I. PREFACE

Direct Investment Finance Limited (DIFL) in other to combat any form of corruption, collusion, coercion, fraud, money laundering obstruction and terrorist financing within DIFL work group as update in DIFL’s Anti-Fraud Policy dated 21 August 2020. Direct Investment Finance Limited (DIFL) has a duty to its stakeholders to take all responsible steps to prevent fraud occurring, whether perpetrated by staff, contractors and suppliers, Borrower/Promoters other organisations or members of the public.
The Direct Investment Finance Limited (DIFL) will maintain robust control mechanisms to both prevent and detect fraud. All staff member regardless of position or qualification have a responsibility for maintaining documented control systems and must be seen to be setting an example by complying fully with procedures and controls. The effectiveness of controls will be subject to cyclical review by the Internal Auditors.

The DIFL conducts investigations stems from:
(i) London Supreme Court of Justice;
(ii) Article 12 of the DIFL Statute;
(iii) DIFL members of the Board of Governors’ Decision of 21 August 2020 concerning DIFL’s operations in the United Kingdom.
Created by the British Ombudsman, the DIFL is an authorised financial service provider in Europe and Arabian countries functioning under the laws of England and Wales AND Spain. As such, we operate in accordance with the British legal framework and DIFL Statute, Article 12 of which implies that: “In its financing activities, the DIFL shall employed its funds in the interests of the Group.”
DIFL shall ensure that loans are used according to the agreed purpose. In this context, DIFL shall endeavor to make sure that its operations are in line with the DIFL Code of conduct to combat corruption and fraudulent practices.
Consequently, DIFL will ensure that all prohibited conduct does not occur, and where it does occur, it will be handled adequately and in a timely manner. To this point, procedures for investigation shall be carried out.
In regards to this DIFL will align it's policies with foreign practice:
(i) The Organisation for Economic Co-operation and Development’s Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
(ii) United Nation
(iii) the COE Criminal Law Convention.
(iv) the FATF.
(iv) the (IFIs) Anti-Corruption Task Force.
All members of staff have a responsibility to protect the assets and reputation of the company and are expected to be alert to the potential for fraud. Line managers should brief staff on the common types of fraud perpetrated in their areas of responsibility. Confidential mechanisms have been established to allow staff to report suspected frauds to management. All reported suspicions will initially be investigated by the Fraud Investigation Group. The members of such a group may include:
1. The Members of the Board of Directors
2. The Audit Committee
3. Legal Department
4. Secretary
Further investigation can be carried by a notarized body through the Supreme Court of Justice.
1. Procedure for Fraud Prevention, Detection and Investigation
1.1. Introduction
The Direct Investment Funding Limited(DIFL) procedure for fraud prevention, detection and investigation is set out below.
The objectives of the procedure are to:
1. Encourage staff to be aware of fraud;
2. Bring suspected fraud to notice;
3. Provide a framework response plan for investigating and reporting fraud; and
4. Ensure both alleged and proven fraud are dealt with in a consistent and timely manner.
The Direct Investment Funding Limited(DIFL) has a unique role to play in the community and any instances of fraud or corruption may be damaging to public confidence and support. Losses due to fraud, theft or corrupt practices can have a Direct effect on jobs and the level and quality of service provision. Vigilance is essential since all staff are responsible for ensuring that the best possible service is provided to DIFL customers, borrowers, promoters and that value for money is secured from public funds.
Successful fraud prevention involves creating an environment which inhibits fraud. Taking immediate and vigorous action if fraud is detected is not only necessary to prevent future losses, but also helps deter frauds. An employee who is alert to the possibility of fraud and who acts accordingly on a day-today basis is a powerful deterrent against fraud.
1.2. Fraud Prevention
Fraud can be defined as ‘any act of wildful dishonesty to gain individual or collective advantage’. It is taken to include theft, misuse of property, corruption, the alteration of financial or other records or any unauthorised act which results Directly or inDirectly in financial gain to the perpetrator or a third party. Fraud can he perpetrated against an employee, borrower/promoter, suppliers, Government Agencies or Departments, or the public. Employee should be aware that gifts, including hospitality, offered by contractors, suppliers and service providers may place employees in a vulnerable position.
1.3. Management Responsibility and Risk Management
The prime responsibility for preventing fraud lies with management through:
a. identifying risks to which systems and procedures are exposed;
b. designing, implementing, documenting and operating of internal controls;
c. establishing an environment that promotes compliance with internal controls;
d. promoting fraud awareness amongst staff; and
e. fostering an ‘anti-fraud’ culture.
However, while management committees are responsible for assessing and controlling the level of risk within their areas of authority, it is the responsibility of all staff to be aware of fraud and to take the necessary steps to minimize the risk to the Company.
Managing the risk of fraud is the same in principle as managing any other business risk. It is best approached systematically both at organisational and operational level. Managers should identify risk areas, assess the scale of risk, allocate responsibility for managing specific risks and implement and test controls to minimize the risks.
Management also have a responsibility to familiarize themselves with common fraud techniques in areas for which they have control. Managers should also ensure that staff in their areas of operation are familiar with common types of fraud.