Fraud Policy

1. Purpose and Scope

This policy defines what we consider fraudulent activity and outlines how we prevent, detect, and respond to it.

This policy applies to all employees, board members, contractors, vendors, and partners working with us in the UAE and across all our operations. We expect everyone representing our company to act with absolute honesty and safeguard the resources entrusted to us.

2. Our Commitment

We have a zero-tolerance approach to fraud. Any act of fraud damages our culture, our reputation, and our financial stability. We investigate all suspected fraudulent activities thoroughly and objectively, regardless of the position, seniority, or relationship of the individual involved.

3. What Constitutes Fraud?

Fraud is any intentional act or omission designed to deceive others, secure an unfair or unlawful gain, or misappropriate company assets. Examples of fraudulent behaviour include:

• Asset Misappropriation: Stealing cash, physical property, inventory, or intellectual property belonging to the company, our clients, or partners.
• Financial Misrepresentation: Intentionally falsifying company books, financial statements, or accounting records.
• Expense and Claims Fraud: Submitting false, inflated, or duplicate expense reports, timesheets, or medical insurance claims.
• Cyber and Digital Fraud: Unauthorised access to systems to alter data, redirect payments, or commit identity theft, which is strictly penalized under UAE Cybercrime laws.
• Conflict of Interest Fraud: Using your position within the company to secure unauthorized financial benefits for yourself, family members, or friends.

4. Prevention and Responsibility

Preventing fraud is a team effort. Every employee plays a role in protecting our workplace.

• Management Duties: Managers must establish and maintain clear checks and balances within their teams to minimize the risk of fraud.
• Employee Duties: You are expected to safeguard company assets under your control and report any unusual or suspicious financial activities immediately.

5. Reporting and Investigation

If you suspect or become aware of any fraudulent activity, you must report it immediately through our official channels:

• Your immediate line manager or the Finance / Human Resources Department.
• Our designated Compliance Officer.

We handle all reports with the highest level of confidentiality permitted by law. Investigations are conducted objectively by authorized personnel, and no one under suspicion will be involved in investigating the matter.

Protection for Whistleblowers: We strictly prohibit any form of retaliation, discrimination, or negative consequence against an employee who reports suspected fraud in good faith.