Business Anti-Fraud Policy

BUSINESS ANTI-FRAUD POLICY

Recitals

WHEREAS, Company Name: seeks to establish and maintain controls, procedures and a culture to prevent, detect and respond to fraud, including but not limited to misappropriation, corrupt practices and financial statement manipulation;

WHEREAS, the parties identified below acknowledge that timely reporting, independent investigation, and proportionate disciplinary measures are essential to mitigate loss and reputational harm and to promote a compliant business environment;

WHEREAS, this Business Anti-Fraud Policy sets forth the responsibilities, reporting channels, investigative procedures and enforcement measures applicable to all personnel, contractors and third parties acting on behalf of the Company.

Scope of Work

This Policy applies to detection, investigation and remediation activities associated with alleged or suspected fraudulent conduct affecting the Company. It covers internal controls, monitoring, reporting mechanisms and coordination with legal and enforcement authorities as required.

Definitions

Fraud: any intentional act or omission designed to secure an unfair or unlawful financial or other benefit. Fraud includes falsification of records, bribery, embezzlement, collusion, and other acts that compromise the integrity of Company operations.

Reporting and Investigation

All employees, contractors and third parties must report known or suspected fraud promptly. Reports may be submitted to the designated Compliance Officer or through the Company’s internal reporting channels. The Company will investigate allegations impartially, document findings, preserve evidence, and take proportionate remedial action.

Payment Terms (for External Implementation Services)

If the Company engages an external service provider to implement or support the Anti-Fraud Program, the following payment terms shall apply unless otherwise agreed in a separate services agreement:

Term and Termination

This Policy shall commence on Start Date: and continue in effect until End Date: , unless earlier terminated according to this section.

Either party may terminate any related services engagement for material breach if the breaching party fails to cure within Notice Period (days):

Confidentiality

All reports, investigative materials, evidence and deliberations arising from alleged fraud are confidential and may be disclosed only to persons with a legitimate need to know, or as required by law. Personnel who knowingly disclose confidential investigative information in violation of this Policy will be subject to disciplinary action up to and including termination.

Responsibilities

Board/Management: approve the Policy, allocate resources and ensure independence of investigations where appropriate.

Compliance Officer: oversee reporting channels, coordinate investigations, maintain records and report material incidents to senior management.

Employees and Contractors: comply with control procedures, complete required training and promptly report suspected fraud.

Disciplinary Action

Violations of this Policy will result in disciplinary measures proportionate to the offense, including counseling, restitution, suspension, or termination. The Company reserves the right to pursue civil or criminal remedies to the fullest extent permitted by law.

Training and Compliance Monitoring

The Company will conduct periodic training and monitoring to ensure compliance. Attendance at mandated anti-fraud training is a condition of continued engagement.

Governing Law

This Policy and any services agreements executed pursuant to it shall be governed by and construed in accordance with the laws of the State of:

Entire Agreement

This Policy, together with any attached schedules and any executed services agreement, constitutes the entire agreement between the parties with respect to anti-fraud controls and supersedes all prior agreements, representations and negotiations, whether written or oral, relating to the subject matter herein.

Acknowledgment

By signing below, each signatory confirms that they have the authority to accept this Policy on behalf of the party represented, acknowledge receipt of, and agree to abide by, the terms of this Policy.

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