF

Staff is responsible to act at all times with the highest degree of honesty, integrity, accountability, and

propriety. Staff should conduct their duties in a manner the does not jeopardize, to the contrary,

safeguards the Company’s resources and assets. Staff shall comply with the Company’s Code of

Business Conduct and Ethics, and the Code of Conduct and Ethics for Corporate Officers and

Directors. If fraud, violation, unethical conduct or dishonest practice is suspected and/or verified,

then it should be reported through the “Ethics and Compliance” Link and provide any required

information during the investigation process.

NTERNAL

UDITOR

“The Internal Auditor should have sufficient knowledge to identify the indicators of fraud but is not

expected to have the capacity of a person whose primary responsibility is detecting and mitigating

fraud.”

The Internal Auditor is responsible to evaluate the adequacy of the internal control system, prioritize

auditing activities in accordance with a documented risk assessment plan, and provide

recommendations, through consulting and assurance activities.

4. F

RAUD

ESPONSE

LAN

The fraud response plan is a guide to follow in the event of fraud being discovered or suspected. Its

purpose is to ensure that proper action is taken in case of fraud.

Any allegations of fraud, theft or other irregularity should be reported via the Ethics and Compliance link

on the web site of the Company.

All allegations are reported anonymously, are treated as confidential and are directed to the Audit

Committee, which will undertake any further investigation.

The Audit Committee is responsible to retain any relevant records, examine the allegations, and plan

the investigation and deterrence of fraud. Deterrence of fraud lies with management. The Audit

Committee will appoint a suitable person, internal or external, to investigate and ensure that the

investigation is conducted in a professional manner. The Audit Committee and the management are

responsible to secure the anonymity and prevent the harassment or discrimination of the people that

make such allegations.

The results of the investigation should be reported directly to the Audit Committee, which will determine

to whom should be communicated, including the Internal Auditor, the CFO, and the CEO. Upon

conclusion of the investigation, an action plan should be agreed, enforced, documented, and distributed

appropriately.

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All records and reports of the investigation process should be under the custody of the Audit Committee,

retained in a safe place with restricted access in the Company headquarters.

The Internal Auditor should be periodically informed of the progress and the final conclusions of any

such investigation.

5. D

ISCIPLINARY

EGAL

CTION

Proven fraud or suspected fraud which comes to light, whether perpetrated by a member of staff or by

persons external to the organization, should be referred to the appropriate authorities, internally or

externally, at the earliest possible opportunity.

6. P

ERSONAL

ONDUCT

The personal conduct is governed by the Code of Business Conduct and Ethics, the Code of Conduct

and Ethics for Corporate Officers and Directors and the Ethics and Compliance Policy.

7. F

RAUD

ETECTION

THICS

OMPLIANCE

OLICY

Staff should be alert to the possibility that unusual events or transactions could be symptoms of fraud or

attempted fraud. An “Ethics and Compliance” policy is in place and enables the reporting of fraud or

other illegal actions. The “Ethics and Compliance” policy shall ensure that all employees have free

access to which unbiased judgment is addressed and anonymity and confidentiality are maintained.