Fraud Policy

The Munters fraud policy guides in the detection and prevention of fraud against Munters. We promote consistent employee behavior through providing guidelines and assigning responsibility for the development of controls and conduct of investigations. A report on suspected irregularity will be presented at regular intervals to the Board.

Policy applicability

This policy applies to any irregularity involving employees as well as shareholders, consultants, contractors, vendors, outside agencies and other parties with a business relationship with Munters.

Any fraud investigation will be performed without regard to the person's position, title or relationship with Munters.

Examples of fraud

Concerns which should be reported include, but are not limited to, staff committing or attempting to commit:

  • any dishonest or fraudulent act;
  • forgery or alteration of documents or accounts;
  • misappropriation of funds, supplies or other assets;
  • impropriety in the handling or reporting of money or financial transactions;
  • profiting from an official position;
  • disclosure of official activities or information for advantage;
  • accepting or seeking value from third parties by virtue of official position or duties;
  • theft or misuse of property, facilities or services.

Fraud Policy

All management groups are responsible for the detection and prevention of fraud and other irregularities. Fraud is defined as the intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her injury.

All employees are responsible for reporting any perceived irregularities.

Detection and prevention of fraud is an ongoing activity for each management team and will be reported followed up at the Business Review and local Board meetings.

Each member of a management team must be familiar with the types of improprieties that might occur within his or her area of responsibility, and be alert for any indication of irregularity.

Failure to report on a suspected fraud or irregularity may lead to disciplinary action.

Any irregularity that is detected or suspected must be reported immediately to the Chief Financial Officer who will inform the Chief Executive Officer and the Board. Reports can also be sent directly to the Chief Executive Officer or the Chairman of the Board. Anonymous reports will be accepted.

The irregularity shall be reported immediately to the appropriate authorities.

All Munters employees are required to fully cooperate with internal and external investigations. Failure to do so will prompt disciplinary action.

Munters will always do the utmost, including all levels of legal action, to seek to recover any funds lost through fraud. Any employee involved in fraudulent behavior will be subject to prompt disciplinary action – potentially including dismissal – as well as legal action.

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