Anti-Fraud Policy of Bajaj Capital Insurance Broking Limited (“BCIBL/Company”)

The Insurance Development and Regulatory Authority of India (IRDAI), vide its Guidelines on Insurance e-commerce bearing number IRDA/INT/GDL/ECM/055/03/2017 dated 9th March 2017 mandates a pro-active fraud detection policy for the insurance e-commerce activities which is approved by the board of directors of the company.

The Company has put in place the framework for identification and mitigation of frauds in the company (“Anti-Fraud Framework) to protect itself and the insurance sector from financial and reputational risks.

The Anti-Fraud Framework is applicable on acts of fraud including suspected fraud in BCIBL which may involve employees (including contractual employees), shareholders, insurance companies, clients, vendors or any other party that has a business relationship with the Company.

IRDAI’s circular bearing IRDAI/SDD/MISC/CIR/009/01/2013 describes fraud in insurance as an act or omission intended to gain dishonest or unlawful advantage for a party committing the fraud or for other related parties. This may, for example, be achieved by means of:

misappropriating assets;

deliberately misrepresenting, concealing, suppressing or not disclosing one or more material facts relevant to the financial decision, transaction or perception of the insurer’s status;

abusing responsibility, a position of trust or a fiduciary relationship

BCIBL’s Antti-Fraud Framework includes identifying, managing, monitoring and prevention of fraud risks.

The Company regularly monitors activities for identification of fraud risk through its risk assessment process and adopts a pro-active approach for prevention of risks which involves implementing effective controls for prevention of frauds before they occur.

In the Company, cases of fraud are reported internally, investigated and appropriate disciplinary action is taken. The Compliance team is actively involved in the process and the Internal Audit team independently assesses the effectiveness of the Anti-Fraud Framework and is also responsible for reporting to the Board of Directors of the Company.

Employees are regularly given trainings covering Anti Money Laundering, Anti-Bribery and Corruption etc. Awareness amongst employees is also created through regular circulars, communication by the leaders via e-mail and at townhalls/meetings etc.