STEEL RECON INDUSTRIES SDN BHD (16592-W)
Steel Recon Industries Sdn Bhd (“SRI”) is committed to conducting all of its business with the highest level of ethics and integrity. The Company requires all employees (including full time, probationary, contract and temporary staff) (“Employees”) and Directors of the Company to be committed to acting professionally and with integrity in their business dealings.
To uphold this commitment and in particular, a zero-tolerance approach to fraud, SRI requires adherence to this Anti-Fraud Policy (“Policy”). This policy is intended to reinforce management procedures designed to aid in the prevention, detection and investigation of fraud, thereby safeguarding the Company’s assets and providing protection from the legal and reputational consequences of fraudulent activities. This Policy is supplemental to, and shall be read in conjunction with the SRI staff handbook.
2.0 DEFINITION OF FRAUD
Fraud involves an act of intentional deceit to secure (by the act or omission of another person) an unfair or unlawful gain for oneself or another or a loss to another. Acts such as deception, bribery, forgery, extortion, corruption, conspiracy, embezzlement, misappropriation, and collusion may or may not constitute fraud, but are also included within the scope of this policy.
Fraud against a company can be committed either internally by employees, managers, officers, or owners of the company, or externally by customers, vendors, and other parties. Other schemes defraud individuals, rather than organizations.
Examples of fraud:
- False accounting, including deliberate misstatement of financial information for personal and/or financial gain;
- Theft including trade secrets, intellectual property, equipment, etc;
- Using false payment instructions, invoices or cheques in order to receive a payment to ones’ own account, or to a third-party account in exchange for a benefit;
- Falsification of payroll records, unsubstantiated expense claims, accepting or providing bribes or kickbacks in exchange for business whether or not for SRI’s benefit;
- Missing invoices/ contracts, Vendor selection without following procurement policy, fake vouchers, fake employment documents etc.
- Suspicious employee and/or customer signatures on delivery orders, constant mistakes and changes in documentation, constant excuses for delay in submitting payment details of customers etc.
The objective of the Policy is to provide information and guidance to the Directors and Employees on standards of behaviour to which they must adhere to and how to recognise as well as deal with any fraud, or suspected fraud, involving SRI and its subsidiaries, as well as its employees, vendors, or any other parties that having a business relationship.
The Policy is not intended to be exhaustive, and there may be additional obligations that Directors and Employees are expected to adhere to or comply with when performing their duties. For all intents and purposes, the Directors and Employees shall always observe and ensure compliance with all applicable laws, rules and regulations to which they are bound to observe in the performance of their duties.
The Policy is applicable to all Directors and Employees of the Company. It is supported by the Internal Audit Function and Chief Operating Officer (“COO”) is responsible for the administration of this policy.
Each Employee has a duty to read and understand the Policy. Violation of any of the Policy’s provisions may result in disciplinary action, including termination of employment.
If a Director requires further clarification on the Policy, the Director may liaise with the COO or Managing Director (“MD”), whereas for an Employee, the Employee may refer or highlight any concerns to the immediate superior, Head of Division or Directors.
5.0 ZERO-TOLERANCE APPROACH
SRI adopts a Zero-tolerance approach to fraud and expects all employees and third parties to act with honesty and integrity.
a) Any allegation or suspected cases of fraud as listed below will be investigated
b) All substantiated frauds will result in disciplinary actions, including prosecution and termination (unless unlawful) and reporting to law enforcement authorities for prosecution, civil action and/or other legal remedy (if reasonably practicable). Board of Directors should set parameters/ guidelines taking into account the potential negative impact to the working environment by failing to report cases of substantiated fraud to law enforcement authorities.
c) Length of service, relationship to SRI or offer to repay the defrauded amount should not be a consideration in assessing disciplinary actions or reporting to law enforcement authorities.
d) SRI Group will not hire, recruit or engage anyone convicted for fraud or if SRI has knowledge of involvement in frauds.
6.0 REPORTING OF VIOLATIONS OF THE POLICY
All employees must stay alert to the signs of fraud report when you find any opportunity or suspicious of fraud exits, regardless of value, to your immediate manager, Director of the company, COO or, if you prefer, instead to MD. MD or COO must be notified immediately if the alleged fraud involves manipulation, omissions or misrepresentation of financial reports/ results.
- If your subordinate reports any suspected fraud then you should, in turn, report the matter to your Director in charge or Chief Operating Officer.
- Do not alert the suspected individual or other unauthorised persons in an effort to determine facts or suspicion. All cases of suspected fraud will be handled with utmost care / confidentially.
- Read the Policy and attend the relevant training programs provided by SRI to understand your obligations.
- Department functions are required to establish and maintain sufficient controls to ensure that fraud risk is properly monitored and mitigated. All employees should comply with controls and procedures in their areas of responsibility.
- Ensure that vendors, consultants, intermediaries and other external parties are aware of this SRI Anti-Fraud Policy.
- Cooperate in investigations and do not wilfully or knowingly state anything which you believe is false or you do not believe to be true.
If you think a suspected fraud could potentially give rise to material legal or regulatory exposure for SRI, COO should be consulted to help with the fraud report and investigation. While never a reason to delay or avoid internally reporting and investigating suspected fraud, COO can help preserve legal privilege, to the extent it is available, which may assist in managing any subsequent external proceedings.
7.0 REVIEW OF THE POLICY
This Policy may be reviewed and amended, at the Board of Director’s discretion from time to time, as and when necessary, to ensure its relevance and effectiveness in keeping with the company’s changing business environment, administrative or operational needs as well as changes to legislations. Changes to the Policy, if any, shall only be made with the Board of Directors’ approval in writing.