Fraud Prevention and Detection Policy

Version: 1.0 
Effective Date: 01.07.2025
Owner: Compliance & Risk Department
Approved by: Board of Directors

1. Purpose and Commitment

Swisswallter AG (“Swisswallter”, “we”, “our”, or “the Company”) is committed to conducting its business with honesty, integrity, and in full compliance with Swiss law and international best practices. Fraud undermines trust, damages reputation, and can result in significant financial and legal consequences.

This Fraud Prevention and Detection Policy (“Policy”) establishes Swisswallter’s framework for preventing, detecting, responding to, and reporting fraud. It also clarifies the responsibilities of all employees, contractors, partners, and stakeholders in upholding a zero-tolerance approach to fraud.

Swisswallter recognises that robust fraud prevention protects our clients, our employees, the financial system, and the Swisswallter brand.

2. Scope of the Policy

This Policy applies to:

  • All employees (permanent, temporary, full-time, and part-time)
  • Contractors, consultants, and agents
  • Directors, officers, and board members
  • Business partners, suppliers, and any third parties acting on behalf of Swisswallter

It covers all operations of Swisswallter AG globally and applies to fraud committed against Swisswallter, by Swisswallter employees, or involving our clients and partners.

3. Regulatory and Legal Framework

Swisswallter operates under Swiss and international regulations including:

  • Swiss Penal Code (SPC), notably Articles 146–172ter (covering fraud, forgery, criminal mismanagement, corruption, etc.)
  • Federal Act on Combating Money Laundering and Terrorist Financing (AMLA)
  • FINMA (Swiss Financial Market Supervisory Authority) Circulars and Guidance, including requirements for internal controls and reporting
  • Data protection laws (FADP) to protect client and employee data
  • International frameworks (FATF Recommendations, OECD Anti-Bribery Convention)

Swisswallter maintains a compliance culture aligned with these laws and updates this Policy as regulations evolve.

4. What is Fraud?

For Swisswallter, fraud is broadly defined as:

“Any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator or a third party gaining an unfair advantage.”

Examples include (but are not limited to):

  • Misappropriation of funds or digital assets
  • Forgery of documents, records, or digital data
  • Identity theft and impersonation
  • Collusion with third parties to defraud Swisswallter or its clients
  • Insider trading or market manipulation
  • Submitting false expense claims or financial statements
  • Cyber fraud, including phishing, malware attacks, and hacking

Fraud may be committed by employees, contractors, partners, clients, or external criminals.

5. Policy Objectives

This Policy aims to:

  • Prevent fraud through education, awareness, robust internal controls, and risk management
  • Detect fraudulent activities quickly using monitoring, audits, and whistleblowing mechanisms
  • Respond to suspected fraud decisively and fairly, ensuring proper investigation and recovery
  • Report confirmed fraud to appropriate authorities, as required by Swiss law
  • Maintain client, partner, and public confidence in Swisswallter’s integrity

6. Responsibilities

Fraud prevention is everyone’s responsibility.

Board of Directors

  • Approves and periodically reviews this Policy
  • Oversees implementation and effectiveness
  • Ensures adequate resources and independence for fraud risk management

Senior Management

  • Embeds a culture of integrity and zero tolerance
  • Implements effective controls and monitoring
  • Supports investigations and disciplinary measures

Compliance & Risk Department

  • Maintains and updates this Policy
  • Conducts fraud risk assessments
  • Coordinates investigations, documents findings, and reports to regulators

All Employees, Contractors, and Agents

  • Act honestly and ethically at all times
  • Immediately report suspected fraud
  • Cooperate fully with any investigations
  • Complete mandatory fraud awareness training

External Partners and Suppliers

  • Must comply with Swisswallter’s fraud prevention standards and contractual clauses related to anti-fraud compliance

7. Prevention Measures

Swisswallter implements layered, practical controls and prevention strategies:

  • Rigorous due diligence (KYC, KYB) on clients and partners
  • Segregation of duties and dual approvals for critical transactions
  • Automated transaction monitoring and anomaly detection
  • Secure IT systems with multi-factor authentication and encryption
  • Background checks during hiring and supplier onboarding
  • Written policies for expense management, procurement, and approvals
  • Periodic internal and external audits

These measures reduce fraud risk without compromising client service.

8. Detection and Reporting

Early detection is critical. Swisswallter maintains:

  • Real-time monitoring systems to detect unusual transactions
  • Internal audits and compliance reviews
  • A whistleblowing channel for employees and external parties to report concerns anonymously and confidentially
  • Regular fraud risk assessments

Employees must report any suspicion or evidence of fraud immediately, without fear of retaliation.

9. Investigation Procedures

When fraud is suspected:

  • Compliance Risk coordinates a preliminary assessment.
  • If warranted, a formal investigation is launched, with independence and confidentiality.
  • Findings are documented objectively.
  • Appropriate actions are taken, which may include:
    • Disciplinary measures (including dismissal)
    • Civil action to recover losses
    • Reporting to law enforcement or FINMA
    • Root causes are analysed, and controls are strengthened.

Investigations follow principles of fairness, data protection, and due process.

10. Response and Consequences

Swisswallter enforces a zero-tolerance approach:

  • Proven fraud results in disciplinary action, up to termination
  • Civil recovery of losses and, if necessary, legal proceedings
  • Cooperation with criminal prosecution
  • Review and strengthening of internal controls to prevent recurrence

11. Training and Culture

  • New joiners complete fraud awareness training as part of onboarding
  • Annual refresher training is mandatory for all staff
  • Managers reinforce expectations through team discussions
  • Updates on fraud trends and new risks are shared periodically

This creates a culture where fraud prevention is a shared responsibility.

12. Confidentiality and Data Protection

All reports, investigations, and related data are handled confidentially, respecting Swiss data protection law (FADP) and the rights of individuals involved.

13. Review and Maintenance

This Policy is:

  • Reviewed at least annually by the Compliance & Risk Department
  • Updated to reflect new laws, regulations, risks, and lessons learned from investigations
  • Approved by the Board of Directors

14. Reporting Contacts

To report suspected fraud or ask questions:
Swisswallter Compliance & Risk Department

Email: [email protected]
[email protected]