This Anti-Fraud Policy aims to develop a culture across the Exchange and its partners that raises the awareness of the risks and consequences of fraud. It provides a framework for promoting the Exchange’s policies and measures to prevent and detect fraud.

This Fraud Policy statement covers fraud, whether caused intentionally or through negligence, and losses on the Exchange and applies to Members, users, Credebt Exchange® employees and third-party providers.

Credebt Exchange® in common with other private and financial based organisations, operates a zero tolerance policy in relation to fraud and requires all Members, users, Credebt Exchange® employees and third-party providers, at all times, to act honestly and with integrity, and to safeguard all resources that have been entrusted to the Exchange. The Credebt Exchange® Fraud Policy is to notify the An Garda Síochána, the Police, local Police, or other appropriate authorities, when a fraud is suspected or realised.

Fraud is said to have occured when: an entity acts in a dishonest manner for gain; or causing loss; or exposure to the risk of loss, by: false representation; by failure to disclose information; or by abuse of position. The Exchange Director is responsible for establishing and maintaining internal controls that support the Credebt Exchange®’s fraud and anti-money laundering policies, aims and objectives.

These controls are designed to identify potential risks and to defend against them. These controls are based on an on-going process that identifies risks, evaluates the nature and extent of those risks and to manage them effectively. Managing fraud risk will be seen in the context of the management of this wider range of risks. The Exchange will regularly review its policies in Credebt Exchange® Documents, legislation and related guidance to ensure that appropriate measures for combating fraud are maintained.

The Exchange is required to report immediately to the Exchange Director suspected or proven frauds, and attempted fraud. The details reported will be included in the report to the included An Garda Síochána, the Police, local Police, or other appropriate authorities.

Credebt Exchange®, is fully committed to supporting national and international policies to combat money laundering and the funding of terrorist and criminal activities. The Company takes all necessary steps to ensure compliance with the provisions of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (the “Act”). Our policies and procedures also take account of the relevant technical changes introduced by the Criminal Justice Act 2013its subsidiaries and the Exchange are firmly committed to participating in international efforts to combat money laundering and the funding of terrorist and criminal activities.

Credebt Exchange® has its headquarters in Dublin and Ireland is a member country of the Financial Action Task Force (FATF) and the European Union (EU) and has enacted laws and guidelines to implement the anti-money laundering policies of both FATF & the EU.

Credebt Exchange® implements an AML program and principles in all the jurisdictions in which Credebt Exchange® operates.

For questions about this Fraud Policy, the practices of the Exchange or any other dealings with Credebt Exchange®, contact us at:

Credebt Exchange®
60 Lower Baggot Street
Dublin 2
Ireland
legal@credebtexchange.com