ANTI FRAUD AND MALPRATICE POLICY

This policy applies to any fraud, or suspected fraud, involving employees as well as shareholders consultants, Partners, vendors, contractors, outside agencies doing business with employees of such agencies, and/or any other parties with a business relationship with GABRICH GLOBAL SERVICES LIMITED.

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

Management is responsible for the detection and prevention of fraud, misappropriations, and other inappropriate conduct. Fraud is defined as the intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her injury. Each member of the management team will be familiar with the types of improprieties which might occur within his or her area of responsibility, and be alert for any indication of irregularity.

Any fraud that is detected or suspected must be reported immediately to ECONOMIC AND FINANCIAL CRIMES COMMISSION (EFCC),6A Olumeni Street, Old GRA, Port Harcourt, Rivers State, in support with any nearest Police State, who coordinates all investigations with the Legal Department and other affected areas, both internal and external.

ACTIONS CONSTITUTING FRAUD
The terms defalcation, misappropriation and other fiscal wrongdoings refer to, but are not limited to:

• Any dishonest o fraudulent act.

• Forgery or alteration of any document or accounting belonging to the Company.

• Misappropriation of funds, securities, supplies or other assets.

• Impropriety in the handling or reporting of money or financial transactions.

• 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, contractors, sub 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 inappropriate conduct.