Compass Sea School Ltd is committed to operating ethically and legally in all areas of its business. In order to do that we enforce the following policies to all staff, contractors, students and any other parties with which we do business.
Counter Fraud Policy
Statement
Compass Sea School Ltd is committed to the prevention of fraud and the promotion of an anti-fraud culture. Compass Sea School Ltd operates a zero-tolerance attitude to fraud and requires staff to act honestly and with integrity at all times, and to report all reasonable suspicions of fraud.
Compass Sea School Ltd will investigate all instances of actual, attempted and suspected fraud committed by staff, freelance instructors, students, suppliers, subsidiaries and other third parties, and will seek to recover funds and assets lost through fraud. Perpetrators will be subject to disciplinary and/or legal action.
Definition of fraud
The term ‘fraud’ is commonly used to describe the use of deception to deprive, disadvantage or cause loss to another person or party, or to obtain financial gain. This can include theft, the misuse of funds or other resources, or more complicated crimes such as false accounting and the supply of false information.
Examples include purchasing items for personal use using Compass Sea School Ltd funds, unapproved use of Compass Sea School Ltd assets for personal gain, falsely claiming travel expenses, or undertaking activities for personal gain during paid Compass Sea School Ltd time without appropriate approval.
Individuals can be prosecuted under the Fraud Act 2006 if they make a false representation, fail to disclose information or abuse their position.
Reporting suspicions
Personnel should report concerns about actual, attempted or suspected fraud directly to the Chief Instructor who will in turn inform the Centre Principal. Staff should not attempt to investigate any fraud themselves.
The Public Interest Disclosure Act 1998 protects employees who raise concerns about certain matters of public interest in good faith.
Anti-Bribery and Corruption Policy
It is the policy of Compass Sea School Ltd that all staff, freelance Instructors and students conduct business in an honest way, and without the use of corrupt practices or acts of bribery to obtain an unfair advantage.
This is not just a cultural commitment on the part of Compass Sea School; bribery is a criminal offence in most countries and corrupt acts expose the Centre and its employees to the risk of prosecution, fines and imprisonment, as well as endangering the Centre’s reputation.
A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.
Employees and others acting for or on behalf of the Company are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments. As part of its anti-bribery measures, the Company accepts transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure, whether given or received.
A breach of these Policies by an employee or freelance instructor will be treated as grounds for disciplinary action. Employees and other individuals acting for the Company should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for the Company.
Anti-Money Laundering
Compass Sea School Ltd has a zero tolerance policy towards Money Laundering and dealing with the proceeds of crime, and we are committed to implementing and enforcing effective systems to counter them. In addition, the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the Money Laundering Regulations 2007 place obligations on Compass Sea School Ltd and its subsidiaries to establish internal procedures to prevent the use of our services for money laundering.
Money laundering is the process of changing ‘dirty’ money into ‘clean’ money in order to hide the fact it may have originated from criminal activity. Money Laundering is the term used for a number of offences involving the proceeds of crime or terrorism funds. Currently Compass Sea School Ltd does not undertake activities requiring licensing under the Money Laundering Regulations but we will continue to actively review the situation to ensure that we do not exceed the thresholds over which we must be licensed.
This anti money laundering applies to the entire workforce, both permanent and temporary. In addition we expect all our suppliers and contractors to comply with equivalent principles to those set out in this policy. Potentially any one of us could be caught by the money laundering provisions if we suspect money laundering and either become involved with it or do nothing about it.
The consequences for any of us of committing an offence are potentially very serious. The failure to disclose a suspicion of a case of Money Laundering is a serious offence, and there are only very limited grounds in law for not reporting a suspicion. Failure to comply with this policy, including reporting suspicious activity, may lead to disciplinary action being taken in addition to any legal prosecution.
Whilst the risk to Compass Sea School Ltd of being involved in any Money Laundering activity is considered low, it is important that we all understand our legal responsibilities and how to report any suspected suspicious activity. Any suspicious activity MUST be reported as soon as is practicably possible directly to the Centre Principal.
Further Information and Guidance
Should you require any further information or guidance on any of the policies in this page please contact us at: Contact Us
