(Prevention or Aftermath of Fraud)
Welcome to MCCCI VIRTUAL TRADE PLATFORM. This anti-fraud policy governs the prevention and detection of fraud for users who access and use of the website, mobile site, mobile application and other portals owned, operated, branded or made available by the Malawi Confederation of Chambers of Commerce and Industry (MCCCI), hereinafter “the Confederation” from time to time which relate to the MCCCI Virtual Trade Platform hereinafter, “the Platform”. Under this policy user includes a Trader or merchant or seller or advertiser or buyer of produce, products, goods or service providers (referred to as “User” hereinafter) and the Confederation.

1. Purpose of Fraud Policy
1.1. The fraud policy is intended to deter fraudulent activities from taking place on the Platform and to facilitate the identification and reporting of suspected and actual fraudulent activities.
1.2. The Platform’s Fraud Policy sets out the responsibility of employees, management, users and third parties in relation to identification and reporting of fraud or suspected fraud within
the Platform.
1.3. Reporting of fraud is mandatory and transcends any confidentiality clauses. Fraud and/or a suspected fraud can also be reported through the MCCCI Whistleblower Policy.
2. Scope of Fraud Policy
2.1. The Fraud Policy applies to any irregularity, or suspected irregularity, involving the user, third parties, any unknown person, employees and where appropriate agents doing
business with the Confederation or its employees, and/or any other parties having a business relationship with the Platform or some other persons unknown to the Confederation.
2.2. For the purposes of the policy, the term ‘employee’ includes individuals who work for the Confederation such as external consultants, contractors, agency personnel, and the management of the Confederation.
3. Definition of Fraud
3.1. Under this Policy, Fraud means a deliberate intent to acquire money or produce, products, goods or services dishonestly through the falsification of records or documents to obtain an unjust/illegal advantage. The deliberate changing of financial statements or other records by either; a member of the public, someone who is an employee or is a volunteer for the Confederation.
3.2. attempted fraud is therefore treated as seriously as accomplished fraud.
3.3. For the purposes of the policy, fraud shall include but is not limited to:
3.3.1. Payment fraud (identity fraud)
3.3.2. Merchant Goods Fraud (eg Advertising non-existent goods)
3.3.3. Submitting false claims for payments;2
3.3.4. Accepting or offering a bribe or accepting gifts or other favours under circumstances that might lead to the inference that the gift or favour was intended to influence an employee’s decision- making while serving the Confederation;
3.3.5. Theft or misappropriation of produce or products or goods or assets owned or managed by the Confederation or Users;
3.4. Any employee or user or third party, external contractor working on the Platform assumes a commitment to acting towards prevention, detection and reporting of fraud or suspected fraud by taking measures necessary to report any circumstances that are fraudulent that have come to their attention.
3.5. The Confederation will prosecute any persons who are deemed liable for:
3.5.1. Blackmail or extortion;
3.5.2. Off the books’ accounting, or making false or fictitious transactions;
3.5.3. Knowingly creating and/or distributing false or misleading financial reports;
3.5.4. Paying of excessive prices or fees where justification thereof is not documented;
3.5.5. Violation of the Platform’s procedures with the aim of personal gain or to the detriment of the Platform;
3.5.6. Willful negligence intended to cause damage to the material interest of the Confederation and the Platform; and
3.5.7. A dishonorable or reckless or deliberate act against the interests of the Confederation and the Platform.
4. Responsibility for the Prevention and Detection of Fraud
4.1. All users and employees have a duty to guard against fraud. Employees are expected to identify processes and procedures that may be vulnerable to fraud and to draw such instances to the attention of management in their decision.
4.2. Management has a particular responsibility to be familiar with and alert to the types of fraud that might occur in their area and to put in place effective controls to avoid such occurrences.
4.3. Management shall provide support to and work with law enforcement agencies in the detection, reporting and investigation of dishonest or fraudulent activity, including the prosecution of offenders. Once fraud is detected, the officer responsible for the Platform is responsible for taking appropriate corrective action to ensure adequate controls are put in place to prevent re-occurrence of improper activity.
5. Procedure for Reporting a Suspected Fraud
5.1. Reporting fraud according to the following procedure is mandatory for any user and employee who suspects that a fraud has occurred. Employees and Users who cover up, obstruct, or fail to report (or monitor) fraud that they become aware of, or ought to have been aware of, may be considered to be an accessory after the fact is discovered and may be subject to the Confederation’s disciplinary procedures which could involve action up to and including dismissal and debarment from transacting on the Platform. Users who3 threaten retaliation against a person reporting a suspected fraud shall be subject to the disciplinary procedures which could include action up to and including exclusion from the Platform or prosecution or both and debarment from transacting on the Platform.
5.2. Details of the incident, facts, suspicions or allegations should not be discussed with anyone inside or outside the Platform unless the Confederation’s investigating team specifically directs this. In particular, the matter should not be discussed with the individual suspected of fraud.
5.3. Fraud can be detected at any level within the Platform, and the following will apply in the reporting of suspected internal fraud:
5.3.1.Any user who suspects that fraudulent activity is taking place should, in the first instance, report the matter to the Confederation using mcccivirtualtradeplatform@mccci.org and to law enforcing agencies.
6. References for Employees Disciplined or Prosecuted for Fraud
6.1. Where there is a request for a reference for an employee or user who has been disciplined or prosecuted for fraud or dishonesty, the Confederation shall prepare any reply to such a request having regard to the Platform’s policies and Employment Law.
7. Review of Fraud Policy
7.1. The Fraud Policy will be reviewed at least every year by the Finance, Audit and Administration Committee.

Approved by the Council of the Confederation on 8th December 2022

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