• Policy:
o IRC is committed to the highest standards of ethical conduct and the prevention of fraud. All employees and associated parties must act in accordance with these standards. Fraudulent activities will not be tolerated, and any violation of this policy will result in disciplinary action, including possible termination and legal prosecution.
• Procedures:
o Fraud Prevention
IRC will maintain a strong system of internal controls, including checks and balances, to minimize opportunities for fraud.
Regular training programs will be conducted for employees to raise awareness of fraud risks and their responsibilities.
A Code of Ethics and Conduct will be distributed to all employees and regularly reviewed.
o Fraud Detection
A confidential reporting system (whistleblower mechanism) will be available for employees to report suspicious activities.
Regular audits and reviews will be conducted by the Internal Audit to detect any irregularities in financial and operational transactions.
Continuous monitoring of transactions, patient billing, and procurement processes will be carried out to identify suspicious patterns.
o Reporting Fraud
Any employee who suspects fraud must report it immediately to the CEO or Operation director through the anonymous whistleblower system.
The whistleblower system allows for direct communication through either a message or email to the CEO/Operations Director, or through an in-person visit to their office.
All reports of suspected fraud will be treated confidentially and investigated thoroughly.
Retaliation against employees who report fraudulent activities will not be tolerated.
o Response to Fraud
Upon receiving a report of suspected fraud, the Internal Audit Department, in collaboration with management, will launch an investigation.
If the investigation confirms fraudulent activity, appropriate disciplinary action will be taken, including termination of employment if necessary.
Where applicable, the case may be referred to law enforcement or regulatory bodies for further action.
Fraud incidents and corrective actions taken will be documented and reported to the relevant governing bodies, if required.
o Risk Assessment
Management, in coordination with the Internal Audit Department, will periodically assess the organization’s exposure to fraud risks.
Based on risk assessments, controls and procedures will be updated to address any vulnerabilities.
o Training and Awareness
All employees will receive mandatory fraud awareness training upon hiring and during annual refreshers.
Employees will be informed of the key fraud risks, how to detect fraud, and the appropriate channels for reporting.
o Monitoring and Review
This policy will be reviewed annually or as needed to ensure its effectiveness and compliance with legal requirements and best practices.
Internal Audit will regularly monitor compliance with this policy and the effectiveness of fraud controls.
