nowydh bora • a new dawn

the trading name of P Hastings Limited

Anti-Fraud, Bribery and Corruption Policy

PURPOSE:

The primary purpose is to provide direction and assistance to {n}.bora staff who may suspect cases of fraud, bribery and corruption. It provides a framework for responding to such suspicions, and advice and information on any subsequent investigations and the implications of these for staff.

This policy applies to all {n}.bora staff, regardless of position held, as well as consultants, vendors, contractors, secondees and other parties who have a business relationship with {n}.bora. It will be brought to the attention of all staff and form part of the induction process for new staff.

This policy should be read in conjunction with the Whistleblowing Policy.


1    Policy Statement


2    Definition of Fraud


3    Definition of Bribery and Corruption



4    Roles and Responsibilities


Managing Director:


Company Secretary:


Audit:


Human Resources Function:


Managers:


All Staff:


5    Fraud Response Plan - Reporting


6    Fraud Response Plan - Investigation Procedure


7    Governance

This is a controlled document. Whilst this document may be printed, the electronic version posted on the internet is the controlled copy. Any printed copies of the document are not controlled. Policies, guidelines and procedures are designed to reflect legal requirements, best practice and {n}.bora’s objectives. Failure to comply with any policy may therefore lead to formal action under the disciplinary or performance management procedures. All policies, guidelines and procedures are monitored by {n}.bora’s Directors, who will ensure that all policies are consistent. Policies, guidelines and procedures are reviewed at intervals of 3 (three) years, or earlier if required by changes to legislation or the business needs of {n}.bora, in conjunction with the relevant stakeholders.


Author: Peter Hastings

Owner: Peter Hastings

Last Updated: 8th April 2020

Version: 2

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P Hastings Limited, Registered in England & Wales Company Number: 08730893

Trading as P Hastings Limited, PHL and n.bora

5 College Way, Truro, TR1 3RX, United Kingdom

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