Fraud Prevention Policy
Trust is one of the most important elements for a good relationship between H. W. Kaufman Group Europe B.V (HWKEU) and its customers. HWKEU is committed to the prevention of fraud and any other forms of dishonestly and will promote an anti-fraud culture. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
We have implemented effective systems and controls to counter fraud. However, Employee vigilance is encouraged with regards to spotting and reporting of any suspicious activity. Appropriate points of contact within the company have been established for this purpose and their identity and role explained to employees. Any reports are treated with confidentiality.
HWKEU is committed to ensuring that all of its employees receive appropriate training in recognition and thereby fraud prevention, by both themselves and others they may have dealings with.
HWKEU takes all reports of alleged Fraud or Fraudulent behaviour extremely seriously and will use all available means to rigorously investigate. Full and active co-operation will be given to the police and any other relevant authorities during this process.
2. Policy Statement
This Policy applies to the conduct of the HWKEU Board and committees, all staff, whether fixed term, contractors, trainees, seconded staff or any other person associated with HWKEU. It also applies to consultants, associates, agents of HWKEU and any third party acting on its behalf.
HKWEU requires all Staff to act honestly and with integrity at all times; and to report all suspicions of fraud, corruption and bribery.
Other policies to be read in connection with this policy as follows:
- Anti-corruption policy
- Conflicts of Interest Policy
- Financial Crime: Anti-money laundering policy
- Complaints procedure
- Code of Ethics and Conduct
Fraud is the intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain. We will most commonly see the following types of fraud; Bribery, Corruption, Theft, Asset and Cash Misappropriation, Financial Statement Fraud and Facilitation of payments.
Bribery: A bribe is an inducement or reward offered, promised or provided in order to gain commercial, contractual regulatory or personal advantage.
Facilitation of payments: Small bribes paid to speed up a service are sometimes called facilitation payments.
Corruption: Is a form of dishonesty or criminal offence undertaken by a person or organisation entrusted with a position of authority, to acquire illicit benefit or abuse power for one’s private gain.
Asset and Cash Misappropriation: Are schemes in which the fraudster steals or misuses resources for their own interest.
Financial Statement Fraud: Involves intentional misstatement or omission of material information of financial reports, invoices or statements.
Theft: Dishonestly acquiring, using or disposing of physical or intellectual property belonging to the Company or its beneficiaries.
The above types of Fraud are deemed criminal offences under the Dutch Criminal Code (Wetboek van Strafrecht) Part XXV Deception and are punishable by imprisonment and/or a fine.
3. The Policy
In accordance with the provisions of the Dutch Criminal Code HWKEU has a zero-tolerance approach to fraud, bribery and corruption. Any kind of fraud or violation of integrity is unacceptable. Any individual(s) found to be complicit with any instance of Fraud will have firm action taken against them.
In relation to the prevention of fraud, theft and abuse of position the Company has the following responsibilities:
- The Ultimate responsibility for this Policy rests with the Compliance officer/Board of HWKEU Enquires should be directed to the Compliance officer/Board.
- Making sure that all employed staff are aware of the Company Anti-Fraud, Bribery and Corruption policies and know what their responsibilities are in relation to combating fraud.
- Authorised Compliance officer/Board are responsible for reviewing this policy as required.
Responsibilities of the Company employees:
- The prevention, detection and reporting of all forms of corruption including Fraud and Bribery are the responsibility of all those working for the Company or under its control.
- All are required to avoid any activity that might lead to, or suggest, a breach of this Policy.
5. Reporting Suspicions
If any employee has any suspicion that the Company, its employees or anyone the Company is connected to, is involved or may be involved in, the possibility of fraud, the Authorised Compliance Officer must immediately be notified. All concerns must be reported immediately.
In respect of all financial or accounting irregularities or circumstances that may suggest irregularities, must be reported immediately to the Compliance Officer.
Once the Compliance Officer has been informed, no further action may be taken until further instruction is received from the Compliance Officer. A proper investigation will be conducted and the appropriate authorities engaged included the Police and Courts.
All employees receive training. As part of our in house training and Continuous Professional Development we test employees on various topics including Fraud, Corruption and Bribery.
7. Monitoring and review
Compliance with this policy will be continually monitored. We will review this policy annually as part of our overall risk management process.
We will also review this policy if:
- There are changes in the law and/ or practice
- We identify or are alerted to a weakness in the policy
- There are changes in the nature of the business, our clients or other changes which can impact on this policy.
Consequences of Non – Compliance
Failure to comply puts you, the employee and HWKEU at risk. You may commit a criminal offence if you fail to comply with this policy. The law relating to Fraud carries severe penalties. We take compliance with this policy very seriously and any failure to comply with any requirement may lead to disciplinary action under our HR procedures. If you have any questions or concerns about anything in this policy, do not hesitate to contact the Compliance Officer, Ben Williams.
Policy may be subject to change at any time the Company deems necessary as new procedures or legislation comes into force.