Fraud Policy

Contents

Version Control

2. About this policy

3. Details

1. Version Control

Date Version Updates Name

September 2019 V1.0 Update of last review date and next review date (previously January 2019/January 2020)

January 2020 V1.1 Redated for January 2020

September 2021 V1.2 Redated for September 2021

September 2022 V1.3 Redated for October 2022

March 2023 V1. Redated for March 2023

March 2024 V1.4 Redated for January 2024

Annual review

Next Review Date: March 2025

Director: Abdulaziz Alnaim

Responsible Officer: Stefan Dawidowski

1. Introduction

Mayar Capital Ltd., in each area of its business, strives to protect its customers and the firm from damages incurred by fraud. When committed, fraud has devastating effects on the lives of individuals and business. As such, Mayar Capital Ltd. is committed to implementing stringent anti-fraud controls to prevent instances of fraud occurring, both from internal and external perpetrators.

This policy outlines Mayar Capital Ltd.’s approach to preventing the firm or its customers being targets of fraud. In developing this policy, the firm considered its legislative and regulatory obligations relating to fraud, as well as trusted industry best practice to prevent it. the firm took into account the Fraud Act 2006, the Senior Management Arrangements, Systems and Controls (SYSC) sourcebook from the Financial Conduct Authority (FCA) Handbook and guidance from the FCA Handbook.

Mayar Capital Ltd. recognises that it has a duty to prevent any of its customers falling victim to fraud through the firm’s services. Subsequently, Mayar Capital Ltd. pledges to allocate sufficient resources into the firm’s internal controls, monitoring system, human resources and staff training to prevent financial crime.

1.1 Scope

This policy applied to the following parties:

• Full-time employees of Mayar Capital Ltd..

• Part-time employees of Mayar Capital Ltd..

• Temporary contractors of Mayar Capital Ltd..

• Individuals on working experiencing or interning at Mayar Capital Ltd..

• Agents of Mayar Capital Ltd..

• All subsidiaries or branches of Mayar Capital Ltd. operating in the UK, another European Economic Area (“EEA”) state, or any other third country.

1.2 Objectives

The objectives of the policy are to:

• Outline the firm’s approach to preventing fraud, both from external and internal perpetrators.

• Emphasis the firm’s commitment to allocating sufficient resources to preventing fraud.

• Explaining how the firm meets its anti-fraud requirements specified by the regulatory bodies.

• Clearly outline the responsibilities of senior management of Mayar Capital Ltd.’s senior management, responsible officer for fraud and other key individuals in relation to the firm’s anti-fraud strategy.

• Explain the most up-to-date fraud risks that Mayar Capital Ltd. is vulnerable to and how the firm intends to counteract these risks.

• Elaborate how the firm will investigate and rectify instances of fraud when they occur.

• Confirm that Mayar Capital Ltd. will take steps to monitor compliance with this policy throughout the firm.

2. What is Fraud?

Mayar Capital Ltd. takes the view that fraud, as defined by Action Fraud, is: “when trickery is used to gain a dishonest advantage, which is often financial, over another person”.

Criminals use many intricate techniques to defraud individuals or businesses. The techniques that criminals use are constantly evolving and becoming increasingly complex, which presents a big challenge for firms attempting to prevent fraud.

There are many different types of fraud, including:

• Individual fraud – fraud committed by an individual (e.g. investment fraud).

• Corporate fraud – fraud committed by a corporation (e.g. intellectual property fraud).

• Charity and non-profit fraud (e.g. internal fraud).

• Market Abuse (e.g. market manipulation).

3. Statement of Zero Tolerance of Fraud

Mayar Capital Ltd. does not tolerate fraud in any form. The scope of the firm’s zero-tolerance approach encapsulates all individuals listed in section 1.1 of this policy, including management and employees of the firm’s branches and subsidiaries.

Under this policy, Mayar Capital Ltd. representatives are prohibited from engaging in any behaviour, or enabling others to engage in behaviour, that could result in the firm or its customers being defrauded. The firm’s employees entrusted with high responsibility positions, especially those with access to customer information, must at all times act with the highest integrity and not take any fraudulent act which may damage the livelihoods of customers or bring the firm into disrepute. Representatives should at all time abide by the firm’s anti-fraud procedures and take all steps to prevent fraud where permissible that are in their line of duty.

In the eyes of Mayar Capital Ltd., fraudulent behaviour through wilful intent to defraud or negligence in preventing fraud is unacceptable and the individual(s) responsible would be subject to strict disciplinary measures.

4. Responsibilities or Senior Management & Employees

Mayar Capital Ltd. clearly defines the roles and responsibilities of all individuals with oversight of the firm’s anti-fraud strategy and responsibility for the firm’s compliance with all anti-fraud requirements.

4.1 Responsible Officer

Mayar Capital Ltd. has appointed Stefan Dawidowski as the Responsible Officer for implementing, maintaining and monitoring compliance with this policy. Stefan Dawidowski assumed this responsibility of 1st August 2021 and is judged to be adequately skilled to hold the role by the firm’s senior management. The individual is responsible for:

• Implement procedures and processes to prevent fraud from occurring.

• Cooperating and liaising with the law enforcement authorities with regards to fraud investigations involving the firm.

• Maintaining the fraud policy and updating it in line with legislative, regulatory and best practice advancement.

• Maintaining a fraud risk register and continually assessing the fraud risks for which the firm is vulnerable.

• Ensuring that all employees are provided with appropriate levels of anti-fraud training.

• Monitor compliance with the policy throughout the firm.

• Making external reports to the Police or law enforcement authorities regarding instances of fraud at the firm.

4.2 Senior Management

The senior management of Mayar Capital Ltd. fully endorses the firm’s fraud policy. As recommended in Part 2 of the FCA’s financial crime guide for firms, the firm’s senior management will be proactive in taking responsibility for the firm’s fraud prevention strategy. The senior management is responsible for:

• Identifying and assessing the fraud risks to which the firm is vulnerable.

• Monitoring the adequacy of existing fraud prevention controls within the firm.

• Allocating sufficient resources towards the firm’s fraud prevention strategy so the firm complies with all current requirements.

• Ensure that the firm’s Directors meet their statutory responsibilities towards fraud, as per the Companies Act 2006.

• Being involved in the creation of anti-fraud policies and procedures.

4.3 Employees

All Mayar Capital Ltd. employees are required to follow this policy and all anti-fraud procedures. Employees are responsible for:

• Attend regular training on anti-fraud organised by the firm.

• Abide by all policies and procedures relating to fraud enforced by the firm.

• Report any suspicions of tax evasion occurring within the firm to the Responsible Officer for fraud.

5. UK Legislation

Mayar Capital Ltd. is fully aware of the UK’s legislative framework relating to fraud. Mayar Capital Ltd. also provided regular training to our employees, agents, and subsidiaries to ensure they have sufficient knowledge of the UK’s legislative framework.

Mayar Capital Ltd. will adhere to the following legislation, regulation and guidance:

• Fraud Act 2006.

• FCA Financial Crime: A Guide for Firms

5.1 Offences

The above legislation outlines the UK’s fraud offences, which Mayar Capital Ltd. is committed to preventing. The key offences under the applicable legislation are as follows:

• Fraud by False Representation (Subject to maximum 10-year jail term and/or fine)

o It is an offence to dishonestly make a false representation or intend to make a false representation to make a gain for oneself or cause a loss to another or expose another to a risk of loss.

• Fraud by Failing to Disclose Information (Subject to a maximum 10-year jail term and/or a fine)

o It is an offence to dishonestly fail to disclose to another person information which he/she is under a legal duty to disclose and intend, by failing to disclose information, to make a gain for oneself or another or to cause loss to another or expose another to a risk of loss.

• Fraud by Abuse of Position (Subject to maximum 10-year jail term and/or fine)

o It is an offence to dishonestly abuse a position where one is expected to safeguard the financial interests of another person and to intend, by means of abusing the position, to make a gain for oneself or another, or to cause loss to another or expose another to the risk of loss.

6. Anti-Fraud Bodies

Mayar Capital Ltd. pledges to cooperate, where necessary, with all entities in the UK that have been invested with powers by the UK government to investigate and prevent fraud. Mayar Capital Ltd. will also keep the relevant bodies appropriately informed of any major instances of fraud that have been perpetrated against the firm.

6.1 National Crime Agency

The National Crime Agency (NCA) is a national law enforcement agency that helps to coordinate the fight against fraud in the UK.

The NCA has a wide remit involving tackling serious and organised crime, strengthening the UK’s borders, fighting fraud and cybercrime, and protecting children and young people from sexual abuse and exploitation.

The NCA is responsible for strategic development and threat analysis relating to fraud, a role previously allocated to the National Fraud Authority, which closed on 31 March 2014.

6.2 Serious Fraud Office

The Serious Fraud Office (SFO) is an independent government department, operating under the superintendence of the Attorney General. Its purpose is to protect society by investigating and, if appropriate, prosecuting those who commit serious or complex fraud, bribery and corruption and pursuing them and others for the proceeds of their crime.

Once a case has been referred to the SFO, it goes through several key stages. These are:

• Intelligence: receiving raw information, record, analyse, develop and evaluate.

• Assessment: assessing referrals, measure against any existing relevant intelligence, assess against acceptance criteria.

• Case team: once accepted, the case is allocated to a specialist team (including police) led by a case manager.

• Investigate and prosecute: following an investigation, the team assesses the need for prosecution.

• Civil recovery: additional means of dealing with certain cases where SFO can prosecute, using its asset recovery powers.

• Trial: should the SFO decide to prosecute, this will go to a court trial.

• Wrap up: review following court’s decision to reflect on any lessons learned that could improve future investigations.

7. Firm Requirements

Mayar Capital Ltd. is aware of the regulatory obligations placed upon it to prevent fraud. The firm implements numerous systems and controls to prevent fraud from both internal and external perpetrators and manages and routinely updates these systems in line with pertinent fraud risks.

7.1 Pre-employment Screening

During Mayar Capital Ltd.’s recruitment process, the firm will undertake pre-employment screening of potential candidates. In doing this, Mayar Capital Ltd. will affirm each candidate’s qualifications, suitability, and experience for the specified role. During the screening process, the firm will obtain and retrieve information that will help us assess whether a potential candidate is likely to engage in fraud. The screening process will help reduce the likelihood that an individual with a history of fraud and unethical behaviour will be offered a role within the firm.

The firm’s pre-employment screening techniques include:

• Confirming the education and professional qualifications of the candidate.

• Verification of the candidate’s employment background.

• Criminal history searches.

• Credit checks.

Only once Mayar Capital Ltd. is satisfied that a potential candidate does not pose any inherent fraud risks will he/she be offered a position in the firm.

7.2 Due Diligence

Due diligence is an important method for determining whether a particular customer poses any interest fraud risks. In conducting due diligence procedures, Mayar Capital Ltd. will look to satisfying itself that:

• Customers are who they say they are.

• It knows whether the customer is acting on behalf of another.

• There is no legal barrier to prevent providing the customer with the product or service requested.

• It can assist law enforcement by being able to provide information on customers or their activities on request.

Mayar Capital Ltd. will conduct the appropriate level of due diligence on a customer in accordance with the risk that the customer has been identified as possessing to the firm.

7.3 Record Keeping

Mayar Capital Ltd. is required to maintain adequate records as part of our anti-fraud procedures. The records that the firm is required to maintain include:

• The client’s identity.

• The supporting evidence of verification of identity.

• The firm’s business relationship with them.

• Details of any occasional transactions.

• Details of monitoring of the relationship.

Mayar Capital Ltd. will retain these records for a minimum of five years after the termination of the business relationship with each customer, except for situations where legal obligations placed upon Mayar Capital Ltd. require otherwise.

8. Fraud Risk Register

Mayar Capital Ltd. is required to establish and maintain a fraud risk register to identify any fraud risks the firm is facing. Once fraud risks have been identified, the firm will implement measures to mitigate and control these risks. The firm’s Responsible Officer is invested with the responsibility to establish and maintain these registers.

The key fraud risks Mayar Capital Ltd. is subject to, in accordance with the firm’s last risk assessment, are:

• Client Identification

• Cyber Security

• Payments

9. Fraud Investigations

Where there is a reasonable suspicion that fraud against the firm has taken place, Mayar Capital Ltd. is entitled to investigate the matter thoroughly using recognised and legitimate investigative techniques.

The firm will abide by the following principles when conducting our investigations:

• All investigations will be carried out objectively and confidentially, and independently of the line management for the area in which the fraud has occurred or is suspected.

• In the normal course of events, the Firm would look to hand over the investigation to the police or other authorities as soon as practical.

• In certain cases, third-party investigators may be employed in order to gather sufficient evidence to hand the case over to the proper authorities.

• The rights of individuals will be respected at all times.

• Where members of staff are involved in a fraud against the Firm, whether actual or attempted, they will be subject to the Firm's disciplinary procedures, which may result in dismissal from the Firm.

• The Firm will seek to prosecute anyone who commits fraud and will seek to recover its assets through legal means.

• The code of conduct adhered to by all investigators will include considerations of all related legislation (e.g. Police and Criminal Evidence Act, Data Protection Act, Public Interest Disclosure Act, European Convention on Human Rights etc in the UK and relevant local legislation overseas) and Firm HR policies.

• Lessons learned will be shared across the Firm as soon as possible after an investigation is concluded.

• The firm is aware that the following requirement of the SUP handbook is likely to apply.

SUP 15.3.17 R 07/03/2016

A firm must notify the FCA immediately if one of the following events arises and the event is significant:

(1) it becomes aware that an employee may have committed a fraud against one of its customers; or

(2) it becomes aware that a person, whether or not employed by it, may have committed a fraud against it; or

(3) it considers that any person, whether or not employed by it, is acting with intent to commit a fraud against it; or

(4) it identifies irregularities in its accounting or other records, whether or not there is evidence of fraud; or

(5) it suspects that one of its employees may be guilty of serious misconduct concerning his honesty or integrity and which is connected with the firm's regulated activities or ancillary activities.

10. External Reporting

All Mayar Capital Ltd. employees have a responsibility to report any instances or suspicions of fraud to the firm’s Responsible Officer for fraud.

Please report any suspicions to the Compliance Officer.

11. Training

Mayar Capital Ltd. employees and agents are provided with anti-fraud training upon their induction to the firm. Employees and agents are also provided with annual training/refresher training by the firm.

The firm’s anti-fraud training covers the following areas:

• The laws and offences of fraud.

• How to identify fraud.

• Reporting fraud internally

• Specific fraud risks to the firm.

• The controls and procedures the firms have in place.

Employee training records are to be retained and evidenced on each individual employee’s Continual Professional Development (“CPD”) Log alongside the firms central training log. Records are required to be retained for five years.