1. Purpose
This policy sets out Murzo Group's approach to preventing fraud and economic crime across group activity, including conduct by workers, contractors, agents, distributors, introducers, suppliers, advisers, and other associated persons.
The purpose is to protect Murzo Group, customers, suppliers, investors, authorities, insurers, and the public from dishonesty, deception, false statements, false accounting, abuse of position, cyber-enabled fraud, and any fraud carried out for the benefit of Murzo Group or another person.
2. Scope
This policy applies to all Murzo Group businesses and activities, including food, farming, design, fashion, security, property, high-value goods, cultural objects, international trade, online platforms, public communications, procurement, recruitment, finance, customs, tax, grants, tenders, and overseas operations.
3. Policy Position
Murzo Group has no tolerance for fraud, attempted fraud, dishonesty, deliberate misstatement, concealment, forged evidence, false claims, or improper advantage.
Fraud prevention procedures must be proportionate to the activity. Controls should focus on real risk, clear approval routes, reliable evidence, transparent dealings, and fast escalation where concerns arise.
4. Fraud Risk Areas
- False invoices, duplicate invoices, payment diversion, bank mandate fraud, payroll fraud, and expenses abuse
- False sales claims, fake orders, refund abuse, chargeback abuse, and customer deception
- False accounting, misleading management information, hidden liabilities, and inaccurate stock, asset, or valuation information
- Fraudulent customs values, origins, product descriptions, certificates, licences, VAT treatment, grants, or authority filings
- Misleading fundraising, investment, property, asset, sustainability, food, provenance, safety, security, or performance claims
- Bid rigging, collusion, tender manipulation, undisclosed conflicts, and procurement fraud
- Cyber-enabled fraud, phishing, impersonation, business email compromise, and misuse of systems or credentials
5. Prevention Controls
Murzo Group will use proportionate controls to reduce fraud risk without creating unnecessary administration. Controls should match the value, sensitivity, complexity, jurisdiction, and counterparty risk of the activity.
- Clear approval levels for contracts, payments, refunds, write-offs, supplier onboarding, commission payments, and high-risk transactions
- Independent verification of bank changes, unusual payment requests, urgent transfers, and new supplier details
- Due diligence on higher-risk customers, suppliers, agents, distributors, introducers, property counterparties, and high-value transactions
- Separation of duties where practical for requesting, approving, paying, receiving, and reconciling material transactions
- Controlled use of Murzo Group branding, signatures, accounts, websites, certificates, and official communications
- Escalation routes for suspected fraud, pressure, intimidation, conflicts, bribery, tax evasion, money laundering, sanctions, or cyber compromise
6. Associated Persons
Agents, distributors, consultants, contractors, introducers, local partners, and other associated persons must not commit fraud or make dishonest statements for Murzo Group's benefit.
Where Murzo Group appoints a person to act on its behalf, authority limits, payment terms, anti-fraud expectations, and termination rights should be clear for the risk level involved.
7. Reporting and Investigation
Suspected fraud must be escalated promptly. Murzo Group may suspend payments, pause activity, preserve relevant evidence, restrict access, notify banks, notify insurers, seek legal advice, or report to authorities where appropriate.
Investigations must be fair, discreet, proportionate, and controlled. Evidence should be limited to what is needed for the concern, legal advice, insurance, authority engagement, disciplinary action, or recovery.
8. Prohibited Conduct
- Creating, approving, submitting, or relying on false documents
- Misstating product, origin, tax, customs, safety, provenance, investment, or financial information
- Concealing fraud concerns from management, auditors, insurers, banks, regulators, or authorities where disclosure is required
- Using Murzo Group systems, accounts, money, assets, or reputation for personal gain or deception
- Retaliating against any person who raises a genuine fraud or economic crime concern
9. Review
This policy will be reviewed when Murzo Group changes business model, appoints higher-risk associated persons, enters new markets, handles higher-value goods, or faces new fraud or economic crime risks.
