Ant-Fraud Policy

Ritemix Consortium

Ritemix Consortium Limited

Document Date: 10/08/2010

Anti-Fraud Management Framework

File name: o3/01 Risk Management Framework REF: RMERM/ATFv1.0.100810 Doc.

Approval
Department
Head Risk Management Head Human Resources

Names & Date

Signature

Comment

Head-Internal Audit

Chief Executive Chair Audit Committee

Implementation
Department
Head Risk Management (Owner) Head Human Resources

Names & Date

Signature

Comment

VERSION HISTORY
Document Version
1.0

Date
10/08/2010

Author(s)

Details/Description
Whole document

Prepared by: Head Risk Management

Reviewed by: Chief Executive

Authorized by : Chair Audit Committee

Effective date: September 2010

Ver:1.0

Page: 2 of 9

Ritemix Consortium Limited

Document Date: 10/08/2010

Anti-Fraud Management Framework

File name: o3/01 Risk Management Framework REF: RMERM/ATFv1.0.100810 Doc.

1. Introduction

1.1 Rite mix recognizes that fraud risk management has great value in the assurance of business goals realization. Further, Managing fraud risk provides confidence to Rite mix customers, stakeholders and investors on reliability of services and report arising from its business activities. 1.2 To attain this value, Rite mix is committed to the highest standards of openness, probity and accountability in all its affairs through the creation of the appropriate tone at the top and is determined to maintain a culture of honesty and proactive fraud risk Management in all it business activities and relationships, reinforced through the establishment and maintenance of policies and an effective system of Internal Controls. 1.3 In line with that commitment, this Anti-Fraud Policy outlines the principles relating to preventing, reporting and managing fraud.

2. Purpose

The purpose of this policy is

2.1 Communicate management commitment to uphold good corporate governance by establishing this enterprise wide fraud policy. 2.2 To ensure that all parties are aware of their responsibilities towards fraud risk management and for establishing controls and procedures for preventing fraudulent activity and/or detecting such fraudulent activity when it occurs in all of Rite mix business activities. 2.3 To provide guidance to staff as to action which should be taken where they suspect any fraudulent activity. 2.4 To provide a clear statement to staff forbidding any Fraudulent activity 2.5 To provide assurance of zero terrorance to any fraudulent activities and that any and all suspected fraudulent event will be fully investigated, and action taken including prosecution , termination of contract and loss recovery procedures.

3. Audience &Scope

3.1. This policy applies to any irregularity or Fraud , or suspected

irregularity or Fraud, involving employees as well as shareholders, consultants, vendors, contractors, outside agencies doing business with employees of such agencies, and/or any other parties with a business relationship with Rite mix Consortium
3.2. Any investigative activity will be conducted by qualified and competent professional to all suspects without regard to length of position/title, or relationship.

Prepared by: Head Risk Management

Reviewed by: Chief Executive

Authorized by : Chair Audit Committee

Effective date: September 2010

Ver:1.0

Page: 3 of 9

Ritemix Consortium Limited

Document Date: 10/08/2010

Anti-Fraud Management Framework

File name: o3/01 Risk Management Framework REF: RMERM/ATFv1.0.100810 Doc.

4. Definitions

Actions Constituting Fraud Fraud terms mean defalcation, Misrepresentation, misappropriation, and other economic irregularities refer to, but are not limited to: Any dishonest or fraudulent act including all use of deceit for personal gain and violation of business rule for direct or indirect illegitimate gain from Rite mix activities Copying, stealing, misuse and unauthorized usage of Rite mix systems, Forgery or alteration of any document or account information Forgery or alteration of a check, e-value, bank draft, or any other financial instrument Misappropriation of funds, securities, supplies, or other assets Impropriety in the handling or reporting of money or financial transactions Profiteering as a result of insider knowledge of Ritemix activities Disclosing to other persons the securities activities engaged in, or contemplated by the consortium. Accepting or seeking anything of material value from vendors or persons providing services/materials to the company intended for a group of employees Destruction or disappearance of records, furniture, fixtures, or equipment Contact the Manager of Rite mix Integrity Unit for guidance if you have any questions of whether an action constitutes fraud.

5. Policy Ownership Roles

5.1 The Board of Rite mix has ultimate responsibility of setting integrity and fraud risk control culture, ethical and fair working environment, zero fraud terrorance fraud appetite and for the prevention and detection of fraud, and is also accountable for ensuring that appropriate and effective internal control systems are in place including policy guideline and resources availability. 5.2 Senior Management is responsible communicating Boards anti-fraud principal s ant fraud policy, detecting fraud i.e. misappropriations and other irregularities and shall be responsible in ensuring ant-fraud control are implemented in their respective functions. 5.3 Each member of the management team should be familiar with the type s fraud risks and of improprieties that might occur within his or her area of responsibility and administer pre-emptive controls and be alert for any indication of fraud risk in his jurisdiction.

Prepared by: Head Risk Management

Reviewed by: Chief Executive

Authorized by : Chair Audit Committee

Effective date: September 2010

Ver:1.0

Page: 4 of 9

Ritemix Consortium Limited

Document Date: 10/08/2010

Anti-Fraud Management Framework

File name: o3/01 Risk Management Framework REF: RMERM/ATFv1.0.100810 Doc.

5.4 All managers must ensure that there are mechanisms in place within their area of control to: 5.4.1 With help of head of risk Management assess the risk of fraud 5.4.2 educate employees about fraud prevention and detection facilitate the reporting of suspected fraudulent activities 5.4.3 All staff shares in the responsibility for the prevention and detection of fraud in their areas of responsibility. All staff has the responsibility to report suspected fraud. Any staff member who suspects fraudulent activity must immediately notify their supervisor or those responsible for investigations. In situations where the supervisor is suspected of involvement in the fraudulent activity, the matter should be notified to the next highest level of supervision 5.5 Head of Risk Management, who report functionally to the audit committee of the board shall be responsible for day to day monitoring of compliance of this policy and shall establish a dedicated Integrity Unit team. 5.6 All employees roles against fraud shall include professional obligation to maintain the highest standards of honesty, propriety and integrity in the exercise of their duties. They are responsible for reporting any suspected fraud, impropriety or other dishonest activity immediately to the manager to Integrity Unit or through the whistleblower program, and to assist in the investigation of any suspected fraud as may be required by management. 5.7 Any fraud by any staff member shall constitute grounds for dismissal and criminal and/or civil litigation against the suspect. 5.8 All staff must read and sign acceptance to adherence to Rite mix internal policies before induction as an employee of Rite mix.

6. Confidentiality

6.1 Rite mix Integrity Unit will accept Fraud relevant information on a confidential basis from an employee who suspects dishonest or fraudulent activity. 6.2 Employees should contact Rite mix Integrity Unit immediately, and should not attempt personally to conduct investigations or interviews/ interrogations related to suspected fraud. 6.3 The results of investigations conducted by Rite mix Integrity Unit will not be disclosed to anyone other than those persons associated with the company who have a legitimate need to know in order to perform their duties and

Prepared by: Head Risk Management

Reviewed by: Chief Executive

Authorized by : Chair Audit Committee

Effective date: September 2010

Ver:1.0

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Ritemix Consortium Limited

Document Date: 10/08/2010

Anti-Fraud Management Framework

File name: o3/01 Risk Management Framework REF: RMERM/ATFv1.0.100810 Doc.

responsibilities to avoid damaging the reputations of persons suspected, but subsequently found innocent of Fraud, and to protect the company from potential civil liability. 6.4 Rite mix will do its best to protect an individual s identity when he or she raises a fraud concern. However the investigation process may reveal the source of the information and a statement by the individual may be required as part of the evidence. 6.5 Rite mix has established Whistle-blowing Program intended to encourage and enable staff to raise serious concerns within the Company rather than overlooking a problem due to fear of harassment and victimization. The Whistle-blowing Program policy which is available on the Rite mix website and the HR manual

7. Anti-Fraud Procedures

7.1 All Fraud investigation will follow due professional fraud examination processes from suspicion to disposition, including police and legal procedures till termination after prosecution and loss recovery from confirmed fraudsters.

7.2 Fraud prevention procedures and appropriate internal controls processes must and shall be incorporated in the organisation s policies related to Cash Management, Value transactions, all other Commercial Transactions, and Investment systems. 7.3 All complaints of suspected fraudulent behaviour will be investigated whilst also providing for the protection of those individuals making the complaint and natural justice to those individuals being the subject of any such complaint. Rite mix recognizes that the decision to report a concern can be a lead to risk of reprisal from those responsible for the malpractice. The Company will not tolerate harassment or victimization and will take action to protect those who raise a concern in good faith 7.4 Where a prima facie case of fraud has been established the matter shall be referred to police. Any action taken by police shall be pursued independently of any employment-related investigation by the organisation. 7.5 Recruitment strategies shall incorporate fraud prevention; Applicants shall be required to undergo police checks where required by the duties of the position.

Prepared by: Head Risk Management

Reviewed by: Chief Executive

Authorized by : Chair Audit Committee

Effective date: September 2010

Ver:1.0

Page: 6 of 9

Ritemix Consortium Limited

Document Date: 10/08/2010

Anti-Fraud Management Framework

File name: o3/01 Risk Management Framework REF: RMERM/ATFv1.0.100810 Doc.

7.6 Rite mix human resources shall use healthy recruitment process where Previous employers and referees shall be contacted, Transcripts, qualifications , publications and other certification or documentation shall be validated. 7.7 Fraud prevention and detection subject will be included in relevant staff development and induction activities and each staff is required to attend at least one internal or external ant fraud training annually 7.8 Vendors and contractors shall be asked to agree in writing to abide by these policies and procedures. 7.9 If an allegation is made in good faith, but it is not confirmed by the investigation, no action will be taken against the originator. If, however, individuals make malicious or vexatious allegations, action may be considered against the individual making the allegation.
Fraud Prevention 7.10 Head of risk management shall champion upfront end to end risk assessment of all Ritemix business activities, project, products and processes and ensure all fraud risk are appropriately managed. Fraud Detection 7.12 Head of Ritemix Integrity Unit will set monitors and maintain Key Fraud Risk indicators (KFRI) across all Ritemix business activities. He will also ensure all staff obtains at least one fraud awareness training to create companywide detection capability. Investigation Responsibilities 7.13 Rite mix Integrity Unit has the primary responsibility for all detected suspected irregularity or fraud investigations 7.14 If an investigation reveals that fraudulent activities have occurred, Rite mix Integrity Unit will issue reports to the proper executives and, if appropriate, to the Board of Directors through its Audit Committee, police and legal cancel to help in fraud disposition in court of law. 7.15 Decisions to prosecute or turn matters over to appropriate law enforcement and/or regulatory agencies for independent investigation will be

Prepared by: Head Risk Management

Reviewed by: Chief Executive

Authorized by : Chair Audit Committee

Effective date: September 2010

Ver:1.0

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Ritemix Consortium Limited

Document Date: 10/08/2010

Anti-Fraud Management Framework

File name: o3/01 Risk Management Framework REF: RMERM/ATFv1.0.100810 Doc.

made in conjunction with legal counsel and Senior Management, as will final decisions on disposition of cases. Authorization for Investigating Suspected Fraud 7.16 In those instances in which the Head of Rite mix Integrity Unit believes it to be in the best interests, members of Rite mix Integrity Unit have the authority and duty, after consulting with appropriate executives, to: Take control of, and/or gain full access to, all company premises, whether owner or rented. 7.17 Examine, copy, and/or remove all or any portion of the contents of files, desks, cabinets, and other storage facilities on the premises without prior knowledge or consent of any individual who may use or have custody of any such items or facilities. Reporting Procedure 7.18 Any irregularity detected or suspected fraud must be reported immediately to the Rite mix Integrity Unit which coordinates all investigations with the help of Rite mix Legal Department and other affected functional managers, both internal and external. Great care must be taken in the investigation of suspected improprieties or irregularities to avoid mistaken accusations or alerting suspected individuals that an investigation is under way. 7.19 An employee who discovers or suspects fraudulent activity should contact Rite mix Integrity Unit immediately using fraud hotline, email to fraud team, or fraud information box. 7.20 All inquiries of the suspected fraud should be directed to Head of Rite mix Integrity Unit or any senior management staff. 7.21 Action will be taken on all cases reported and the respective conclusions will be outlined in the Fraud Register, and Loss data bases Updated Post investigation review 7.22 In all confirmed fraud investigation, a post-mortem will be carried by a committee headed by head of Integrity unit and recommend processes and policy changes to prevent the fraud from re-occurring. Policy Review 7.23 This policy shall be at least annually and when necessary reviewed by the Rite mix Head of Enterprise risk Management in consultation with the head of Human Resources and with Head of Internal Audit providing and independent policy adequacy and effectiveness review

Prepared by: Head Risk Management

Reviewed by: Chief Executive

Authorized by : Chair Audit Committee

Effective date: September 2010

Ver:1.0

Page: 8 of 9

Ritemix Consortium Limited

Document Date: 10/08/2010

Anti-Fraud Management Framework

File name: o3/01 Risk Management Framework REF: RMERM/ATFv1.0.100810 Doc.

8. Enforcement

8.1 Non compliance with or violation of this Policy may result in serious disciplinary action, including suspension or termination of employment. It may also result in civil and/or criminal prosecution and penalties as applicable by law litigation to recover losses arising from the policy breaches. 8.3 All questions regarding this policy can be directed to the Head of Enterprise Risk or Head of Human resources or the Chief Executive.

Notice
This policy is supplemented by Ritemix , Fraud processes Manual, Whistle blowing policy, code of ethic and HR Manual ----END---

Prepared by: Head Risk Management

Reviewed by: Chief Executive

Authorized by : Chair Audit Committee

Effective date: September 2010

Ver:1.0

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