Counter Fraud Policy

Auren Institute

January 2026

Auren Institute Counter Fraud Policy

1. Purpose

Auren Institute is committed to maintaining the highest standards of integrity, transparency, and accountability.

This policy establishes a framework to prevent, detect, and respond to fraud and related misconduct across all operations.

2. Scope

This policy applies to:

• Employees, contractors, and consultants
• External partners, suppliers, and service providers
• Any individual or entity acting on behalf of Auren Institute

3. Definition of Fraud

Fraud refers to any intentional act of deception carried out for personal or organisational gain. This includes, but is not limited to:

• Financial misappropriation or theft
• Falsification of records or reports
• Misuse of company assets
• Corruption, bribery, or conflicts of interest
• Misrepresentation of qualifications, services, or outcomes

4. Policy Statement

Auren Institute adopts a zero-tolerance approach to fraud.

Any suspected or confirmed fraudulent activity will be investigated promptly and may result in disciplinary, legal, or contractual action.

5. Roles and Responsibilities

Management

• Establish and maintain effective internal controls
• Promote a culture of ethical conduct
• Ensure proper oversight of financial and operational activities

Employees and Associates

• Act with honesty and integrity at all times
• Report any suspected fraud or irregularities
• Comply with internal controls and procedures

6. Prevention Measures

Auren Institute will implement:

• Segregation of duties in financial processes
• Approval controls for transactions and payments
• Regular reconciliations and financial reviews
• Due diligence on partners and suppliers
• Clear documentation and audit trails

7. Reporting Mechanism

Any suspicion of fraud must be reported immediately to:

• Senior Management or designated compliance contact

Reports can be made confidentially. Auren Institute ensures:

• Protection against retaliation for whistleblowers
• Fair and objective handling of all concerns

8. Investigation Process

• All reports will be assessed and investigated promptly
• Investigations will be conducted objectively and confidentially
• Appropriate corrective and disciplinary actions will be taken

9. Disciplinary and Legal Action

Confirmed cases of fraud may result in:

• Disciplinary action (including termination)
• Recovery of losses where applicable
• Reporting to relevant authorities

10. Monitoring and Review

This policy will be:

• Reviewed periodically to ensure effectiveness
• Updated in line with regulatory and organisational changes

11. Communication and Training

Auren Institute will:

• Communicate this policy to all relevant stakeholders
• Provide awareness and training where necessary

Conclusion

Fraud risk is not only a financial issue. It is a governance and reputational risk.

By embedding strong controls and a culture of accountability, Auren Institute safeguards its operations, partners, and long-term credibility.