ANTI-FRAUD POLICY
The objective of the anti-fraud policy is to strengthen a culture of prevention, detection and response of non-tolerance in the face of illegal, unethical acts and situations of fraud, within a framework of conduct and responsible behavior for all human beings.
DEFINITION OF POSSIBLE FRAUD ACTIONS.
Fraud actions can be presented in three broad categories, which in turn are typified in the issues that are linked to them. These categories, not exhaustive, are:
A. Corruption. Regarding corruption, this can be classified as one or more of the following facts:
- - Conflict of Interest
- - Bribery
- - Illegal gratification
- - Economic demands
- - Scam
- - Improper conclusion of Contracts
B. Embezzlement of Assets.
The originating from this classification could comprise one or more of the followingsituations:
- - Theft of securities (Cash, securities)
- - Cash and Non-Cash Embezzlement
- - Unregistered operations
- - Undue or Fraudulent Disbursements
- - Improper Use of Inside Information.
C. Alteration of information
- - Falseness in documents, presentation or delivery of documents that are not real or are improperly modified, which may lead to actions of deception, undue benefits or verification of untrue events, which, regardless of seeking personal benefit, may misleadwrong performances.
- - Alteration of information in databases. Change of sensitive information in the database to obtain benefit for oneself or for a third party.
- - Disclosure of information subject to reservation. Ignorance of the rules that regulate the reservation of financial information, handing it over or consulting it withoutauthorization of the holder.
ANTI-FRAUD POLICY
Xceess, as already mentioned, applies the principle of “Zero Tolerance” towards the commission of any fraudulent, corrupt or collusive practice in the development of its activities or operations. For the purposes of this policy, the following definitions will apply:
- Fraudulent practice is understood to be any action or omission, including false declaration, contrary to the truth and rectitude, by which it is deliberately induced or intended to mislead, in order to obtain undue benefit, or to evade an obligation.
- Corrupt practice means the act of offering, giving, receiving or directly or indirectly requesting anything of value to improperly influence the actions of another party, or the attempt to act in that way.
- Collusive practice means an agreement between two or more parties that has an improper purpose, which may include, among other things, influencing