In accordance with the Insurance Development and Regulatory Authority of India (IRDAI) guidelines on Insurance e-commerce, as stipulated in IRDA/INT/GDL/ECM/055/03/2017 dated 9th March 2017, the Board of Directors of the Company has endorsed a proactive fraud detection policy. This policy encompasses insurance e-commerce operations and is designed to address potential fraudulent activities, including those specific to e-commerce. The formulation of this policy is aligned with the imperative to safeguard against diverse forms of fraud, including e-commerce fraud, that the company may encounter. The policy serves as a comprehensive framework to facilitate the prevention, identification, investigation, and mitigation of fraudulent activities associated with e-commerce operations.

The purpose of this policy is to establish a framework that actively deters, identifies, investigates, and mitigates instances of insurance fraud within the Company. It serves to foster the creation of streamlined procedures aimed at preempting, identifying, and effectively addressing fraudulent activities. Additionally, the policy reinforces the implementation of control mechanisms at an organizational level and facilitates comprehensive investigative practices. The Company is steadfast in its commitment to conduct business with an unwavering emphasis on equity and ethical conduct. The eradication of fraud across all operational facets remains a core aspiration. The Company unreservedly upholds a "Zero-Tolerance" stance towards fraudulence and categorically disapproves of any form of dishonest or fraudulent conduct perpetrated by both internal and external stakeholders.

As defined in the IRDAI's circular (IRDAI/SDD/MISC/CIR/009/01/2013), insurance fraud encompasses actions or omissions deliberately undertaken to gain illicit or unauthorized benefits for the perpetrating party or related entities. These actions may involve:

• Misappropriating Assets: Engaging in the unauthorized use or diversion of assets, which may encompass money, securities, property, or other resources.
• Deliberate Misrepresentation: Intentionally presenting, concealing, suppressing, or failing to disclose crucial material facts essential to financial decisions, transactions, or perceptions regarding the Company's status.
• Abusing Responsibility, Trust, or Fiduciary Relationships: Exploiting one's position of authority, trust, or a fiduciary connection to perpetrate fraudulent acts.

Policy Scope and Protection:

In order to effectively shield the company from the financial and reputational vulnerabilities arising from insurance fraud, this policy is strategically designed. Its primary objectives encompass the prevention, detection, investigation, and mitigation of fraudulent incidents within the company. The policy incorporates strategic measures tailored to counter threats posed by the following overarching categories of fraud, accompanied by an illustrative list.

Internal Fraud:

This category encompasses fraudulent activities committed against the company by its directors, managers, employees, or any other affiliated individuals.

• Embezzlement: Unauthorized diversion or misappropriation of funds, securities, assets, or resources.
• Misleading Financial Reporting: Falsification or modification of accounting records or documents.
• Cheque Manipulation: Forging or altering cheques, bank drafts, or financial instruments.
• Unauthorized Account Openings: Overrides used to initiate unauthorized account setups.
• Inflated Expense Claims: Submission of exaggerated expense reimbursement claims or inflated billing.
• False Invoices with Supplier Collusion: Processing fabricated or inflated invoices through collusion with suppliers.
• Forgery or Alteration of Corporate Documents: Falsification or tampering with company documents.
• Conflicts of Interest Impacting Finances: Situations leading to financial loss due to conflicts of interest.
• Payroll Deception: Fraudulent activities affecting payroll processing.
• Tax Evasion: Intentional evasion of tax obligations.
• Unauthorized or Improper Use of Sensitive Information: Illicit or unauthorized utilization of confidential data.
• Manipulation of IT Systems: Unlawful or unauthorized tampering with information technology systems.
• Deliberate Omission of Material Information: Intentional withholding of significant information.
• Irregularities in Pricing Practices: Unethical or improper pricing practices.

These examples portray the diverse forms of internal fraud covered under the policy. The outlined measures aim to prevent, identify, investigate, and address such fraudulent activities effectively.

The primary responsibility for the daily oversight of activities, alongside the maintenance, implementation, and enhancement of respective systems and controls to mitigate fraud risk, rests with each functional head.

Any instances of fraud identified by any department or discovered by any individual possessing information of confirmed, attempted, or suspected fraudulent activities, as well as anyone coerced into involvement by another party in fraudulent endeavors, must be promptly reported. The functional head is entrusted with the responsibility of reporting such occurrences within 48 hours from the moment of identifying any confirmed, attempted, or suspected fraudulent conduct.

The Head of the Fraud Investigation Unit, along with the Principal Officer, Compliance Officer, or duly authorized individuals, holds the complete mandate for conducting thorough investigations into all suspected or confirmed fraudulent actions as delineated in this policy. The authorized entity shall draw upon the requisite support from pertinent departments, external investigation agencies, and forensic experts, as needed, to facilitate the investigation.
Furthermore, the Principal Officer or the head of the Fraud Investigation Unit is empowered to constitute specialized investigation teams on a case-by-case basis. These teams shall be vested with comprehensive rights and authority to investigate any facet of the company, including but not limited to its records, workstations, storage facilities, emails, documents, and premises, as required for a thorough investigation.