ANTI-FRAUD STRATEGY

Fraud or fraud can occur due to weak supervision, deviations from established policies/procedures, and lack of effective disciplinary action and other socio-economic factors. Therefore, the Anti-Fraud Strategy policy must be made so that the fraud control system can be built and function optimally, thoroughly, and refers to the policies that have been set previously. The company has a culture of “Zero Tolerance”, as a form of commitment in implementing Fraud control, it is deemed necessary for the Company to maximize resources effectively and sustainably. The effectiveness of the implementation of Anti-Fraud policy is the responsibility of all the people of Tugu Insurance.

Objectives and Scope

The formulation of the Anti-Fraud Strategy policy aims to:

Improve internal Fraud control systems and guidance on:a. Fraud Prevention
b. Fraud Detection.
c. Fraud investigation, reporting and penalty
d. Monitoring, Evaluation and Follow-up.In realizing Corporate Value 6C (ie Clean, Capable, Creative, Collaborative, Committed, and Customer Focused)
A form of confirmation from the Company that Fraud is an act of crime. Minimizing and preventing fraud by:
a. Increased awareness and fraud risk awareness
b. Implementation of an integrated anti-fraud (Fraud) strategy.
c. Investigation of fraud (Fraud) detected according to competence.
d. Applying appropriate penalty
e. Quality improvement of human resources.In scope, the Anti-Fraud Strategy applies throughout the Tugu Insurance environment, including branch offices throughout Indonesia.

General Provisions in Implementing Anti-Fraud Strategy Policies

The implementation of the Anti-Fraud Strategy policy is part of the implementation of Risk Management in general. The effectiveness of the implementation of the Anti-Fraud Strategy needs to be supported by strengthening from various aspects, including active management oversight, organizational structure, and accountability, as well as control and monitoring. The implementation of the Anti-Fraud Strategy policy includes:

Active management supervision of the Fraud which includes the authorities and responsibilities of management, including the Board of Commissioners and Directors.
Zero tolerance commitment of the Board of Directors in every form of fraud, both internal and external from the company.
Implementation of the Anti Fraud Strategy Policy through 4 (four) pillars.
The implementation of the Anti Fraud Strategy Policy involves each Work Unit with duties and responsibilities according to authority.
The Anti Fraud Commitment is the basis for the preparation of every policy, system and procedure of the Company’s business operations as well as Risk Management, GCG Principles and internal control systems.
Application of the Code as the basic principles of professionalism of the management and workers, which is the basis for the formulation of policies, systems and procedures of the Company’s business operations.
All workers are responsible for implementing Compliance Culture by taking into account values, actions and behaviour in accordance with the Company’s internal policies, external policies/regulators, and the authorities.
Workers are not permitted to place themselves in positions or situations that create a conflict of interest (COI).
Types of acts classified as Fraud: Fraud Financial Statements, Asset Misappropriation, Corruption, Collusion and Nepotism
To improve the danger and risk of fraud, Tugu Insurance provides education and training related to fraud and will be held at least once a year.

Organization of Anti-Fraud Strategy Implementation

In order to actualize the effective prevention of fraud, the company carries out direct and indirect control of fraud. This is done through the application of risk management and the implementation of good governance. Of course, the successful implementation of the Anti-Fraud Strategy Guidelines is influenced by a conducive environment, so that all related parties can play their roles properly.

The implementation of the anti-fraud strategy is the responsibility of the Board of Commissioners, the Board of Directors, and all staff. The Fraud Control Officer (FCO) and Internal Audit act as coordinators in the implementation of the responsibilities of all levels and report to the Directors and Board of Commissioners of Tugu Insurance.

Fraud Control Framework

The management of the Fraud control framework refers to the concept of Three Lines of Defense:

Management & Staff (First Line of Defense)
Management and staff are responsible for implementing and exercising controls to reduce the risk of fraud. Fraud prevention and detection are the main responsibilities of the Company’s management
Risk Management & Compliance (Second Line of Defense)
Responsible for facilitating the implementation of the fraud control framework and the effectiveness of Fraud monitoring. Investigation of fraud must be handled by those trained in this field and appointed to assist in the implementation of the First Line of Defense.
Internal audit (Third Line of Defense)
Work independently to ensure the effectiveness of the Fraud Control Framework Internal Audit provides an overview and guarantee of the efficiency of the fraud control framework.

Implementation of Anti-Fraud Strategy Policy

The implementation of the Anti-Fraud Strategy policy is carried out by the company as part of risk mitigation methods, especially those related to internal control aspects. This strategy structure combines the basic principles of Risk Management (internal control) and Good Governance. Fraud prevention measures are important in order to reduce the potential for large losses that must be felt by the company.

Good Corporate Governance