1. Purpose of Fraud Policy

 

The ALINAFE ONLINE’s Fraud Policy sets out the responsibility of employees, management, users and third parties in relation to reporting of fraud or suspected fraud within the ALINAFE ONLINE.

Though there is some overlap between this policy and the Confidential Disclosures Policy, it is important to note that the reportage of fraud is mandatory.

However, a fraud and/or a suspected fraud can also be reported under the Confidential Disclosures (‘Whistleblowing’) Policy.

2. Scope of Fraud Policy

 

The Fraud Policy applies to any irregularity, or suspected irregularity, involving user, third parties, any unknown person, employees and where appropriate outside agencies doing business with the ALINAFE ONLINE or employees of such agencies, and/or any other parties having a business relationship with the ALINAFE ONLINE or some other persons unknown to ALINAFE ONLINE.

For the purposes of the policy, the term ‘employee’ includes individuals who work within the ALINAFE ONLINE such as external consultants, contractors, agency personnel, and Central ALINAFE ONLINE management.

3. Definition of Fraud 

 

1. Fraud can be broadly defined as an intentional act of deceit to obtain an unjust/illegal advantage. For the purposes of the policy, fraud shall include but is not limited to:
   1. 1. Theft or misappropriation of assets owned or managed by the ALINAFE ONLINE;
      2. Submitting false claims for payments or reimbursement;
      3. Accepting or offering a bribe or accepting gifts or other favours under circumstances that might lead to the inference that the gift or favour was intended to influence an employee's decision-making while serving the ALINAFE ONLINE;                            

Any employee or user or third party, external contractor working with ALINAFE ONLINE assumes a commitment to acting towards prevention, detection and reporting of fraud or suspected fraud by taking measures necessary to report any circumstances that are fraudulent that have come to their attention.

 

  2. ALINAFE ONLINE will prosecute any persons who are deemed liable for:

1. Blackmail or extortion;
2. 'Off the books' accounting, or making false or fictitious entries;
3. Knowingly creating and/or distributing false or misleading financial reports;
4. Paying of excessive prices or fees where justification thereof is not documented;
5. Violation of the ALINAFE ONLINE’s procedures with the aim of personal gain or to the detriment of the ALINAFE ONLINE;
6. Wilful negligence intended to cause damage to the material interest of the ALINAFE ONLINE; and
7. A dishonourable or reckless or deliberate act against the interests of the ALINAFE ONLINE.

4. Responsibility for the Prevention and Detection of Fraud

• All users and employees have a duty to guard against fraud. Employees are expected to identify processes and procedures that may be vulnerable to fraud and to draw such instances to the attention of management in their division. 
• Management have a particular responsibility to be familiar with and alert to the types of fraud that might occur in their area and to put in place effective controls to avoid such occurrences.
• Management shall provide support to and work with the Internal Audit Division, other Divisions involved, and law enforcement agencies in the detection, reporting and investigation of dishonest or fraudulent activity, including the prosecution of offenders. Once fraud is detected, Heads of Divisions are responsible for taking appropriate corrective action to ensure adequate controls are put in place to prevent reoccurrence of improper activity.

 

5. Procedure for Reporting a Suspected Fraud

Reporting fraud according to the following procedure is mandatory for any user and employee who suspects that a fraud has occurred. Persons who cover up, obstruct, or fail to report (or monitor) a fraud that they become aware of, or ought to have been aware of, may be considered to be an accessory after the fact and may be subject to the ALINAFE ONLINE’s disciplinary code which could involve action up to and including dismissal. Persons who threaten retaliation against a person reporting a suspected fraud shall be subject to the disciplinary code which could include action up to and including dismissal or prosecution or both.

Details of the incident, facts, suspicions or allegations should not be discussed with anyone inside or outside the ALINAFE ONLINE unless the ALINAFE ONLINE’s investigating team specifically directs this. In particular, the matter should not be discussed with the individual suspected of fraud.

Fraud can be detected at any level within the ALINAFE ONLINE, and the following will apply in the reporting of suspected internal fraud:

1. Any person who suspects that fraudulent activity is taking place should, in the first instance, report the matter to ALINAFE ONLINE using [email protected]  and to law enforcing agencies.

 

6. References for Employees Disciplined or Prosecuted for Fraud

Where there is a request for a reference for an employee who has been disciplined or prosecuted for fraud or dishonesty, the Human Resources Division shall prepare any reply to such a request having regard to the ALINAFE ONLINE’s policies and Employment Law.

 7. Review of Fraud Policy

The Fraud Policy will be reviewed at least every three years by the Audit Committee.