MIDDLE EAST HEALTHCARE COMPANY
FRAUD/WHISTLE BLOWER POLICY
This Fraud Policy has been drafted by the MEAHCO Assurance department, upon special instructions of the MEAHCO Chairman, to facilitate the development of controls that will aid in the detection and prevention of fraud against MEAHCO. It is the intent of MEAHCO to promote consistent organizational behavior by providing guidelines and assigning responsibility for the development of controls and conduct of investigations.
SCOPE OF POLICY
This policy applies to any irregularity, or suspected irregularity, involving employees as well as vendors, contractors, consultants, outside parties, and/or any other parties with a business relationship with MEAHCO. Any investigative activity required will be conducted without regard to the suspected wrongdoer’s length of service, position/title, or relationship to the Company.
ACTIONS CONSTITUTING FRAUD
Fraud is defined as “any illegal acts characterized by deceit, concealment or violation of trust. These acts are not dependent upon the application of threat of violence or of physical force. Frauds are perpetrated by parties and organizations to obtain money, property, or services; to avoid payment or loss of services; or to secure personal or business advantage”.
The terms fraud and other fiscal irregularities refer to, but are not limited to:
Any dishonest or fraudulent act.
Misappropriation of funds, securities, supplies, or other assets.
Impropriety in the handling or reporting of money or financial transactions.
Profiteering as a result of insider knowledge of company activities.
Disclosing confidential and proprietary information to outside parties.
Accepting or seeking anything of material value from contractors, vendors, or persons providing services/materials to the MEAHCO or any of its subsidiaries. Exception: Gifts less than SAR 50 in value or have special approval from Chairman for higher value.
Destruction, removal, or inappropriate use of records, furniture, fixtures, and equipment; and/or
Any similar or related irregularity.
Irregularities concerning an employee’s moral, ethical, or behavioral conduct should be resolved by relevant department head and the HR/Personnel manager.
HOW TO REPORT SUSPECTED FRAUD BY WHISTLE BLOWER
Great care must be taken in the investigation of suspected improprieties or irregularities so as to avoid mistaken accusations or alerting suspected individuals that an investigation is under way. An employee who discovers or suspects fraudulent activity will communicate the management/Chairman, immediately. The employee or other complainant should remain anonymous. The whistle blower should be informed of the following:
Do not contact the suspected individual in an effort to determine facts or demand restitution.
Do not discuss the case, facts, suspicions, or allegations with anyone unless specifically asked to do so by the Legal Department.
The whistle blower will report the suspected activity as follows:
Report to Whistle Blower
Chairman Legal Affair
Chairman GIAs and ROs
Management Any other Staff
Chairman Any other Staff (If management does not take action)
WHO IS RESPONSIBLE TO IMPLEMENT CONTROLS
Management/Executive Committee is responsible for the detection and prevention of fraud, misappropriations, and other irregularities. Each member of the management team will be familiar with the types of improprieties that might occur within his or her area of responsibility, and be alert for any indication of irregularity.
The MEAHCO Chairman has the primary responsibility for the investigation of all suspected fraudulent acts as defined in the policy. Upon receiving intimation of any irregularity the MEAHCO Chairman will immediately assign independent investigation of that irregularity, to the head of assurance department for estimation of loss in terms of money or company reputation and then forward their report to the Legal Department for penalizing the fraudster and to take legal action against him according to Saudi law/ relevant local law.
Any employee who suspects dishonest or fraudulent activity will notify the management/ MEAHCO Chairman immediately, and should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act (see HOW TO REPORT SUSPECTED FRAUD BY WHISTLE BLOWER section above). Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the MEAHCO from potential civil liability.
AUTHORIZATION FOR INVESTIGATING SUSPECTED FRAUD
The assurance department, investigating the fraudulent activity, will have:
Free and unrestricted access to all Company records and premises, whether owned or rented; and
The authority to examine, copy, and/or remove all or any portion of the contents of files, desks, cabinets, and other storage facilities on the premises without prior knowledge or consent of any individual who might use or have custody of any such items or facilities when it is within the scope of their investigation.
RECOVERY OF LOSS AND TERMINATION WITHOUT BENEFITS
In case the investigation concludes that the person was involved in any fraudulent activity causing loss of money/reputation to the company, the Legal affair will take action against that person according to the law, which may include as follow:
Recovery up to three times of the loss amount from the fraudster(s).
Fraudster(s) particulars will be reported to the general specialization or any official organization to stop them from coming back to the country.
Termination without all benefits.
DISTRIBUTION OF THIS POLICY
The HR/Personnel department is responsible to email the updated PDF copy of this policy to all employees in the company at their email addresses, annually.
The management is responsible for the administration, revision, interpretation, and application of this policy. The policy will be reviewed annually and revised as needed after getting approval from MEAHCO Chairman .