The term \"fraud\" is used to describe a wide range of unethical behaviours, such as theft, corruption, embezzlement, bribery, forgery, misrepresentation, collusion, money laundering and the concealment of facts. It frequently involves the use of deception in order to obtain personal gain for a person linked to a public body or for a third party, or losses for another person. Intent is the key element that distinguishes fraud from irregularity. Internal fraud is one of the major challenges facing organisations. It can undermine an organisation's development capabilities, distort its corporate governance system and, most importantly, prevent the company's strategic objectives from being achieved. The anti-fraud policy is set out as a set of measures and controls aimed at preventing and detecting fraudulent conduct that could cause any kind of damage to the organisation, whether financial or reputational.<\/p>\n
The objective of this policy is to promote a culture that deters any type of fraudulent activity that could take place within the organisation, to enable its prevention and detection, and to develop procedures that facilitate the investigation of fraud and related offences, ensuring that such cases are addressed appropriately and in a timely manner. All members of staff are expected to embrace this commitment. Fraud can be classified along three main lines:<\/p>\n
In turn, each of these can be divided into two categories:<\/p>\n
This policy must be communicated together with the Code of Ethics and the other policies making up the Compliance System.<\/p>\n
FRAUD<\/strong>\u00a0Fraud can be defined as deceiving a third party, abuse of trust, simulation, etc. The term fraud refers to an intentional act by management, staff, or third parties, that results in a misrepresentation of the financial statements.\u00a0IRREGULARITY<\/strong>\u00a0An irregularity is a breach of national or EU rules that has potential adverse effects on their financial interests, but which may be due to mere errors, whether by the beneficiaries of the funds or by the authorities responsible for payments. However, if the irregularity is committed deliberately, then it constitutes fraud.\u00a0ACTIVE CORRUPTION<\/strong>\u00a0Anyone who promises, offers or gives an undue advantage in exchange for another person failing to fulfil their business obligations.\u00a0PASSIVE CORRUPTION\u00a0<\/strong>Anyone who requests or receives an undue advantage in exchange for failing to fulfil their obligations in the course of a business activity. PRIVATE CORRUPTION Corruption in which no public authority or official is involved.\u00a0PUBLIC CORRUPTION\u00a0<\/strong>Corruption involving a public authority or official acting in the exercise of their duties.\u00a0PROHIBITED CONDUCT\u00a0<\/strong>Any conduct that could amount to an act meeting the elements of corruption, extortion or bribery, including any attempt to have such conduct carried out by any member of Grupo Lacasa. Any gift or hospitality, as well as any promise to grant one, to a public authority or official is prohibited. Any conduct carried out with the aim of obtaining a favourable ruling in favour of Grupo Lacasa from a public official or authority. Making transfers to accounts without having obtained the account ownership certificate. Gifts or hospitality intended to obtain any favour, benefit or advantage for Grupo Lacasa or for a third party related to the group are prohibited, in accordance with the Gifts Policy. No employee, executive or member of Grupo Lacasa's Board of Directors may benefit, in purchases made from suppliers, from discounts or advantageous terms exceeding the general terms that apply to the supplier's customers generally.<\/p>\n Following a risk analysis of the entity's processes, a set of controls will be assessed with the aim of facilitating the detection and prevention of fraud, or mitigating the likelihood of fraudulent conduct occurring. Anti-fraud controls alert us to possible fraud and enable an investigation to be initiated. An anti-fraud control can therefore be defined as any action, protocol or verification carried out in order to detect irregular or anomalous conduct. Some examples of anti-fraud controls are given below:<\/p>\n Anyone who becomes aware of any of the conduct described in this policy shall be obliged to report it through the Whistleblowing Channel implemented within the organisation, which can be accessed at https:\/\/grupo.lacasa.es\/canal-denuncias\/<\/p>\n Data processing arising from the application of this policy will be strictly limited to what is necessary to ensure compliance with it and, in all cases, will be based on compliance with a legal obligation and on the performance of a task carried out in the public interest, guaranteeing the confidentiality of the whistleblower's data by keeping it anonymous and not disclosing it to third parties, unless their identification constitutes a necessary and proportionate obligation imposed by EU or national law in the context of an investigation carried out by national authorities or within judicial proceedings, in which case it must be disclosed to the competent authorities in the matter. In all cases, the purpose will be the management and processing of the corresponding reports received through the Whistleblowing Channel, and the data will not be used for any other or incompatible purposes. The data will be disclosed to a third-party provider which, acting as data processor, will guarantee the appropriate handling of the reports received, as well as to the competent public authority that requests it from us. The data will be kept for a maximum period of 3 months from the date it is entered into the channel, after which it will be deleted from the channel, but it may remain blocked where necessary to demonstrate the operation of the crime prevention model, or where it may be required by the competent authority to initiate the corresponding investigation into the facts. For more information about the processing of your data or how to exercise your rights, please refer to our Privacy Policy.<\/p>\n The Board of Directors will implement this policy, which will be reviewed periodically or whenever a change occurs that so requires.<\/p>\n","protected":false},"excerpt":{"rendered":" INTRODUCTION The term \"fraud\" is used to describe a wide range of unethical behaviours, such as theft, corruption, embezzlement, bribery, forgery, misrepresentation, collusion, money laundering and the concealment of facts. It frequently involves the use of deception in order to obtain personal gain for a person linked to a public body or for a third […]<\/p>\n","protected":false},"author":1,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_acf_changed":false,"footnotes":""},"class_list":["post-92","page","type-page","status-publish","hentry"],"acf":[],"yoast_head":"\nCONTROLS<\/strong><\/h2>\n
\n
DUTY TO REPORT<\/strong><\/h2>\n
DATA PROTECTION<\/strong><\/h2>\n
APPROVAL<\/h2>\n