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 :-
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:
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 :
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 :-
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.
