Fraud Prevention Policy

POLICY OBJECTIVES :
The ‘Fraud Prevention Policy of RCF-2010’ has been framed to provide a system for detection and prevention of fraud, reporting of any fraud that is detected or suspected and fair dealing of matters pertaining to fraud. 

The policy will ensure and provide for the following :-

To ensure that management is aware of its responsibilities for detection and prevention of fraud and for establishing procedures for preventing fraud and/or detecting fraud when it occurs.

To provide a clear guidance to employees and others dealing with RCF, forbidding them from involvement in any fraudulent activity and the action to be taken by them where they suspect any fraudulent activity.

To conduct investigations into fraudulent activities.

To provide assurances that any and all suspected fraudulent activity will be fully investigated.

 
SCOPE OF THE POLICY :
This policy applies to any fraud, or suspected fraud, involving employees of RCF (all full time, part time or employees appointed on adhoc / temporary / contract basis, probationers and trainees) as well as representatives of vendors, suppliers, contractors, consultants, service providers or any outside agency(ies) doing any type of business with RCF.
 
DEFINITION OF FRAUD :
"Fraud" is a willful act or omission, intentionally committed by an individual either acting independently or in group(s) - by deception, connivance, suppression, cheating or any other fraudulent or illegal means, thereby, causing wrongful gain(s) to self or any other individual(s) and / or wrongful loss to other(s). This also includes abatement of any act mentioned above. Many a times such acts are undertaken with a view to deceive / mislead others, leading them to do or prohibiting them from doing a bonafide act or take bonafide decision which is not based on material facts.
 
ACTIONS CONSTITUTING FRAUD :
While fraudulent activity could have a very wide range of coverage, following are some of the act(s) which constitute fraud.The list given below is only illustrative and not exhaustive:

Forgery or alteration of any document or account.

Forgery or alteration of cheque, bank draft or any other financial instrument etc.

Misappropriation or embezzlement of funds, securities, supplies or others assets by fraudulent means etc.

Falsifying records, removing the documents from files and /or replacing it by a fraudulent note etc.

Willful suppression, alteration or manipulation of facts or deception in matters of appointment, placements, submission of reports, tender committee recommendations, sales records etc.

Utilizing Company funds for personal purposes.

Authorizing or receiving payments for specified goods not supplied or services not rendered or for inferior goods and services which are not as per the specified quality or quantity.

Destruction, disposition, removal of records or any other assets of the Company with an ulterior motive to manipulate and misrepresent the facts  as a result of which objective assessment/decision is hampered.

Manipulating or unauthorized interfering with the Electronic records, or electronic data processing system in any way.

Irregularity in recording and reporting financial transactions.

Irregularities or deliberate inaccuracies in any kind of report, which may lead to distortion of facts and adversely affect the process of decision making.

Willfully causing loss of revenue or reputation of the company in any manner.

Any other act that falls under the gamut of fraudulent activity and considered as such by the management.

REPORTING OF FRAUD :
Any employee (full time, part time or employees appointed on adhoc/temporary/contract basis, probationers and trainees), representative of vendors, suppliers, contractors, consultants, service providers or any other agency(ies) doing any type of business with RCF as soon as he / she comes to know of any fraud or suspected fraud or any other fraudulent activity must report such incident(s). Such reporting shall be made to the designated Nodal Officer(s).  The management shall appoint Nodal Officers for each division / dept. If, however, there is shortage of time such report should be made to the immediate controlling officer / Vigilance dept. whose duty shall be to ensure that input received is immediately communicated to the Nodal Officer. The reporting of the fraud normally should be in writing. In case the reporter is not willing to furnish a written statement of fraud but is in a position to give sequential and specific transaction of fraud/suspected fraud, then the officer receiving the information/Nodal Officer should record such details in writing as narrated by the reporter and also maintain the details about the identity of the official / employee / other person reporting such incident. Reports can be made in confidence and the person to whom the fraud or suspected fraud has been reported must maintain the confidentiality with respect to the reporter and such matter should, under no circumstances, be discussed with any unauthorized person.

All reports of fraud or suspected fraud shall be handled with utmost speed and shall be coordinated by Nodal Officer(s) to be nominated.

The Vigilance Department should get regular updates from the Nodal Officer.

Officer receiving input about any suspected fraud, Nodal Officer(s) shall ensure that all relevant records documents and other evidence is immediately taken into custody and protected from being tampered with, destroyed or removed by suspected perpetrators of fraud or by any other official under his influence.

INVESTIGATION PROCEDURE :
The "Nodal Officer" shall, refer the details of the Fraud/suspected fraud to the Vigilance Department of RCF, for further appropriate investigation and needful action.

This input would be in addition to the intelligence, information and investigation of cases of fraud being investigated by the Vigilance Department of their own, as part of their day to day functioning.

After completion of the investigation, due & appropriate action (which could include administrative action, disciplinary action, civil or criminal action or closure of the matter if it is proved that fraud is not committed etc. depending upon the outcome of the investigation) shall be undertaken by the competent authority.

Vigilance Department shall apprise the Nodal Officer of the outcome of the investigation undertaken by them. There shall be constant coordination maintained between the two.

RESPONSIBILITY FOR FRAUD PREVENTION :
Every employee (full time, part time, adhoc, temporary, contract, probationers and trainees), representative of vendors, suppliers, contractors, consultants, service providers or any other agency(ies) doing any type of business with RCF, is expected and shall be responsible to ensure that there is no fraudulent act being committed in their areas of responsibility/control. As soon as it is learnt that a fraud or suspected fraud has taken place or is likely to take place they should immediately apprise the same to the concerned as per the procedure.

All controlling officers shall share the responsibility of prevention and detection of fraud and for implementing the Fraud Prevention Policy of the Company. It is the responsibility of all controlling officers to ensure that there are mechanisms in place within their area of control to :-

Familiarize each employee with the types of improprieties that might occur in their area.

Educate employees about fraud prevention and detection.

Create a culture whereby employees are encouraged to report any fraud or suspected fraud which comes to their knowledge, without any fear of victimization.

Promote amongst employees, awareness of ethical principles subscribed to by the Company.

Controlling Officers should evolve adequate mechanism to prevent fraud in their respective areas of operation. Adequate and timely action should be initiated if a fraud is likely to be committed or has already been committed.

It is the responsibility of each controlling officer to regularly monitor all systems and procedures in their respective areas of operation to ensure that the possibility of fraud is eliminated.

Due amendments shall be made in the general conditions of contracts of the organization wherein all bidders/service providers/vendors/consultants etc. shall be required to certify that they would adhere to the Fraud Prevenion Policy of RCF and not indulge or allow anybody else working in their organization to indulge in fraudulent activities and would immediately apprise the organization of the fraud/suspected fraud as soon as it comes to their notice.

These conditions shall form part of documents both at the time of submission of bid and agreement of execution of contract.

ADMINISTRATION AND REVIEW OF THE POLICY:
The Board will regularly review the progress in implementation of this Policy. The policy shall be revised or amended as and when required.
CMD shall be responsible for the administration of the Policy.

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