Anti-Fraud Policy

AIA Group adopts a Zero-tolerance approach to fraud and expects all employees, insurance intermediaries and third parties to act with honesty and integrity. All suspected cases of fraud will be investigated and disciplinary procedures enforced, including prosecution and termination.

Fraud involves an act of intentional deceit to secure (by the act or omission of another person) an unfair or unlawful gain for oneself or another or a loss to another. Acts such as deception, bribery, forgery, extortion, corruption, conspiracy, embezzlement, misappropriation, and collusion may or may not constitute fraud, but are also included within the scope of this policy.

Examples of fraud:

• False accounting, including deliberate misstatement of financial information for personal and/or financial gain;
• Theft including trade secrets, intellectual property, equipment, etc;
• Using false payment instructions, invoices or cheques in order to receive a payment to ones’ own account, or to a third party account in exchange for a benefit;
• Falsification of payroll records, unsubstantiated expense claims, accepting or providing bribes or kickbacks in exchange for business whether or not for AIA’s benefit;
• Acts by insurance intermediaries, including any act or omission knowingly committed with the intent to obtain a benefit through deceit. This would include, but not be limited to: forgery or intentionally presenting false information on an application for insurance or in connection with the renewal or reinstatement of insurance or in support of a claim for benefits; the manipulation of policy documents in order to unlawfully obtain customer funds; fraudulent representations in sales and marketing activities; and embezzlement or theft of company or client assets including policy benefits and premiums.

Stay alert to the signs of fraud and report suspicion of fraud immediately, regardless of value, to your manager, or, if you prefer, instead to: Group Internal Audit; a Compliance Officer; or anonymously via the AIA Ethics & Compliance Hotline at www.aiaethicsline.com. Head of Group Internal Audit must be notified immediately if the alleged fraud involves manipulation, omissions or misrepresentation of financial reports/ results.

• If your subordinate reports any suspected fraud then you should, in turn, report the matter to Group Internal Audit or a Compliance Officer.
• Do not alert the suspected individual or other unauthorised persons in an effort to determine facts or suspicion. All cases of suspected fraud will be handled with utmost care / confidentially.
• Read the Code of Conduct and this Policy and attend the relevant training programs provided by the AIA Group to understand your obligations. Work in accordance with the Operating Principles.
• Line functions are required to establish and maintain sufficient controls to ensure that fraud risk is properly monitored and mitigated. All employees should comply with controls and procedures in their areas of responsibility.
• Ensure that vendors, consultants, intermediaries and other external parties are aware of this AIA Group Anti-Fraud Policy.
• Cooperate in investigations and do not willfully or knowingly state anything which you believe is false or you do not believe to be true.

Public information about current fraud schemes at other organisations for any lessons to be learned and applied at AIA.

Where you believe the opportunity for fraud exists, you should discuss it with your line manager or Group Internal Audit. A number of frauds can be detected through suspicious behaviour. Some common red flags include: (More examples are included in the AIA Group Anti-Fraud Guidelines)

• Reluctance to take leave, missing invoices/ contracts, Vendor selection without following procurement policy, fake vouchers, fake employment documents etc.
• Intermediary frauds - trend of loans, surrendered or lapsed policies in the portfolio, suspicious customer signatures including for requests to change existing information, constant excuses for delay in submitting customer premium, withdrawal of complaints by customers etc.

If you think a suspected fraud could potentially give rise to material legal or regulatory exposure for AIA, your Law Department should be consulted to help with the fraud report and investigation. While never a reason to delay or avoid internally reporting and investigating suspected fraud, your Law Department can help preserve legal privilege, to the extent it is available, which may assist in managing any subsequent external proceedings.