Fraud Policy Statement and Response Procedures

Introduction. Flowers School of Technology and Management (the School) considers the act of fraud as a very serious matter and as such the School is committed to set out a strategy that is designed to frustrate any attempted act of fraudulent or corruption within the School or from outside.

Definition of Fraud. Fraud is defined as dishonest, irregular acts, illegal acts, deliberate intent to embezzel, false representation, issuance of false cheque, acts of money laundering or related act, concealment, 419 or related schemes, furnishing false information with intent to deceive or cause loss to the School, misappropriation of the School's assets including information and intellectual property, diversion of resources or related act for the benefit of an individual or group of individuals at a consequent loss to the School. The above is not to be construed as an exhaustive definition of the term "fraud".

Scope. Flowers School of Technology and Management's policy applies to fraud of any kind or suspected fraud involving members of the School, outside agencies doing business with the School, students or prospective students and or any other parties having a business relation with the School. Flowers School of Technology and Management will carry out any investigative action (including preparing and submitting a dossier to either the British or German police department) without warning or notifying the suspected wrongdoer(s).



FRAUD RESPONSE ACTION PLAN.

1.1 Fraud and or suspected fraud may be reported by any member of staff, student or other parties having dealings with the School.

1.2 Any cheque issued in excess of €50 (Fifty Euros) of actual course fee or service charge will be treated with high level suspicion alert. If the investigation to ascertain the authenticity of such cheque is beyond the capacity of the School, the matter will be referred to the School's Bank Account Manager or the British/German police department for proper investigation and advice.

1.3 Where significant fraud is suspected, the School will prepare a statement for submission to the British/German police department and where necessary the School will instruct solicitors to pursue the prosecution of any individual or parties involved.

1.4 Where any prospective student or parties having business relations with the School present a suspicious pattern of behaviour, the School will endeavour to take an appropriate action to prevent any potential fraudulent scenario from occurring.

The President
Flowers School of Technology and Management