Anti-Fraud Policy

Zajl & Partners Consultancy (“we,” “us,” or “our”) is committed to maintaining the highest standards of integrity and preventing fraud in all its forms. This Anti-Fraud Policy outlines the measures we take to detect, prevent, and respond to fraudulent activities affecting our website, services, clients, and partners. By engaging with us, you agree to the terms of this policy.

1. Purpose & Scope

This policy:

• Defines what constitutes fraud.
• Describes the responsibilities of employees, clients, and partners.
• Sets out the controls and procedures we use to mitigate fraud risk.
• Applies to all Zajl & Partners staff, contractors, clients, and third-party service providers.

2. Definitions

• Fraud: Any deliberate act or omission intended to secure an unfair or unlawful gain.
• Misappropriation: Unauthorized use or theft of company or client assets.
• Falsification: Altering records, documents, or data to mislead or conceal.
• Corruption: Offering, giving, soliciting, or accepting anything of value to influence an action.

3. Prohibited Activities

No one associated with Zajl & Partners may:

• Submit false or misleading information in applications, invoices, or reports.
• Misuse client funds, deposit accounts, or corporate assets.
• Collude with external parties or insiders to conceal improper transactions.
• Circumvent internal controls or approval processes.

4. Fraud Prevention Measures

1. Segregation of Duties
   • Separate roles for transaction initiation, authorization, and reconciliation.
2. Verification & Due Diligence
   • Perform Know-Your-Client (KYC) checks on all new clients.
   • Validate the authenticity of documents (e.g., corporate registries, passports).
3. Access Controls
   • Restrict system and data access based on role and need-to-know.
   • Enforce strong password policies and multi-factor authentication.
4. Transaction Monitoring
   • Implement real-time monitoring for unusual payments, duplicate invoices, or round-sum transfers.
   • Flag and review any activity above predefined thresholds.

5. Employee & Client Obligations

• Employees must:
  • Adhere to all finance, procurement, and IT security procedures.
  • Complete mandatory fraud-awareness training annually.
  • Immediately report any suspicion of wrongdoing.
• Clients & Partners must:
  • Provide accurate information and notify us of any changes.
  • Use secure channels for transmitting sensitive data.
  • Refrain from tampering with or forging documents.

6. Detection & Investigation

• Reporting Channels:
  • Employees and third parties may report concerns anonymously via whistle-blower hotline or email [email protected].
• Investigation Process:
  • All reports are logged and assessed by the Risk & Compliance Team.
  • If warranted, an independent investigation is launched, preserving confidentiality.
  • Findings are documented, and corrective actions are recommended.

7. Consequences of Fraud

• Disciplinary Action:
  • Violators face disciplinary measures up to and including termination of employment or contract.
• Legal Action:
  • We will pursue civil remedies and cooperate with law enforcement for criminal prosecution.
• Restitution:
  • Recoverable losses will be sought from the responsible parties.

8. Record Keeping & Reporting

• Maintain all records of investigations, audit trails, and remediation actions for a minimum of five years.
• Provide periodic fraud-risk reports to senior management and the Board of Directors.

9. Policy Review

This policy is reviewed at least annually or following a significant fraud incident, regulatory change, or organizational restructuring. Updates are communicated to all stakeholders and published on our website.