Anti-Fraud Policy

WHY WE ARE DOING IT - BACKGROUND

The corporate anti-fraud policy is established to facilitate the development of controls that will aim at detection and prevention of fraud against OÜ GetEx Technologies (hereinafter – “GetEx” or “the Company”.). It is the intent of GetEx to promote consistent organizational behavior by providing guidelines and assigning responsibility for the development of controls and conduct of anti-fraud investigations.

GetEx fosters honesty and integrity in its entire staff. Director(s) and staff are expected to lead by example in adhering to policies, procedures and practices. Equally, members of the public, service users and external organizations (such as suppliers and contractors) are expected to act with integrity and without intent to commit fraud against GetEx.

WHEN WE ARE DOING - SCOPE OF POLICY

This policy applies to any irregularity, or suspected irregularity, involving employees as well as shareholders, clients, users, consultants, vendors, contractors, outside agencies doing business with employees of such agencies, and/or any other parties with a business relationship with GetEx.

Any investigative activity required will be conducted without regard to the suspected wrongdoer’s length of service, position/title, or relationship to the Company.

WHAT WE ARE DOING - POLICY

Director of GetEx (Sole Member of Management Board of the Company) is responsible for the detection and prevention of fraud, misappropriations, and other irregularities. Fraud is defined as the intentional, false representation or concealment of a material fact for inducing another to act upon it to his or her injury. Each member of GetEx Management team will be familiar with the types of improprieties that might occur within his or her area of responsibility, and be alert for any indication of irregularity.

Any irregularity that is detected or suspected must be reported immediately to the Director of GetEx, who coordinates all investigations with the Legal Department and other affected areas, both internal and external.

WHAT IS FRAUD

The terms defalcation, misappropriation, and other fiscal irregularities refer to, but are not limited to:

  • Any dishonest or fraudulent act;
  • Misappropriation of funds or other assets;
  • Impropriety in the handling or reporting of money or financial transactions;
  • Impropriety in the handling or reporting of cryptocurrencies or transaction involving cryptocurrencies;
  • Profiteering as a result of insider knowledge of company activities;
  • Disclosing confidential and proprietary information to outside parties;
  • Disclosing to other persons securities activities engaged in or contemplated by the company;
  • Accepting or seeking anything of material value from clients, users, contractors, vendors, or persons providing services/materials to the Company. Exception: Gifts less than $50 in value;
  • Destruction, removal, or inappropriate use of records, furniture, fixtures, and equipment; and/or
  • Any similar or related irregularity.

INCONSITENCIES

Irregularities concerning an employee’s moral, ethical, or behavioral conduct should be resolved by GetEx Management Board and Human Resources.

If there is any question as to whether an action constitutes fraud, contact the Director of GetEx for guidance at: contact@getex.com

DIRECTOR RESPONSIBILITIES

Overall responsibility for managing the risk of fraud has been delegated to Management Board of GetEx.

Their responsibilities include:

  • Undertaking a regular review of the fraud risks associated with each of the key organizational objectives;
  • Establishing an effective anti-fraud response plan, in proportion to the level of fraud risk identified;
  • The design of an effective control environment to prevent fraud;
  • Establishing appropriate mechanisms for:
    • reporting fraud risk issues;
    • reporting significant incidents of fraud or attempted fraud to the Shareholders of the Company;
  • Liaising with GetEx’s appointed Auditors;
  • Making sure that all staff are aware of GetEx Anti-Fraud Policy and know what their responsibilities are in relation to combating fraud;
  • Ensuring that appropriate anti-fraud training is made available to Director(s) and staff as required; and
  • Ensuring that appropriate action is taken to minimize the risk of previous frauds occurring in future.

STAFF RESPONSIBILTIES

Every member of staff is responsible for:

  • Acting with propriety in the use of GetEx’s resources and the handling and use of funds whether they are involved with cryptocurrencies, fiat currencies, receipts, payments or dealing with suppliers;
  • Conducting themselves with selflessness, integrity, objectivity, accountability, openness, honesty and leadership;
  • Being alert to the possibility that unusual events or transactions could be indicators of fraud;
  • Alerting their manager when they believe the opportunity for fraud exists e.g. because of poor procedures or lack of effective oversight;
  • Reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events; and
  • Cooperating fully with whoever is conducting internal checks or reviews or fraud investigations.

INVESTIGATION RESPONSIBILITIES

Director of GetEx has the primary responsibility for the investigation of all suspected fraudulent acts as defined in the policy.

If the investigation substantiates that fraudulent activities have occurred, Director of GetEx will issue reports.

Decisions to prosecute or refer the examination results to the appropriate law enforcement and/or regulatory agencies for independent investigation will be made in conjunction with legal counsel and senior management, as will final decisions on disposition of the case.

CONFIDENTIALITY

Director of GetEx treats all information received confidentially. Any employee who suspects dishonest or fraudulent activity shall notify Director immediately, and should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act (see REPORTING PROCEDURE section below).

Investigation results will not be disclosed or discussed with anyone other than those, who have a legitimate need to know. This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the Company from potential civil liability.

AUTHORIZATION FOR INVESTIGATING SUSPECTED FRAUD

Director of GetEx or a person designated by Management Board of the Company to perform an investigation has:

  • Free and unrestricted access to all Company records and premises, whether owned or rented; and
  • The authority to examine, copy, and/or remove all or any portion of the contents of files, desks, cabinets, and other storage facilities on the premises without prior knowledge or consent of any individual who might use or have custody of any such items or facilities when it is within the scope of their investigation.

REPORTING PROCEDURES

Great care must be taken in the investigation of suspected improprieties or irregularities so as to avoid mistaken accusations or alerting suspected individuals that an investigation is under way. An employee who discovers or suspects fraudulent activity shall contact the Director immediately in person, by phone +442036088362 or by email contact@getex.com. The employee or other complainant may remain anonymous. All inquiries concerning the activity under investigation from the suspected individual, his or her attorney or representative, or any other inquirer should be directed to Management Board of GetEx or the Legal Department. No information concerning the status of an investigation will be given out. The proper response to any inquiries is: “I am not at liberty to discuss this matter.” Under no circumstances should any reference be made to “the allegation,” “the crime,” “the fraud,” “the forgery,” “the misappropriation,” or any other specific reference. The reporting individual should be informed of the following:

  • Do not contact the suspected individual in an effort to determine facts or demand restitution.
  • Do not discuss the case, facts, suspicions, or allegations with anyone unless specifically asked to do so by the Legal Department or Management Board of GetEx.

TERMINATION

If an investigation results in a recommendation to terminate relationship with an individual, the recommendation will be reviewed for approval by the designated representatives from Human Resources and the Legal Department and, if necessary, by outside counsel, before any such action is taken. However, Management Board of GetEx has the authority to make the decision to terminate relationship with an employee.

ADMINISTRATION

Management Board of GetEx is responsible for the administration, revision, interpretation, and application of this policy. The policy will be reviewed annually and revised as needed.

APPROVAL

Approved by Member of the Management Board of GetEx

Technologies OÜ A. Gorshkov

Dated: 25.07.2018