Global Anti Fraud Policy

The Group’s fraud risk management framework consists of:

• Prevention,

  Detection,

  Response

• Planning,

  Execution,

  Monitoring

• Reporting,

  Auditing,

  Training

• Awareness,

  Control,

  Compliance

Answer explanation

CLI’s Fraud risk management framework consists of three pillars:

1) Prevention:

Internal controls, segregation of duties, pre-employment screening, manage third parties, training and conflict-of-interest declarations.

2) Detection:

Transaction monitoring, red-flag indicators (non-exhaustive examples at Annex A), independent reviews/audit and whistleblowing.

3) Response:

Investigation protocols, disciplinary actions, recovery of losses and disclosure to authorities where required.

Which of the following is NOT listed as an example of fraud?

• Forgery of company documents

• Improper disclosure of confidential information

• Duplicate payments to vendors

• Routine staff training

Fraud can only be committed by employees, not third parties.

• True
• False

Answer explanation

Fraud is the use of deception with intention of obtaining an advantage, avoiding an obligation or causing loss to another party. Fraud can be perpetuated by employees, third parties or a collusion between employees and third parties.

You notice a colleague accessing confidential files unrelated to their role. What should you do?

• Ignore it since it may be harmless

• Confront them directly and demand an explanation

• Report the incident to your supervisor or via the Whistleblowing Channel

• Share the information with another colleague to confirm suspicion

Answer explanation

The Whistleblowing Channel2 is a trusted avenue for employees and external parties who believe that they may have discovered malpractice or impropriety in the workplace to report with confidence. Employees who make reports of malpractice or impropriety in the workplace in good faith will not be dismissed, penalised or discriminated against by the Group because of the making of such reports. In all circumstances, timely reporting is essential. Doing so will allow the Group an opportunity to deal with the issue promptly before the consequences escalate.

Supervisors or HODs who have come into knowledge of any fraud incident must report and escalate the incident to Senior Management or via the Whistleblowing Channel, as they deem appropriate.

The Audit Committee Chairman and Head of Group Internal Audit will ensure that investigation will be independently conducted.

To make a report via Whistleblowing Channel please send an email to: [e-mail].

A vendor insists on being paid in cash without issuing an invoice. According to the policy, this is:

• Acceptable if the amount is small

• A red flag situation requiring escalation

• Allowed if approved by a manager

• Standard practice in some jurisdictions

Employees are permitted to respond directly to regulators or police without consulting Legal & Compliance.

• True
• False

Answer explanation

All contact with authorities must be coordinated with Legal & Compliance.

CLI takes a zero-tolerance stance toward fraud

• True
• False

Which of the following is NOT considered an internal control for fraud prevention?

• Proper authorization of transactions

• Verification and approval of services

• Mandatory block leave for certain functions

• Ignoring irregularities unless they cause financial loss

Which of the following is a consequence for employees who conceal fraud violations?

• No action if they were not directly involved

• Possible termination and civil/criminal liability

• Only a verbal warning

• Mandatory retraining

Which of the following is part of the Response pillar in the fraud risk management framework?

• Segregation of duties

• Transaction monitoring

• Investigation protocols

• Pre-employment screening

Answer explanation

Segregation of duties and Pre-employment screening is part of prevention framework.

Transaction monitoring is part of detection.