TAJ CORPORATION

Document: HR Manual PBU

Date: 03-April-2018
Version: 1

INTERNAL CONTROL SYSTEM

FRAUD & CORRUPTION CONTROL (FCC)

INTRODUCTION

This policy and procedure is to initiate internal control system against fraud and corruption.

PREVENTION & DETECTION

Two main things help in prevention and detections of fraud and corruption – culture and controls. Line
Managers and supervisors have to ensure that there are no fraudulent or corrupt activities. Middle
Managers have to check that proper monitoring and controlling is taking place. Business leader has to
check overall system for internal controls in the business. Whistleblowing, internal tip-off, by accident,
change of personnel, segregation of duties, internal audits, security, risk management, reconciliations,
cross verifications and many other methods can be used to detect fraud. Identification and assessment of
risks should be done for prevention and detection of fraud and corruption. Relevant departments have to
perform their role for internal controls system against fraud and corruption. Departments have to visit field
for checking the execution of their system.

INVESTIGATION
If any fraud is detected or reported, its investigation will start on urgent basis with required planning and
confidentiality. Planning will be about response formulation, physical and electronic evidences,
confidentiality of and access to data, interviews, statements from witnesses and suspects, etc. Any
employee can report detected or suspected fraudulent activity directly to Investigation Unit through
hotline number and email. Investigation Unit will plan and conduct investigation of the suspected or
occurred fraudulent activity and substantiate Investigation Report. Investigation Unit will send
Investigation Report to Audit Committee. If required, Audit Committee will present Investigation Report to
Executive Committee. Risk Register can be used during investigation for enlisting all weak areas.
Note: Legal Council will decide in case of need for independent or joint investigation through external legal
entity.

ACTION
Audit Committee will make the decision on action based on Investigation Report and recommendation
from Legal Council. Final action can include recovery, internal disciplinary action, civil response, criminal
prosecution, or any other appropriate action. If case is of sensitive nature, Executive Committee will decide
on the final action. Case Closing Report will be emailed to Executive Committee. Audit Committee will file
Case Closing Report and update relevant log and learning records.

Policy No. Recommended By: Vetted By: COO Approved By: CEO
Taj/HR-PBU/2018/0011 Head of Strategy &
Excellence
Dated: 3-April-2018 Revision: 15-March-2018 Page 2 of 2
*The information presented in this document is intended only for employees of Taj Corporation and may contain confidential or
privileged material, or both. Any review, receipt, dissemination or other use of this information by any unauthorized person is
prohibited.
 TAJ CORPORATION
Document: HR Manual PBU
Date: 03-April-2018
Version: 1

INVESTIGATION UNIT
Investigation Unit will be led dually by senior representative of Audit and Compliance Department and
senior representative of Business. If case is sensitive, leader of Audit and Compliance Department and
Business will be there. Representative of relevant department can also be part of Investigation Unit. Audit
Committee will decide on other members on Investigation Unit as per requirement. Investigation process
will be run by leader of business.

AUDIT COMMITTEE
Audit Committee will be led by leader of Audit and Compliance Department. Key member will be leader of
Business. Other important members will be leaders of Finance and Accounts, Human Resources and Legal
Departments. If there is need of any temporary member, Audit Committee will unanimously choose that
member.

CONFIDENTIALITY AND REPUTATION

All measures should be taken to ensure confidentiality of all sensitive information, especially during
investigation. Reputation of organization and innocent personnel should not be compromised in any way.

Policy No. Recommended By: Vetted By: COO Approved By: CEO
Taj/HR-PBU/2018/0011 Head of Strategy &
Excellence
Dated: 3-April-2018 Revision: 15-March-2018 Page 2 of 2
*The information presented in this document is intended only for employees of Taj Corporation and may contain confidential or
privileged material, or both. Any review, receipt, dissemination or other use of this information by any unauthorized person is
prohibited.