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Anti-Fraud and Whistle-Blowing Policy

Scope

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The scope of this document covers the high level policies required to be in place for the Internal Audit Directorate to ensure that Qatar Foundation (QF) is committed to the highest possible standards of openness, integrity and accountability in all its affairs, and maintain a culture of honesty and opposition to fraud and corruption. This policy not only covers possible improprieties in matters of financial reporting, but also covers other QF policies and operational activities. Fraudulent or corrupt acts may include:

Systems Issues
Where a process/system exists that is prone to abuse by either employees or public.

Financial Issues
Where individuals or companies have fraudulently obtained money from the Company.

Equipment Issues
Where the Company’s equipment is used for inappropriate personal use.

Resource Issues
Where there is a misuse of resources, (for example, theft of materials).

Other Issues
Activities undertaken by officers of the Company which may be: unlawful; against the Company’s policies; falls below established standards or practices; or amounts to improper conduct.

Objective

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The objective of the QF Anti-Fraud Whistle Blowing Policy is to provide the framework for Internal Audit Directorate to prevent, report, and manage fraud corruption to:

  • Support Qatar Foundation’s values;
  • Ensure employees and stakeholders can raise concerns about possible improprieties in matters of financial reporting and other malpractices without fear of suffering retribution; and
  • Provide a transparent and confidential process for dealing with concerns.

Policy

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  1. To develop an anti-fraud culture, Internal Audit Directorate to review QF system/processes on a regular basis to prevent/reduce the likelihood of fraudulent and corrupt acts.
  2. Internal Audit Directorate shall take all reported cases seriously and investigate them before taking any action. All reported cases raised shall be treated fairly and properly.
  3. QF Internal Audit Directorate will decide on the most appropriate investigation methods and resources in coordination with the relevant directorates within QF to deal with all complaints raised through them and, if necessary, route them to the Audit Committee to reach a decision.
  4. In the case of concerns requiring immediate action, the Chief Audit Executive will decide upon the severity of the case and will seek guidance from the Chairman of the Audit Committee or one of the members through appropriate channels. The complaint will be raised during the next Audit Committee meeting.
  5. Internal Audit Directorate should develop an accessible communication channel to report on fraud in a confidential manner. Develop other Terms and Conditions and procedures where necessary:

    • to allow employees to report reasonably and in good faith any existing malpractice in the workplace if, for any reason, they are reluctant to report this immediately to their line managers.
    • to allow and encourage the public to contact the Internal Audit Directorate when they suspect fraud and corruption within Qatar Foundation.

Terms and Abbreviations

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Fraud
The intentional distortion of financial statements or other records by persons internal or external to the company that is carried out to conceal the misappropriation of assets or otherwise for gain.

Corruption
The offering, giving, soliciting, or acceptance of an inducement or reward, which may influence the action of any person.


Whistleblower
A person who, in good faith, submits a confidential or anonymous allegation of misconduct or potential wrongdoing. Whistle-blowers are not those who raise issues or concerns through the normal business or management channels in an open, non-confidential manner.