Fraud Prevention Policy

Purpose and Scope

This Fraud Prevention Policy outlines our commitment to preventing, detecting, reporting, and responding to fraudulent activities across all areas of our business.

This policy applies to all employees, directors, board members, contractors, consultants, vendors, suppliers, and business partners operating on behalf of our company within the United Arab Emirates (UAE) and across all our business operations.

Everyone representing our organization is expected to act honestly, ethically, and responsibly while protecting the assets, information, and resources entrusted to them.

Our Commitment

We maintain a zero-tolerance approach to fraud in any form. Fraud undermines trust, damages our reputation, disrupts our operations, and may expose both individuals and the company to serious legal consequences.

All allegations or suspicions of fraud will be investigated thoroughly, fairly, and confidentially, regardless of the position, seniority, or relationship of the individual involved.

Definition of Fraud

Fraud is any intentional act or omission designed to deceive another person or organization for personal, financial, or commercial gain, or to unlawfully obtain, misuse, or conceal company assets or information.

Examples of Fraud

• Asset Misappropriation: Theft or unauthorized use of company funds, equipment, inventory, intellectual property, customer information, or any other company asset.
• Financial Misrepresentation: Deliberately falsifying accounting records, invoices, financial statements, payroll records, or other business documents.
• Expense and Claims Fraud: Submitting false, inflated, duplicate, or misleading expense claims, timesheets, reimbursement requests, or insurance claims.
• Cyber and Digital Fraud: Unauthorized access to company systems, data manipulation, payment redirection, phishing, identity theft, or any other cyber-related fraudulent activity prohibited under UAE Cybercrime laws.
• Conflict of Interest Fraud: Using one’s position within the company to obtain unauthorized financial or personal benefits for oneself, family members, friends, or associated businesses.

Roles and Responsibilities

Fraud prevention is the responsibility of every individual working with our organization.

Management Responsibilities

• Establish effective internal controls and approval processes.
• Monitor business activities to identify potential fraud risks.
• Promote a culture of integrity, transparency, and accountability.

Employee Responsibilities

• Protect company assets and confidential information.
• Follow company policies and internal procedures.
• Immediately report any suspected or actual fraudulent activity.

Reporting Fraud

Anyone who suspects or becomes aware of fraudulent activity must report the matter immediately through one of the following official reporting channels:

1. Your immediate Line Manager.
2. The Finance or Human Resources Department.
3. The designated Compliance Officer or Ethics Committee.

All reports will be handled confidentially to the fullest extent permitted by law. Investigations will be conducted independently by authorized personnel, and individuals who are the subject of an investigation will not participate in the investigation process.

Whistleblower Protection

We encourage employees and business partners to report genuine concerns without fear of retaliation.

No employee or individual who reports suspected fraud in good faith will be subjected to dismissal, discrimination, harassment, intimidation, or any other adverse action, even if the investigation ultimately finds no wrongdoing.

Investigation Process

All reported incidents will be reviewed promptly and investigated in an impartial, confidential, and professional manner. Where appropriate, external legal, forensic, or regulatory authorities may be involved.

Consequences of Fraud

Any confirmed act of fraud will result in appropriate disciplinary and legal action.

• Disciplinary Action: Employees found responsible for fraudulent conduct may face disciplinary action up to and including immediate termination of employment, subject to applicable UAE Labour Law.
• Legal Action: Fraud is a criminal offence under UAE law. The company may report confirmed cases to the appropriate law enforcement authorities and pursue civil action to recover financial losses or stolen assets.
• Termination of Business Relationships: Contractors, suppliers, consultants, vendors, or business partners involved in fraudulent activities may have their contracts terminated immediately and may be permanently disqualified from future business with the company.

Policy Review

This policy will be reviewed periodically to ensure compliance with applicable UAE laws, regulatory requirements, and international best practices. All employees and business partners are expected to understand, comply with, and support the principles outlined in this policy.