Fraud

Principles

We are committed to the prevention and detection of fraud and will investigate any allegation of fraudulent activity. Fraud is a criminal offence, which we will not tolerate.

assess the nature and extent of our exposure to potential external and internal risks of fraud.
carry out a scheduled fraud risk assessment that is rigorous and documented.
apply due diligence procedures, taking a proportionate and risk-based approach, to mitigate identified fraud risks.
ensure that our fraud prevention policies and procedures are embedded and understood throughout the organisation, through internal and external communication and training.
regularly monitor and review our fraud prevention policies and procedures and make improvements where necessary.
require all individuals, regardless of position, title, or tenure, to remain vigilant and report any suspicions of fraud to their manager, a subject matter expert (e.g., Ethics & Compliance), the legal team, a Local Ethics Advisor (LEA) or the Speak Up line.
will investigate all allegations of fraud, and will take appropriate disciplinary and legal action, up to and including dismissal, recovery of losses and forwarding information to the appropriate authorities for prosecution.

Group Policies

Additional Guidance

Contacts