Anti-Corruption Policy

Last updated 25/01/2022

1. Purpose and Context
The purpose of Crystal Clear Translation’s (CCT’s) anti-corruption policy is to minimise corrupt or fraudulent acts through a series of measures, including clear policies and processes, regular internal and external audits, and training for all staff.

2. Principles
CCT is dedicated to the investigation of any and all suspected acts of fraud, misappropriation or other similar corrupt actions. Detecting fraud and corruption is the responsibility of all staff, and any incident or potential incident must be reported
immediately, as per company policy.

3. Scope
CCT is committed to maintaining a trusted and respectable reputation amongst its clients, partners, and beneficiaries. All CCT employees and service providers are obligated to maintain company integrity in all their endeavours and must avoid circumstances that may compromise their decisions or actions. All employees must ensure that the ethical business practices and interests of CCT are observed at all times.
It is a major violation of CCT’s policies for employees or service providers to knowingly conceal, falsify or misrepresent a material fact relating to any transaction or service.
Misrepresentation may include (but is not limited to): signing for receipt of goods or services not yet received or completed, or altering any document to disguise or change the outcome, including the back-dating of official documents.
Any employees proven to have committed such violations will face disciplinary action, resulting in dismissal from employment with CTT and possible legal action. For service providers, proven violations will result in the immediate termination of their contract and the cessation of all business dealings with CCT.

4. Definition and Terms
‘Anti-corruption’ relates to the measures taken to eradicate or prevent dishonest or fraudulent conduct.
Both corruption and fraud amount to abuse and theft. Acts of fraud and corruption include, but are not restricted to:
• Falsifying time sheets or payroll records
• Falsifying travel and entertainment expenses
• Creation of false invoices, including the back-dating of documents
• Misappropriation of CCT’s equipment, resources and even data
• Misstatement of income
• Misstatement of assets
• Understatement of liabilities
• Paying bribes (defined as payment to another person to induce a certain action from them).
• Receiving and accepting money or gifts in exchange for an unsanctioned service
• Obtaining CCT income or assets by deception
• Claiming to provide services to beneficiaries that do not exist, and other types of identify fraud

5. Policy Implementation
CTT will undertake the following steps to prevent and discourage corrupt and fraudulent activities:
• Set out clear policiy on the expected conduct of company staff, such as the AntiBribery and Safeguarding policies communicated as part of the employee induction period, with current staff notified of any changes to such policies.
• Record and investigate all incidents (suspected and confirmed) of fraud, in line with government ESF-Anti Fraud guidance.
• Report incidents of fraud to the police and to the Charity Commission.
• Implement robust anti-fraud and corruption controls and inform staff of the procedures and measures in place.
• Ensure that records of all income and expenditure are kept securely and that receipts, invoices, and supporting documents are legitimate and up to date.
• Check that financial controls are not overridden, by-passed, or ignored.
• Restrict and closely monitor access to sensitive information, especially that of a financial nature.
• Implement internal audit function reviewing processes and procedures on a risk basis.
• Establish clearly defined roles for staff that includes the segregation of duties

CCT has a zero-tolerance approach to fraud and corruption and will apply robust sanctions to combat activity related to these offences, including disciplinary action and
reporting suspected criminal activity to the police.

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