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  1. Dawn has a zero tolerance for fraud both inside and outside of Dawn. All alleged violations must be investigated and may lead to disciplinary proceedings

  2. EVERYONE has the responsibility for fraud prevention and detection. This must be communicated and actively and regularly promoted throughout the organisation to all employees, irrespective of grade, position or length of employees, irrespective of grade, position or length of service.

  3. Every office must display the fraud and ethics hotline poster in clear and full view of all employees.

  4. Management has a responsibility to ensure adequate antifraud measures and controls are present in systems. Therefore, all Managing Directors, Financial Directors and other line managers must:
    a. ensure that an adequate system of internal control exists within their areas of responsibility (company, financial and Dawn Ltd (Pty) Ltd, Policies & Procedures 8 12000 Fraud Policy other areas of responsibility) and that controls operate effectively;
    b. conduct regular risk assessments to identify high risk areas and evaluate the control around these; and
    c. ensure that Dawn's Code of Ethical Conduct are well communicated to all staff within their areas of responsibility.

  5. All staff are equally expected to be vigilant and play an active part in anti-fraud activity.
    a. Therefore, all employees must ensure that they are familiar with:
    i. Dawn's Code of Ethical Conduct;
    ii. Fraud Policy and other related policies; and
    iii. required controls and procedures in their areas of responsibility; and report any suspected fraudulent acts.
    b. Employees are in the best position to recognise any specific risks within their own area of responsibility. All employees also have a duty to ensure that those risks are identified and eliminated or mitigated. Where an employee believes the opportunity for fraud exists, whether because of poor procedures or oversight or other reasons, it MUST be discussed with their line manager, other member of your immediate management chain and/or a member of Internal Audit.

  6. Employees should not attempt to personally conduct investigations or interviews/ interrogations related to any suspected fraudulent act. Great care must be taken in the investigation of suspected fraud or wrongdoing so as to avoid mistaken accusations or alerting suspected individuals that an investigation is under way. An employee who discovers or suspects fraudulent activity should immediately report the matter to the Chief Financial Officer and/ or the Group Risk Officer and/ or the Chief Audit Executive. However, in instances where an employee does not believe that their issues can or should be addressed using the above 8 9 Policy 12000 Fraud Policy reporting procedures, alternatives for reporting are provided within the whistle-blowing mechanism as outlined in Dawn's Code of Ethical Conduct. The employee or other complainant may remain anonymous.

  7. All known cases of fraud must be reported to the Chief Financial Officer and/ or the Group Risk Officer and/ or the Chief Audit Executive. An up to date register must be kept at each site (Confidential) to record ALL fraud and ethical non-compliances.

  8. Dawn is committed to investigating all reported cases of fraud in order that appropriate action can be taken. Any investigative activity required will be conducted without regard to the suspected wrongdoers length of service, position/title, or relationship to Dawn.

  9. The investigation of fraud involving employees should be conducted independently - i.e. outside the control of the line management of the area in which the investigation will take place.

  10. In certain cases, third-party investigators may be employed in order to gather sufficient evidence to hand the case over to the proper authorities.

  11. The rights of individuals will be respected at all times.

  12. Dawn will seek to prosecute anyone who commits fraud and will seek to recover its assets, losses and costs through legal means.

  13. It is the policy of Dawn to report, in consultation of the Legal and Compliance Officer, all known criminal activity to the police for investigation by them.

  14. Any attempt by a 3rd party to offer anything to an employee that might be seen as a bribe should be disclosed in terms of the Conflict of interest policy.