Anti-Fraud Policy

Introduction

The perpetuation of fraud is the sad and unfortunate reality of our times. In common terminology, fraud means deception or misrepresentation with the intent of obtaining the wrongful gain. Fraud perpetrated against a company can lead to significant financial losses as well as loss of goodwill and Public image. Global Tree Overseas Education and Immigration Services Ltd. (hereinafter referred to alternatively as ‘Global Tree’ or ‘the company’) is committed to providing the best quality service to its clients and to adhering to the highest possible standards of integrity, honesty, and corruption free behavior, and expects all its employees and business partners to do the same. In order to maintain the highest standards possible, Global Tree has put in place a comprehensive anti-fraud policy.

General Principles

It is the policy of Global Tree to promote a culture of openness, integrity, and honesty among its employees. The company realizes the importance of providing best quality services to clients in an effort to build good brand value and brand awareness amongst current and potential clients. In light of this, Global Tree aims to safeguard its reputation through the implementation of the anti-fraud policy.

Scope and Intent of Policy

The policy is intended to provide comprehensive information about fraud to all stakeholders of the company, to delineate in detail the different types of fraudulent behavior and set out pre- approved measures to address the same, to create a fraud awareness program to help employees and other stakeholders easily identify and report fraudulent behavior, and to create a fraud prevention and reporting system to enable pro-active tackling of fraud and fastest possible recovery of fraud losses.

Definitions and Types of Fraud

Fraud, by definition, is a willful act committed by an entity or an individual of deliberate misrepresentation, deception, suppression, cheating or any other fraudulent behavior, in order to accumulate wrongful gains to self and losses to the company. Types of fraud may include but are not limited to

• Fraud committed by business partners when doing business with the company
• Fraud committed by prospective employees during the selection process
• Fraud committed by employees when dealing with clients either through withholding information or providing falsified information
• Fraud committed by clients with a willful intention to mislead and provide false information

The company has to at all times guard itself against fraud, which can be perpetrated against it by any of the following, acting either independently or in collusion with each other

• Ex-employees and employees of the company
• Persons engaged by the company for work on a contractual or ad-hoc basis
• Vendors to the company
• Advisors, consultants, investigators and other professional service providers to the company either in their individual capacity or through their employees, knowingly or unknowingly
• Third Party Administrators (TPA) and their employees or representatives
• Clients of the company.

Examples of Fraud

The following are some commonly found examples of fraud that the company needs to be vigilant about. It is to be noted that it is not possible to cover all kinds of fraud in below list as definitions of fraud are constantly changing

• 1Forgery or unauthorized alteration of any legal or financial documents
• Misappropriation of funds or utilizing company funds for personal purposes
• Providing falsified information during personal interview or counseling sessions
• Destruction, disposition or removal of documented or electronic records with a motive to suppress objective assessment of facts
• Removal of assets of the company
• Authorizing or receiving payments for services not rendered
• Failing to honor payment commitments

Compliance

All employees working in the company and all individuals/organizations/entities dealing with the company shall undertake to endeavor in every possible manner to the rules and regulations laid down in this policy. Non-compliance shall be deemed as a violation of terms and conditions of employment or terms and conditions of contract (as the case may be) and shall be dealt with summarily as per the Company’s disciplinary procedure or terms of the particular contract(s) or the law as applicable and appropriate. Also, all employees are responsible for bringing to notice of their immediate superiors or the management about any fraud detected as soon as it comes to their notice. It is the responsibility of employees to ensure that in respect of their areas of responsibility, all reasonable necessary steps are taken for prevention of fraud and all possible necessary action is taken in case of suspicion of commission of a fraud or detection of an actual fraud. Individuals who cover up, obstruct, fail to report or monitor a fraud of which they have become cognizant of, shall be considered an accessory after the fact and may face disciplinary action. Also, disciplinary action shall be taken against persons who threaten harm or retaliation against persons reporting fraud perpetrated by them, or persons willfully making false allegations of fraud against another person with an intention to damage their reputation

Prevention and Control of Fraud

The prevention of fraud is possible only through the proper awareness of the anti-fraud policy and the fraud prevention effort. As a part of its ongoing commitment in its fight against fraud, the company shall aim at continuously educating its employees, vendors, contractors, clients and other stakeholders as well as the general public on fraud prevention and enlist their support and participation in the fraud prevention efforts. The anti-fraud policy document shall be published on the company’s website, as well as a physical record will be maintained of it in all of the company’s office. The company shall also undertake to educate and sensitize the clients and the general public through flyers and other material. The company shall aim to improve the knowledge of its employees on the subject of fraud through targeted training sessions and/or circulars/newsletters/email

Reporting Fraud and Fraudulent Behavior

Global Tree states that it is the bounden duty of every employee of the company to report to management any information or suspicion that they may possess a fraudulent activity or suspected fraudulent behavior. Each and every instance of attempted fraud or detected fraud should be brought without fail to either their immediate supervisors or to the management, regardless of whether aforesaid fraud has caused financial losses to the company or not.

Whistle Blower Policy

The company will put in place a whistleblower policy to protect the identity of any employee/client/stakeholder who reports the perpetration of fraud at any level in the company. All steps shall be taken to ensure that the anonymity of the reporting person is maintained.

Defamation Policy

Global Tree as a provider of overseas education and immigration services has a strong online presence, both through its own website and through social media networks such as Facebook, Quora, and other such platforms. It invites honest and constructive reviews of its services and service providers through these platforms and strives to constantly learn from critical reviews and to improve its quality of service. However, it has come to our light that certain unscrupulous individuals are deliberately leaving critical and damaging reviews with a malicious intent of harming the reputation and marketability of the company. It is stated herein that any individuals who are found guilty of the same will be reported to the law enforcement agencies and will be tried to the fullest extent of the law.