1.1 The purpose of this Anti-Fraud, Bribery and Corruption Policy (“Policy”) is to set out the Company’s stance on fraud, bribery and corruption.
2.0 Policy Statement
2.1 Labuan Reinsurance (L) Ltd has a ‘zero tolerance’ policy towards fraud, bribery and corruption. This means that it does not accept any level of fraud, bribery or corruption within the organisation.
2.2 It will always seek to take disciplinary and /or legal action against those found to have perpetrated, be involved in, or assisted with the fraudulent or other improper activities.
2.2 The Company requires all staff to act honestly and with integrity at all times, and must immediately report any incident or suspicion of fraud, bribery or corruption. Anyone raising a concern in good faith will not be penalised.
2.3 All reports of fraud, bribery and corruption will be taken seriously, and be investigated fairly and appropriately.
3.1 This Policy is applicable to all staff of Labuan Re, including external parties such as brokers, cedants, consultants, suppliers, contractors, and/or any other party with a business relationship with the Company.
3.2 The Risk & Compliance Officer will make aware of this Policy to the staff. For external parties mentioned in point 3.1 above, it will be made known as and when necessary by the staff that interacts with them.
3.3 All suspected or actual instances of fraud, bribery and corruption shall be reported under the Complaints Procedure. Failure to report could result in disciplinary action.
4.0 Definition & Interpretation
In this document
a) “Bribery” means giving or offering someone a financial or other advantage to encourage that person to perform their functions or activities improperly, or to reward someone for having already done so.
b) “Conflict of interest” means where an individual has private interests that may or actually do influence the decisions that they make as an employee or representative of an organisation.
c) “Corruption” means the misuse of entrusted power for personal gain. This would include dishonest or fraudulent behavior by those in positions of power, such as managers or government officials. It would include offering, giving and receiving bribes to influence the actions of someone in a position of power or influence, and the diversion of funds for private gain.
d) “Fraud” means knowingly making an untrue or misleading representation with the intention of making a gain for oneself or another or causing a loss, or risk of loss, to another.
e) “Labuan Re” or “the Company” means Labuan Reinsurance (L) Ltd