This Policy has been assembled to protect company operations, clients and

employees from the adverse effect of fraudulent behaviour.

APEX Personnel Limited always requires all staff to act with honesty, integrity and to safeguard the assets for which they are responsible. Bribery, fraud, and theft are ever present threats to these assets and hence must be a concern to all members of staff.

Fraudulent and dishonest behaviour can result in substantial cost to the company, loss of

business and damage to our reputation.

This policy applies to all employees, directors, contractors, and consultants of APEX Personnel Ltd.

Fraud is the deliberate action by a person; or allowing action to be taken by another; for the

purpose of, or intention of;

• Obtaining money, assets, or services.
• Distorting business performance.
• Causing loss to the company, supplier, or employee.
• Accepting high value gifts or inappropriate hospitality.
• Prejudicing the Company’s competitive position or business reputation.
• Money laundering.
• Unauthorised release of confidential information.
• Employment of illegal emigrants, those working under an assumed name or anyone

unauthorised to work or carry-on business in the UK.

All persons covered by this policy have a role to play in preventing, detecting and reporting

fraud.

You must:

• Carry out your duties in such a way as to prevent fraud.
•  Immediately report any suspicion of fraud to a Senior Manager

Following the reporting of suspected fraud;

• All reported incidents of fraud will be investigated.
• The confidence of those reporting the incident or suspicion of fraud will be respected.
• The investigation will be carried out either internally by a Senior Manager, appointed by the

Operations Director, having no operational responsibility within the business unit implicated or externally by an appointed agency reporting to the Operations Director.

In all cases the Operations Director will take the decision as to whether the police or other

authorities should be brought into the investigation.