Last update: 7 January 2023
This document sets out the policy and procedures of VIP Exchange against fraud and other forms of dishonesty. It applies to Directors, staff and trusted partners. Anybody associated with VIP Exchange who commits fraud, theft or any other dishonesty, or who becomes aware of it and does not report it, will be subject to appropriate disciplinary action. VIP Exchange will continually strive to ensure that all its financial and administrative processes are carried out and reported honestly, accurately, transparently and accountably and that all decisions are taken objectively and free of personal interest. We will not condone any behaviour that falls short of these principles. All members of VIP Exchange have a responsibility for putting these principles into practice and for reporting any breaches they discover.
a) Fraud: A deliberate intent to acquire money or goods dishonestly through the falsification of records or documents. The deliberate changing of financial statements or other records by either; a member of the public, someone who works for VIP Exchange. The criminal act is the attempt to deceive and attempted fraud is therefore treated as seriously as accomplished fraud
b) Theft: Dishonestly acquiring, using or disposing of physical or intellectual property belonging to the firm or to individual members.
c) Misuse of equipment: Deliberately misusing materials or equipment belonging to VIP Exchange for financial or material benefit.
d) Abuse of position: Exploiting a position of trust within the organisation for financial or material benefit.
In relation to prevention of fraud, theft, misuse of trademark, facilities, equipment and abuse of position, specific responsibilities are as follows:
a) The internal control is based on an on-going process designed to identify the principal risks, to evaluate the nature and extent of those risks and to manage them effectively. Managing fraud risk is seen in the context of the management of this wider range of risks.
b) The Chief Executive Officer (CEO): Overall responsibility for managing the risk of fraud has been delegated to the CEO. The day to day responsibility has been delegated to the CFO to act on behalf of the CEO.
c) Management Team & Staff are responsible for:
- Ensuring that an adequate system of internal control exists within their areas of responsibility and that controls operate effectively;
- Preventing and detecting fraud as far as possible;
- Assessing the types of risk involved in the operations for which they are responsible;
- Reviewing the control systems for which they are responsible regularly;
- Ensuring that controls are being complied with and their systems continue to operate effectively;
- Implementing new controls to reduce the risk of similar fraud occurring where frauds have taken place.
- Conducting themselves with selflessness, integrity, objectivity, accountability, openness, honesty and leadership;
- Being alert to the possibility that unusual events or transactions could be indicators of fraud;
- Alerting their manager when they believe the opportunity for fraud exists e.g. because of poor procedures or lack of effective oversight;
- Reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events; and
- Cooperating fully with whoever is conducting internal checks or reviews or fraud investigations.
This policy will be reviewed on an annual basis.