Fraud Reporting Policy

  1. Purpose
  2. The fraud policy is established to facilitate the development of controls that will aid in the detection and procedures of reporting fraud at VM Marine Group (“The Company”) and its subsidiaries. It is the intent of VM Marine Group to promote consistent organization behavior by providing guidelines and assigning responsibility for the development of controls and conduct of investigations. 

  3. Scope
  4. This policy applies to VM Marine Group and all of its subsidiaries. This policy applies to any irregularity, or suspected irregularity, involving employees as well as shareholders, consultants, vendors, contractors, third party agencies doing business with employees of The Company, and/or any other parties with a business relationship with The Company and all of its subsidiaries.

    Any investigation activity required will be conducted without regard to the suspected wrongdoer’s length of service, position/title or relationship to The Company.

  5. Policy/Statement
  6. It is the responsibility of directors to prepare financial statements, which give a true and fair view of the affairs of the group, and of its profit or loss for the financial year.

    Financial personnel are expected to be aware of the potential risk of fraud and they will often occupy positions that could result in them becoming the first to be aware of any misappropriation or misreporting.

    Any indication of fraud (whether perpetrated from inside or outside of the business) or other material discrepancies must be notified immediately to the Group Financial Controller or any of the Executive Directors (collectively termed as the ‘Investigation Unit’).

    Investigation Responsibilities

    The Investigation Unit has the primary responsibility for the investigation of all suspected fraudulent acts as defined in the policy. If the investigation substantiates that fraudulent activities have occurred, the Investigation Unit will issue reports to the Audit Committee.

    Authorization for Investigating Suspected Fraud

    Members of the Investigation Unit will have:

    -           Free and unrestricted access to all Company records and premises, whether owned or rented.

    -           The authority to examine, copy, and/or remove all or any portion of the contents of files, desks, cabinets, and other facilities on the premises without prior knowledge or consent of any individual who may have custody of any of such items of facilities when it is within the scope of their investigation.

    Reporting Procedures

    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 underway.

    An employee who discovers or suspects fraudulent activity will contact the Investigation Unit immediately. The employee or other complainant may remain anonymous, though they are encouraged to put their name down.

    Contact details and names provided will be kept absolutely confidential.


    The Investigation Unit treats all information received confidentially. 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 reputations of persons suspected but subsequently found innocent, and to protect The Company from potential damage to its reputation.

    Any employee who suspects dishonest or fraudulent activity should not attempt to personally conduct investigations or interviews related to any suspected fraudulent act. 

  7. Associated Comments
  8. None

  9. Responsibilities
  10. It is the responsibility of all financial personnel at each business location to be aware of the potential risk of fraud and the procedure for reporting its existence.


    Promulgated on 21 Apr 2013

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