Anti-Money Laundering Policy


Rocket Paye conducts its operations in a lawful and principled manner. All employees, officers, subcontractors, and anyone associated with the company are accountable for maintaining honesty and integrity in their actions, interests, and conduct, without conflicting with the guidelines outlined in this policy, regardless of their level of authority. Rocket Paye is devoted to preventing fraud and fostering an anti-fraud culture. We maintain a strict stance against fraud and require our staff and partners to consistently uphold honesty and integrity, as well as report any reasonable suspicions of fraud. We will thoroughly investigate all cases of actual, attempted, or suspected fraud carried out by staff, consultants, suppliers, or any third parties, and we will endeavour to recover any funds or assets lost due to fraud. Wrongdoers will face disciplinary and/or legal consequences. This policy’s purpose is to establish a clear definition of fraud and to outline the levels of authority, responsibilities, and reporting channels in the event of suspected, attempted, or actual fraud or irregularities perpetrated by an individual or entity against Rocket Paye.

Fraud Defined

The Fraud Act of 2006 establishes a framework in which individuals can be found guilty of fraud if they engage in one of three specific actions:

  1. a) False representation: This occurs when a person intentionally and dishonestly makes a false statement or representation.
  2. b) Failure to disclose information: A person commits fraud if they dishonestly withhold information.
  3. c) Abuse of position: Fraud is committed when a person dishonestly exploits their position.

In these cases, an individual is considered to have committed fraud if they engage in false representation, purposefully withhold information, or abuse their position with the intent to achieve one of the following:

  1. Gaining for themselves or another. ii. Inflicting a loss upon another or exposing another to the risk of loss.

Rocket Paye’s definition of fraud can be found below:

“A false representation of a factual matter—whether conveyed through words or conduct, via false or misleading statements, or through the concealment of information that should have been disclosed—intended to deceive another and induce them to act to their detriment.”

Key Responsibilities

The Managing Director holds the responsibility for creating, implementing, and upholding effective internal control systems to prevent and identify fraud. This role is supported by the Directors. Heads of Departments are tasked with acquainting themselves and their teams with potential instances of fraud and dishonesty that could occur within their respective business units. They are also responsible for overseeing adherence to internal processes, established policies, and procedures. In the event of any signs of fraudulent activity, they should promptly inform their line manager or any of the designated individuals mentioned below.

Suspicions of fraud or irregularity can be identified through various means, including:

  1. a) Individuals reporting their suspicions of fraud or irregularity to their Line Manager, HR Manager, or Director. b) Individuals utilizing the company’s Whistleblowing Policy. c) Detection through routine operational procedures. d) Discovery during planned audit activities.

Reporting Fraud

Any suspected or confirmed instances of fraud or irregularities, whether involving individuals or businesses, must be promptly reported to their Line Manager or Director. At the earliest opportunity, Directors should also be informed. The decision regarding when to involve the police or external agencies will be made by a Director.

When the initial investigation yields reasonable grounds to suspect fraud, the Director will determine how to prevent additional losses. In cases involving employees, this may entail suspending the individual(s) accused of the alleged fraud or irregularity. The timing of the suspension may need to be carefully planned to prevent individuals from destroying or removing evidence that could be essential for further actions.

Loss Recovery

One of the primary goals of any fraud investigation is to recuperate losses. The Director will make sure that in all fraud investigations, the extent of the loss is accurately determined. Efforts to recover the losses should be pursued in every instance. The Director will, when required, contemplate obtaining legal counsel. This may include actions such as freezing the assets of suspects in cases involving substantial losses and pursuing the recovery of losses and associated expenses through legal proceedings.

Communication & Training

Rocket Paye guarantees that its fraud prevention policies and related procedures are ingrained and comprehended across the entire organization through both internal and external communication. This includes training programs tailored to the level of risk the organization faces. Line Managers are tasked with ensuring that all employees receive the necessary training and with disseminating this policy and other pertinent policies to relevant individuals.

Our Commitment

Line Managers are also responsible for overseeing and revising their procedures and action plans to ensure their appropriateness, sufficiency, and effectiveness concerning this policy, implementing enhancements as needed.

This policy undergoes an annual review to verify its suitability, conducted by the Directors. It is fully endorsed by the Rocket Paye management team and enjoys the complete support of the Managing Director and Senior Management.