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Anti-Fraud, Bribery and Corruption Policy

Relevant Legislation

3.1  Fraud is defined in the Fraud Act 2006 which came into effect from 15 January 2007. There are three basic types of fraud:

  • False representation

Where a person makes a representation that is intentionally and dishonestly made, knowing that it is, or might be, untrue or misleading with intent to make a gain for him/herself or another, to cause loss to another or to expose another to risk of loss.

  • Failing to disclose information

Where a person fails to disclose information to another person when he/she is under a legal duty to disclose that information honestly, intending by that failure to make a gain or cause a loss.

  • Abuse of position

Where a person occupies a position in which he/she is expected to safeguard, or not to act against, the financial interests of another person and abuses that position dishonestly intending by that abuse to make a gain/cause a loss (the abuse may consist of an omission rather than an act).

A person can be found guilty even if there is no victim of the crime; all that needs to be proven is the intent to make a gain or cause a loss by the accused.

3.2 The Bribery Act 2010 contains two general offences:

  • Section 1 - the offering, promising or giving of a bribe (active bribery);
  • Section 2 - and the requesting, agreeing to receive or accepting of a bribe (passive bribery)

3.3 The Theft Act 1968 and the Forgery and Counterfeiting Act 1981 define offences of:

  • Theft
  • False Accounting
  • Forgery

3.4 The Criminal Finance Act 2017 created a criminal offence of failing to put adequate measures in place to prevent tax evasion in the United Kingdom or overseas.

3.5 The Proceeds of Crime Act 2002 made it a criminal offence to fail to disclose knowledge of or suspicion of money laundering.

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