ABG – Anti-fraud Policy

A B Graphic International Limited

 

1. Policy Statement

1.1            A B Graphic International Ltd is a global leader in innovative label and packaging solutions. Since establishing in Yorkshire by the Burton family in 1954, we remain deeply committed to our values of decency, integrity and above and beyond service.

1.2           Our reputation is founded on the values we uphold as a company, our collective commitment to treating people fairly, and demonstrating the highest ethical standards. This ensures we maintain and enhance our reputation and confidence among our customers and business partners.

1.3            Rooted in our commitment to high ethical standards, we unequivocally reject fraud in all its forms and adopt a zero-tolerance approach to fraud within our business, our business dealings and relationships, or within the operations of our business partners that provide services for us on our behalf.

1.4            We will comply with any laws in relation to countering fraud in all the jurisdictions in which we operate. In the UK, the Economic Crime and Corporate Transparency Act 2023 which came into force on 1 September 2025, applies in respect of our conduct both at home and abroad. This policy details our implementation and enforcement of effective procedures to counter fraud.

1.5            The purpose of this policy is to:

1.1.1              outline our stance and wholesale rejection of fraud, even if it results in short-term business loss, missed opportunities or delays;

1.1.2              set out our responsibilities, and of those working for and on our behalf, in observing and upholding our anti-fraud policy;

1.1.3              provide information and guidance to those working for and on our behalf on how to recognise and deal with fraud; and

1.1.4              include our Fraud Risk Management Procedure in Schedule 1 of this policy.

1.1            Fraud is punishable for individuals by up to 10 years’ imprisonment. If our workers commit an offence with the intention of benefiting us, we could face criminal liability, unlimited fines, reputational damage, and potential civil claims. We therefore take our responsibilities very seriously.

2. Who is Covered by the Policy?

This policy applies to all persons working for us or on our behalf in any capacity and at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, distributors, or any other person associated with us (which refers to any individual or organisation performing services for and on our behalf), or any of our subsidiaries or their employees, wherever located (collectively referred to as workers in this policy).

3. What is Fraud?

3.1            Fraud is an act or omission, made with the intent of making a financial gain, or causing a financial loss, or exposing another to the risk of a financial loss. For the purpose of this policy, fraud includes but is not limited to:

(a)             fraud by false misrepresentation, i.e. knowingly making a false statement to customers;

(b)             fraud by failing to disclose information where there is a legal duty to do so, i.e. failing to disclose relevant product information to customers;

(c)             fraud by abuse of position, i.e. stealing trade secrets from competitors;

(d)             participating in fraudulent businesses;

(e)             obtaining services dishonestly;

(f)               cheating the public revenue, i.e. underreporting tax liabilities to the HMRC;

(g)             false accounting or misleading underlying records; and

(h)             false statements by company directors to deceive members or creditors.

4. Your Responsibilities

4.1            You must ensure that you read, understand and comply with this policy.

4.2            You must not engage or partake in fraudulent activities of any kind, regardless of whether it would benefit us financially.

4.3            The prevention, detection and reporting of fraud are the responsibility of all those working for us or providing services on our behalf. All workers are responsible for:

(a)             complying with this policy which is available on our website;

(b)             acting with propriety in the use of the Company’s resources and the handling of funds and those of customers and suppliers;

(c)             where appropriate, conducting due diligence if there is a risk that fraud might occur in relation to a particular transaction, third party or territory;

(d)             being alert to the possibility that unusual events or transactions could be indicators of fraud;

(e)             reporting details immediately if you suspect that a fraud has been committed or see any suspicious acts or events (see section 5 below regarding raising concerns); and

(f)               co-operating fully during internal audits, reviews or investigations.

4.4            You must notify your Team Leader as soon as possible if you believe or suspect that a breach of this policy has occurred or may occur in the future.

4.5            Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationships with other workers if they breach this policy.

5. How to Raise a Concern

5.1            You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes fraud or is otherwise unlawful, or if you have any other queries, these should be raised with your Team Leader.

5.2            For more information, please refer to the Fraud Risk Management Procedure in Schedule 1 of this policy.

6. Protection

6.1            Workers who refuse to participate in fraudulent activities, or those who raise concerns or report another’s wrongdoing, are sometimes worried they may face possible repercussions. We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

6.2            We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in fraud, or because of reporting in good faith their suspicion that an actual or potential fraud offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Compliance Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

7. Training and Communication

7.1            Training on fraud risk management is part of the induction process to new workers, depending upon their job titles, current responsibilities and potential risks associated with their role, as required. All existing workers in such roles will receive training on how to implement and adhere to this policy.

7.2            Our zero-tolerance approach to fraud must be communicated to all suppliers, distributors, agents, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

8. Who is Responsible for this Policy?

8.1          The board of directors (the Board) has overall responsibility for the effective operation of this policy but has delegated responsibility for overseeing its implementation to the Compliance Manager.

8.2          The Compliance Manager shall have the following specific responsibilities:

(a)          keeping up to date with new fraud risks;

(b)          to maintain a register of the incidents of fraud that are reported to him or her in accordance with this policy;

(c)           to compile a report for the Board every two years on the implementation of this policy including the outcomes of any relevant risk assessments and due diligence and any incidents of reported fraud, thereby contributing to the monitoring and review of this policy; and to recommend any changes to this policy which, may from time to time, become appropriate;

(d)          to ensure that any standard company documents and procedures reflect the requirements of this policy;

(e)          to coordinate our response to any investigation or charge under anti-fraud legislation;

(f)            to ensure that procedures are in place to communicate this policy to all workers and to deliver appropriate training to workers;

(g)          to oversee the compilation of specific fraud risk assessments and the conduct of appropriate due diligence into significant areas of activity with a view of assessment fraud risks and taking appropriate action to mitigate them.

8.3          Team Leaders have day-to-day responsibility for this policy, and you should refer any questions about this policy to them in the first instance. They will involve the Compliance Manager where appropriate.

8.4          This policy is reviewed continually by the Compliance Manager and any suggestions for change should be reported to him or her.

9. Monitoring and Review

9.1          The Compliance Manager will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering fraud.

9.2          All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected risk or wrongdoing.

9.3          We invite comments on this policy and suggestions on ways in which it might be improved. Comments, suggestions and queries should be addressed to the Compliance Manager.

9.4          This policy does not form part of any employee’s contract of employment, and it may be amended at any time.

Schedule 1

Fraud Risk Management Procedure

10. Purpose and Objectives

10.1          The purpose of this Schedule is to provide guidance to employees, managers and others, and ensure there is a clear understanding of our procedures regarding deterrence, detection and investigation of fraud.

10.2          Contact details for the relevant persons or authorities are provided at the end of this Schedule.

11. Reporting Suspected Fraud

11.1          Workers

11.1.1           We rely on you to help prevent and detect fraud as workers are very often the first to realise there are issues within the company. Accordingly, you are in the best position to spot possible fraud cases and report it to us at an early stage.

11.1.2           Please note that we are not trying to encourage workers to spy on colleagues or to create a hostile working environment of suspicion and counterclaims.

11.1.3           You should report any suspicion of fraud, at the earliest opportunity, to your Team Leader. If your Team Leader is unavailable, your concerns should be reported to the Compliance Manager.

11.1.4           If you wish to remain anonymous in making your report, we will make every effort to protect your anonymity. However, in certain circumstances, anonymity cannot be maintained. If this occurs, we will advise you prior to the release of any information.

11.1.5           If you suspect fraud, you should clearly record and retain all evidence, including but not limited to documents, correspondence, emails, invoices or receipts, all activities you have witnessed; and information you have received or are aware of (evidence).

11.1.6           You should avoid discussing your suspicions with anyone other than the Team Leader or Compliance Manager you have raised concerns with. You should not, under any circumstances, attempt to undertake an investigation of your own.

11.1.7           Although workers are encouraged to raise their concerns, if an allegation is made frivolously, in bad faith or for personal gain, disciplinary action may be taken against the worker making the allegation.

11.1.8           Anyone connected to a fraud allegation must retain all evidence in connection to the allegation. You must not destroy or erase any evidence.

11.2          Team Leaders

11.2.1           If you are made aware of fraud, you should listen to the concerns of the worker and treat every report sensitively and seriously.

11.2.2           At the earliest opportunity, you should arrange an interview with the worker to obtain as much information as possible, including any notes and any evidence in support of his or her allegation.

11.2.3           After the interview, you should write a report on the interview including the nature of the complaint, the questions asked, and the answers received. The report should provide a comprehensive picture of any information or allegations for the Compliance Manager and the Board’s future reference.

11.2.4           You must not interfere with any evidence. Any supporting evidence must be retained and stored in a secure location, or if in a digital format.  Please ensure that no one has access to the evidence except the Compliance Manager.

11.2.5           After conducting the interview, writing the report and compiling the evidence, you should then submit all relevant information to the Compliance Manager so he or she may decide whether to launch a formal investigation into the worker’s allegations.

11.2.6           If appropriate and subject to legal constraints, feedback will be provided to the worker who initially raised the concerns.

11.3          Confidentiality

11.3.1           Details of any investigations are strictly confidential and must therefore not be discussed or conveyed to anyone other than the relevant management representatives.

11.4          Disciplinary Action

11.4.1           If a fraud investigation results in the recommendation to dismiss or otherwise discipline a worker, the recommendation will be reviewed for approval by the appropriate representative from Human Resources and the Compliance Manager before such action is taken.

11.5          Internal Contacts

Contact	Details
Compliance Manager	Mark Norman – MarkN@ABGInt.com