The Company is committed to the protection of its assets against losses to fraud and corruption. It is working to make sure that the opportunity for fraud and corruption is reduced to the lowest possible level. It will be supported in this by the honest majority of people who oppose fraud.
The Company aims to prevent fraud and corruption by:
• Taking a strategic approach to managing fraud risk;
• Promoting an anti-fraud and corruption culture to which everyone is committed;
• Encouraging the reporting of reasonably held suspicions;
• Assessing, and reviewing, areas where the risk of fraud and corruption is greatest, and providing adequate resources to carry out preventative and detective anti-fraud controls in those areas;
• Designing and operating systems, procedures and policies which minimise the risk of fraud and corruption;
• Assisting government bodies, where appropriate, in their investigations into fraud and corruption; co-operating with other bodies to prevent and detect fraud and corruption
• Complying with the good practice as set out in the Money Laundering Regulations 2007;
• Creating an anti-bribery culture, supported by policies and procedures, and ensuring compliance with its corporate responsibilities under the Bribery Act 2010;
• Providing appropriate training to members, managers and staff to make them aware of fraud risks and of their responsibilities under this and related company policies.
Where possible, the Company will seek to ensure that individuals who have acted, or who have attempted to act, fraudulently or corruptly are prosecuted and any proceeds of their actions are recovered.
Members of the public, partners, contractors, suppliers and other external organisations should be encouraged to raise any issues that concern them regarding possible fraudulent, corrupt or other illegal acts, through whichever channel they consider appropriate. Requirements on contractors, partners and suppliers parties to abide by this Policy in the conduct of their business with and for Bolton at Home will be included in tender documents and terms of contract.
In the event that complaints against the Company from external bodies cannot be resolved informally the Company has a formal complaints procedure. Allegations received by anonymous letters or telephone calls must be treated seriously and investigated in an appropriate manner as far as it is practical to do so, unless there are good reasons to believe that the allegation is not genuine.
Item 15 - Anti fraud and corruption policy (2) - appendix (policy).