Buroka creates opportunities for the people and builds trust between them worldwide. Buroka is committed to conducting
business in accordance with the highest ethical, professional and legal standards. The public, Buroka’s partners
and Users’ have the right to expect that professional, competent and trustworthy people are employed by Buroka.
Buroka will comply with applicable legislation. In line with applicable legislation Buroka has a ‘zero tolerance’
policy towards fraud, corruption, collusion, money laundering, financing of terrorism and other criminal conduct
(jointly “Prohibited Conduct”) and will thoroughly investigate and seek to take disciplinary and/or legal action
against those who perpetrate, are involved in, or assist with fraudulent or other improper actions in all Buroka
activity and related transactions.
Buroka will provide adequate and appropriate resources to implement the Anti-Fraud Policy and will ensure it is
communicated and understood.
The Anti-Fraud Policy has been drafted to comply with the current applicable local and international legislation,
including, but not limited to applicable EU legislation. Adherence to the Anti-Fraud Policy Buroka will ensure
compliance with all relevant legislation and internal policies.
In pursuance of the Anti-Fraud Policy, Prohibited Conduct includes fraud, corruption, collusion, money laundering,
financing of terrorism and other criminal conduct defined as follows:
Fraud: any act or omission, including a misrepresentation that knowingly or recklessly misleads,
or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation.
Corruption: offering, giving, receiving, or soliciting, directly or indirectly, anything
of value to influence improperly the action of another party.
Collusion: arrangement between two or more parties designed to achieve an improper purpose,
including influencing improperly the actions of another party.
D. Money laundering:
(a) the conversion or transfer of property, knowing that such property is derived from criminal
activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit
origin of the property or of assisting any person who is involved in the commission of such activity to evade
the legal consequences of his action;
(b) the concealment or disguise of the true nature, source, location, disposition, movement, rights
with respect to, or ownership of property, knowing that such property is derived from criminal activity or from
an act of participation in such activity;
(c) the acquisition, possession or use of property, knowing, at the time of receipt, that such
property was derived from criminal activity or from an act of participation in such activity;
(d) participation in, association to commit, attempts to commit and aiding, abetting, facilitating
and counselling the commission of any of the actions mentioned in the foregoing points
Terrorist financing: provision or collection of funds, by any means, directly or indirectly,
with the intention that they should be used or in the knowledge that they are to be used, in full or in part,
in order to carry out any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision
2002/475/JHA of 13 June 2002 on combating terrorism.
Criminal conduct: conduct, which constitutes an offence in any part of the world or would
constitute an offence in any part of the world if it occurred there.
Buroka performs a “Know-Your-Customer Policy” (KYC) due diligence on all new Users and a due diligence on all transactions
in order to detect possible compliance or integrity concern. Such due diligence is performed in accordance with
the requirements of the money laundering and terrorist financing activities regulations, pursuant to the terms
In view of the Anti-Fraud Policy Buroka is responsible for:
Buroka’s Operational Anti-Fraud Department, in particular, the Anti-Fraud Commissioner, is the first line of detection,
investigation and protection in preventing Prohibited Conduct through the Users and transactions appraisal process.
The Anti-Fraud Commissioner will be responsible for the proper fulfillment of the Anti-Fraud Policy.
The Anti-Fraud Commissioner, through the Operational Anti-Fraud Department, working in close collaboration with
the Nominated Officer (cf. Know-Your-Customer Policy), shall be responsible for:
For situations requiring an urgent response, the Anti-Fraud Commissioner may take any necessary measures required
for the investigation, notably to preserve evidence.
The Operational Anti-Fraud Department shall enjoy complete independence in the exercise of its responsibilities.
The Anti-Fraud Commissioner shall have full authority to open, pursue, close and report on any investigation
on Prohibited Conduct within its remit without prior notice to, the consent of, or interference from any other
person or entity.
(c) Professional Standards
All Prohibited Conduct investigations conducted by the Operational Anti-Fraud Department shall be fair and impartial,
with due regard to the rights of the Users and persons or entities involved. The presumption of innocence applies
to those alleged to have engaged in misconduct. Those involved in the Prohibited Conduct investigation (be those
under investigation or those conducting the investigation) should be aware of their rights and obligations and
ensure they are fully respected.
All Users are required to cooperate with the Operational Anti-Fraud Department and the Anti-Fraud Commissioner
promptly, fully, efficiently and in the manner specified by the Operational Anti-Fraud Department, including
by answering relevant questions and complying with requests for information and records.
n accordance with Buroka internal rules on access to information, all information and documents collected and generated
during a Prohibited Conduct investigation, not already in the public domain, shall be kept strictly confidential.
The confidentiality of the information collected will be respected both in the interests of those concerned and
the integrity of the investigation.
In particular, during the Prohibited Conduct investigation the confidentiality will be respected in so far as it
would not be contrary to the interests of the investigation.
The Operational Anti-Fraud Department shall disclose such information and documents only to those persons or entities
authorized to receive them or otherwise on a need-to-know basis.
Buroka will review the Anti-Fraud Policy to reflect new legal and regulatory developments and ensure good practice.
I WARRANT AND GUARANTEE THAT I HAVE NO INTENTION TO COMMIT ANY OF PROHIBITED CONDUCT ACTS DESCRIBED HEREIN; FURTHERMORE,
I CONSENT TO ANY CHECKS DUE TO INVESTIGATION UNDER THE ANTI-FRAUD POLICY AND I AGREE TO COOPERATE FULLY AND PROMPTLY
WITH THE ANTI-FRAUD COMMISSIONER WITHIN SUCH INVESTIGATION.