Counter Fraud Policy

Version 2.0. Effective 31 July 2026. Next review 31 July 2027.

1. Purpose and scope

Auren Institute has no tolerance for fraud, whether committed against us, by us, or through us. This policy sets out what counts as fraud, how to report it, and what we do about it.

Auren Institute is registered in Malta at 92, No. 1, St Edward Street, Qormi QRM 2136, Malta, registration P1421, VAT MT20967027. We operate in Malta and the United Kingdom, so this policy addresses the law of both.

2. The law we work to

• United Kingdom: Fraud Act 2006. Section 2 fraud by false representation, section 3 fraud by failing to disclose information, and section 4 fraud by abuse of position.
• United Kingdom: Criminal Finances Act 2017, sections 45 and 46, the corporate offences of failing to prevent the facilitation of tax evasion. The only defence is having reasonable prevention procedures.
• United Kingdom: Theft Act 1968 and Proceeds of Crime Act 2002 where the proceeds of fraud are handled.
• Malta: Criminal Code, Chapter 9 of the Laws of Malta, in particular the provisions on fraud and misappropriation.

3. What counts as fraud here

Fraud is dishonesty for gain. In our business the realistic forms are these.

• Falsifying a learner record, an assessment result, an attendance record or a certificate.
• Claiming completion of training that did not take place, particularly where a funding claim depends on it.
• Submitting or approving an inflated or fictitious invoice or expense claim.
• Manipulating affiliate or introducer attribution to earn commission not properly due.
• Misrepresenting our accreditation status, or a learner qualification, to a buyer or a regulator.
• Facilitating a client evading tax, including through the way an engagement is invoiced or described.

4. Certification fraud, our highest exposure

We issue certificates that people rely on. A certificate that is not earned is a fraud on the learner, on their employer and on the accreditation body.

Certificates are issued only on genuine completion of the stated requirements. No one may issue, backdate or amend a certificate outside the normal process. Assessment records supporting every certificate are retained and are auditable by the relevant accreditation body.

5. Prevention

• Separation of duties: the person who approves an invoice is not the person who raises it.
• No cash. All payments are traceable through the banking system or our payment provider.
• Certificates issue from the platform record, not by hand.
• Affiliate commission is paid only after the refund period has passed and attribution has been checked.
• Access to learner records and financial systems is limited to those who need it.

6. Reporting

Report any suspicion to the Managing Director at info@aureninstitute.com. If the concern involves the Managing Director, report it to our external accountants, whose details are available on request.

Concerns may be raised in confidence and, where you prefer, anonymously. We protect anyone who raises a concern in good faith, and retaliation against them is treated as a disciplinary matter in its own right. This protection applies whether or not the concern is upheld.

7. Response

On a credible report we secure the relevant records first, then investigate proportionately. Where fraud is established we will recover losses, take disciplinary or contractual action, and report to the police or other authorities where appropriate. We will notify an accreditation body where a certificate or assessment is affected. Records of any investigation are kept for six years.

Ownership and review

This policy is owned by the Managing Director of Auren Institute and applies to all directors, employees, contractors, associate trainers and anyone acting for Auren Institute.

It is reviewed annually, and sooner if the law changes, if an incident occurs, or if our operations change materially. The version and effective date are shown at the top of this page.

Questions about this policy, and any report made under it, go to info@aureninstitute.com, marked for the attention of the Managing Director.