1. Scope and definitions

"EnsoTraffic" strives to conduct business honestly and ethically. The Company recognizes that fraud can have serious consequences, such as damage to reputation, financial loss and legal penalties. That's why "EnsoTraffic" is committed to implementing and maintaining systems that prevent all forms of fraud.

Fraud is defined as intentionally misrepresenting or concealing someone's true identity or material for personal gain.

The Company is committed to the highest anti-fraud standards and encourages consistent behavior within the organization by providing guidelines and assigning responsibility for the development of controls, processes and investigation standards. We are committed to implementing a robust program focused on detecting and preventing fraud and other misconduct involving employees, customers and partners. "EnsoTraffic".

Each team member involved in fraud prevention must be aware of the types of violations and red flags that may arise in his or her area of ​​responsibility, as well as the procedures necessary to investigate and take appropriate action. High ethical standards are the basis of the company's long-term strategy and are embedded in the culture of our organization. Fair practice and a commitment to preventing and combating any fraudulent activity or behavior are key principles in our dealings with customers and partners.

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2. Risk assessment

The Company will use a wide range of methods and tools to detect fraud in a timely manner. This includes analytical procedures and other methods to identify anomalies, as well as the implementation of reporting mechanisms related to suspected fraudulent activity.

Key elements of a fraud detection strategy include exceptional reporting, data analytics, trend analysis and ongoing risk assessment. By following these techniques, we can continually improve internal systems and controls, making it more difficult for potential attackers to succeed.

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3. Responsibilities

3.1. Employees

Employees are required to abide by a code of conduct that prohibits fraudulent practices. They are required to notify their supervisor or company policy officer of any suspected fraud.

All employees have the same responsibility for preventing, detecting and reporting fraud. They must avoid any actions that may violate this policy.

If an employee violates this policy, disciplinary action may be taken, up to and including dismissal for gross violation.

3.2. Management

Management is responsible for ensuring that appropriate procedures are in place to prevent fraud and must ensure that employees are trained in accordance with this policy and its implementation.

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4. Training and communication

The Company will provide training to all employees to ensure they understand this policy and their responsibilities. The policy will be communicated to all new employees as part of their onboarding process, and to all current employees through regular training sessions.

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5. Fraud reporting

Fraud prevention and detection can identify ongoing fraud; however, a company can implement additional strategies to improve its processes and combat new types of fraud. Through continuous analysis and proper reporting, the company continually improves key performance indicators while keeping fraud levels at an acceptably low level.

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6. Record keeping

The Company will maintain detailed and accurate financial records and have appropriate internal controls to provide evidence for all payments.

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7. Revision

This policy will be reviewed and adjusted as necessary to ensure its effectiveness and compliance.

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8. Binding force

The Company is committed to promptly eliminating and combating any inappropriate behavior and will not tolerate such behavior from employees, managers, customers or partners. This policy requires the company to regularly discuss and address factors associated with any form of fraud.