Financial Crime, Anti-Bribery, Sanctions and Fraud

The purpose of this document is to set out IEG Group’s policy in relation to the prevention, detection and response to financial crime risks, including bribery and corruption, fraud, sanctions breaches and conflicts of interest. 

IEG Group operates within sectors including local government and the NHS, where high standards of integrity, transparency and regulatory compliance are required. Financial crime represents a significant risk to the organisation, both in terms of legal exposure and reputational impact. 

This policy defines the controls that must be implemented to manage these risks effectively and forms part of the organisation’s Information Security Management System (ISMS). 

This control applies to all systems, people and processes that constitute the organisation’s information systems, including board members, directors, employees, suppliers and other third parties who have access to IEG Group systems. 

The following policies and procedures are relevant to this document: 

• Staff Handbook 
• Whistleblowing Policy  
• Disciplinary Process  
• HR Security Policy  
• Segregation of Duties Guidelines  
• Information Security Incident Response Procedure  

IEG Group operates a zero-tolerance approach to financial crime and requires all personnel to act with honesty, integrity and accountability at all times. 

Anti-bribery and corruption 

Bribery and corruption in any form are strictly prohibited. 

The organisation will not: 

• Offer, give or accept bribes  
• Make facilitation payments  
• Provide gifts or hospitality intended to improperly influence decisions  

All employees must comply with the standards of conduct defined in the Staff Handbook. 

Any suspicion of bribery or corruption must be reported in accordance with the Whistleblowing Policy. 

Conflicts of interest 

All employees must declare any actual or potential conflicts of interest. 

Managers are responsible for reviewing and managing declared conflicts to ensure that risks are mitigated appropriately. 

Records of conflicts may be maintained where required. 

Training and awareness 

IEG Group provides mandatory training to ensure awareness of financial crime risks. 

• • Training includes:  
    • Anti-bribery and corruption  
    • Whistleblowing
    • Anti-money laundering
  • Training is mandatory at onboarding and must be completed within a defined timeframe
  • A group-wide rollout ensures all existing personnel complete training
  • Completion is tracked via the learning platform, including:
    • Exportable reports
    • Certificates of achievement

Training records are retained as evidence of compliance.

Training must be refreshed at least every two years.

Additional training may be required for higher-risk roles.

Third-party due diligence

IEG Group recognises that third-party relationships present financial crime risks.

The organisation will:

• Perform proportionate due diligence prior to engagement  
• Verify supplier legitimacy and reputation  
• Apply enhanced review for higher-risk engagements 

Suppliers are expected to comply with applicable legal and ethical standards.

Sanctions compliance

IEG Group is committed to complying with applicable financial and trade sanctions. 

The organisation will: 

• Not knowingly engage with sanctioned individuals or entities  
• Perform proportionate checks against publicly available sanctions lists where appropriate
• Escalate any potential matches for review
• Sanctions screening is conducted on a risk-based basis for relevant customers, suppliers and business partners, and records of such checks are retained where applicable. 

Pre-transaction screening

IEG Group conducts sanctions screening against the UK Sanctions List maintained by the Office of Financial Sanctions Implementation (OFSI), in compliance with the Sanctions and Anti-Money Laundering Act 2018. 

Screening may also include the EU Consolidated Sanctions List and other internationally recognised sanctions regimes where appropriate. 

Pre-transaction checks may be conducted on a risk-based basis. 

These checks may include: 

• Identity verification  
• Legitimacy assessment  
• Review of high-value or higher-risk engagements  

Fraud prevention 

IEG Group implements controls to prevent fraud and financial misconduct. 

These include: 

• Segregation of duties where appropriate
• Financial approval controls 
• Monitoring of transactions and anomalies 

Fraud response

Where fraud or suspicious activity is identified: 

• Incidents must be reported immediately 
• Evidence must be preserved  
• An investigation will be conducted  
• Senior management will be informed  
• Legal or regulatory reporting will be considered  

Reporting and whistleblowing

• IEG Group encourages the reporting of concerns relating to financial crime
• Confidential reporting channels are available, and individuals raising concerns will be protected from retaliation
• All reports will be handled in accordance with the Whistleblowing Policy

Financial crime presents a significant risk to IEG Group in terms of legal, regulatory, financial and reputational impact. It is therefore essential that appropriate controls are defined, implemented and maintained to reduce this risk to an acceptable level. 

This policy establishes the principles and requirements for managing financial crime risks across the organisation, including bribery and corruption, fraud, sanctions compliance and conflicts of interest. These controls are supported by related policies, procedures and processes within the Information Security Management System (ISMS). 

All personnel are required to understand and comply with this policy as part of their responsibilities. Failure to do so may result in disciplinary action and, where appropriate, legal consequences. 

This policy will be subject to periodic review to ensure that it remains effective, relevant and aligned with applicable legal, regulatory and organisational requirements.