VRS believes that effective fraud prevention begins with a strong culture of ethical business conduct. Every business decision, customer interaction, commercial relationship, and operational activity should be undertaken honestly, fairly, professionally, and in accordance with applicable laws, contractual obligations, and recognised ethical standards.

VRS expects all directors, authorised representatives, independent contractors, recruitment support professionals, consultants, suppliers, technology providers, and business partners acting on behalf of VRS to conduct themselves with integrity and to avoid any behaviour that could undermine trust, create conflicts of interest, expose the business to fraud risks, or damage the reputation of VRS or its customers.

Ethical business conduct extends beyond compliance with legislation. Individuals acting on behalf of VRS are expected to exercise sound judgement, communicate honestly, protect confidential information, accurately represent facts, avoid misleading statements, and conduct all business dealings transparently and in good faith.

VRS does not tolerate dishonest behaviour undertaken for personal gain or commercial advantage, including the concealment of material information, deliberate misrepresentation, falsification of records, manipulation of financial information, misuse of confidential information, or any other conduct intended to deceive customers, suppliers, candidates, technology providers, regulators, or other stakeholders.

Where ethical concerns arise, individuals are encouraged to seek guidance before taking action. VRS believes that maintaining a strong ethical culture significantly reduces fraud risk and supports the long-term sustainability of the business.

VRS seeks to reduce fraud risk through the implementation of appropriate governance arrangements, operational procedures, financial controls, information security practices, verification processes, and organisational oversight.

Fraud prevention measures adopted by VRS may include identity verification procedures, customer due diligence, supplier verification, candidate screening, background verification where appropriate, reference verification, segregation of responsibilities, approval processes, financial controls, secure technology platforms, access management controls, audit logging, secure document handling, cybersecurity protections, confidentiality obligations, information security policies, contractual safeguards, and ongoing operational monitoring.

The nature and extent of these controls will vary depending upon the type of service being provided, the level of commercial risk involved, the sensitivity of the information being processed, applicable contractual obligations, and evolving fraud risks.

VRS recognises that fraud prevention requires continual review rather than reliance upon static controls. Accordingly, fraud prevention measures may be reviewed, strengthened, or expanded periodically to reflect changes in technology, emerging fraud techniques, regulatory developments, customer requirements, or operational experience.

While VRS seeks to implement robust preventative measures, no control framework can completely eliminate the possibility of fraud. For this reason, fraud prevention is supported by ongoing vigilance, reporting mechanisms, monitoring activities, and continuous improvement initiatives across the organisation.

VRS recognises that appropriate due diligence plays an important role in reducing fraud risk throughout the recruitment support lifecycle.

Reasonable verification measures may be undertaken in relation to customers, independent contractors, suppliers, technology providers, business partners, and other organisations with whom VRS establishes commercial relationships.

Depending upon the circumstances, due diligence activities may include verification of business identity, review of publicly available business information, identity verification, reference verification, professional background reviews, confirmation of contact details, verification of banking information, review of contractual documentation, assessment of commercial legitimacy, and other enquiries reasonably considered appropriate to the nature of the proposed relationship.

Within recruitment support activities, VRS may also undertake reasonable verification of candidate information, qualifications, employment history, professional references, identity documentation, and other recruitment-related information where such activities form part of the agreed services or are otherwise appropriate.

The level of due diligence undertaken will generally reflect the nature of the relationship, the level of commercial risk, legal obligations, customer requirements, and the sensitivity of the services being provided.

VRS reserves the right to decline to commence or continue a business relationship where it reasonably believes that appropriate verification cannot be completed, material inconsistencies remain unresolved, fraudulent information has been provided, or unacceptable fraud risks have been identified.

VRS seeks to maintain appropriate financial governance arrangements designed to reduce the risk of financial fraud, accounting irregularities, unauthorised transactions, payment diversion, invoice fraud, and other forms of financial misconduct.

Appropriate financial controls may include segregation of financial responsibilities where practical, approval requirements for significant financial transactions, verification of supplier banking details, invoice review procedures, payment authorisation processes, reconciliation activities, accounting controls, record-keeping requirements, and periodic review of financial processes.

Where changes to payment instructions, banking details, invoicing arrangements, or financial contact information are requested, VRS may undertake reasonable verification before processing such requests. Verification may include independent confirmation through previously established communication channels or other appropriate verification procedures.

VRS also encourages customers, suppliers, and business partners to exercise appropriate caution when receiving payment requests, amended banking details, or other financial instructions purporting to originate from VRS. Any request that appears unusual, unexpected, or inconsistent with previous communications should be independently verified before funds are transferred.

Financial records maintained by VRS should accurately reflect underlying business activities and should not be intentionally falsified, manipulated, concealed, or otherwise altered to misrepresent the financial position or commercial activities of the organisation.

VRS recognises that information systems, cloud platforms, communication technologies, and customer environments are increasingly targeted by cyber-enabled fraud and other malicious activities.

Accordingly, VRS seeks to implement appropriate information security controls designed to protect business systems, customer systems accessed in connection with agreed services, confidential information, commercial information, and personal data against unauthorised access, misuse, theft, manipulation, or compromise.

Depending upon operational requirements, security measures may include role-based access controls, least-privilege access principles, strong authentication requirements, multi-factor authentication where available, secure password management, endpoint protection, encryption technologies, secure communication platforms, audit logging, system monitoring, device security controls, software updates, vulnerability management, malware protection, phishing awareness, and incident response procedures.

Individuals acting on behalf of VRS must not attempt to bypass security controls, access systems beyond their authorised permissions, share credentials, install unauthorised software, deliberately weaken security measures, misuse customer technology environments, or use information systems for unlawful, fraudulent, or unauthorised purposes.

Nothing contained within this Policy authorises any individual acting on behalf of VRS to access customer systems, confidential information, financial records, applicant tracking systems, customer relationship management systems, email environments, or other technology platforms beyond the level of access expressly authorised by the customer and required for the agreed services. Customers remain responsible for determining user permissions and access rights within their own systems, while VRS remains responsible for ensuring that services are delivered professionally, securely, and in accordance with applicable contractual arrangements and internal governance standards.

VRS encourages the prompt reporting of suspected phishing attempts, credential compromise, cybersecurity incidents, suspicious communications, unauthorised system activity, or other events that may indicate attempted cyber fraud so that appropriate containment and investigation measures can be implemented without unnecessary delay.

Where VRS receives information suggesting that fraud or financial crime may have occurred, reasonable steps will be taken to assess the available information and determine whether a formal investigation is appropriate.

The nature and scope of any investigation will depend upon the seriousness of the allegations, the potential risks involved, the information available, applicable legal obligations, contractual arrangements, and the circumstances of the matter.

Investigations may include reviewing documentation, financial records, system access logs, communications, audit trails, recruitment records, contractual documentation, technology platforms, security information, publicly available information, witness accounts, or any other information reasonably considered relevant to establishing an accurate understanding of the circumstances.

Where appropriate, VRS may temporarily restrict access to systems, preserve evidence, engage external advisers, consult legal counsel, notify insurers, involve specialist investigators, or cooperate with customers, suppliers, financial institutions, regulators, or law enforcement agencies while an investigation is ongoing.

Investigations will generally be conducted objectively, confidentially, and in accordance with the principles of procedural fairness. The commencement of an investigation does not constitute a finding that fraud has occurred, and conclusions will be based upon the available evidence following appropriate review.

Upon completion of an investigation, VRS may implement corrective actions designed to strengthen governance, improve operational controls, reduce future fraud risk, enhance information security, recover losses where appropriate, or support any legal or regulatory action considered necessary.

VRS is committed to complying with applicable laws and cooperating with law enforcement agencies, regulatory authorities, government bodies, financial institutions, insurers, and other competent authorities where required or appropriate in connection with suspected fraud, financial crime, or other unlawful activity.

Where VRS reasonably believes that fraudulent conduct, criminal activity, cybercrime, identity theft, bribery, corruption, money laundering, or other unlawful conduct may have occurred, VRS reserves the right to report the matter to the appropriate authorities and to provide information where permitted or required by applicable law.

Depending upon the nature of the matter, VRS may cooperate by preserving relevant evidence, providing documentation, supplying system records, responding to lawful requests for information, participating in investigations, supporting forensic reviews, or taking other reasonable steps necessary to assist lawful enquiries.

Nothing contained within this Policy requires VRS to disclose information where doing so would breach applicable legislation, legal professional privilege, contractual confidentiality obligations, or other legal restrictions. Where disclosure is permitted or required, VRS will seek to ensure that only information reasonably necessary for the relevant purpose is disclosed.

Customers remain responsible for managing their own regulatory obligations in relation to their business operations, including any reporting obligations arising from fraud affecting their own systems or information. Where fraud impacts customer-controlled environments accessed by VRS in connection with the agreed services, VRS will cooperate reasonably with the customer in investigating the matter in accordance with applicable contractual arrangements and legal obligations.

VRS also reserves the right to cooperate with insurers, cybersecurity specialists, forensic investigators, legal advisers, auditors, financial institutions, and other appropriately qualified professionals where their involvement is considered necessary to investigate, mitigate, or resolve fraud-related matters.

Fraud, attempted fraud, financial crime, bribery, corruption, dishonest conduct, intentional deception, cyber-enabled fraud, or any other serious breach of this Policy will be treated seriously by VRS.

Where an investigation establishes that fraudulent or dishonest conduct has occurred, VRS may take any action it reasonably considers appropriate having regard to the nature of the conduct, the seriousness of the matter, contractual obligations, applicable legislation, commercial considerations, and the legitimate interests of affected parties.

Depending upon the circumstances, appropriate action may include suspension or removal of system access, discontinuation of recruitment activities, termination of customer engagements, termination of supplier or contractor relationships, cancellation of commercial arrangements, recovery of financial losses, enforcement of contractual rights, referral to insurers, commencement of civil proceedings, reporting to regulatory authorities, referral to law enforcement agencies, or any combination of these actions.

Where fraud affects customer systems, customer information, candidate information, confidential information, or commercial assets, VRS may also implement additional security controls, undertake further verification activities, review access permissions, strengthen operational procedures, or require additional contractual safeguards before services continue.

The remedies described within this Clause are cumulative and do not limit any other rights or remedies available to VRS under applicable law, equity, contract, or other policies published by VRS.

Nothing in this Clause limits the right of VRS to seek injunctive relief, equitable remedies, recovery of damages, indemnification, or any other legal remedy available in circumstances involving fraud, theft of confidential information, intellectual property misuse, cybersecurity incidents, or other unlawful conduct.

VRS recognises that one of the most effective methods of preventing fraud is ensuring that individuals understand the risks they may encounter and the responsibilities they have in identifying and responding to suspicious activity.

Accordingly, VRS seeks to promote a culture of fraud awareness throughout its business by providing appropriate guidance, operational procedures, governance documentation, information security practices, and educational resources relating to fraud prevention, ethical business conduct, cybersecurity, confidentiality, and responsible information handling.

Where appropriate, directors, authorised representatives, independent contractors, recruitment support professionals, consultants, and other individuals acting on behalf of VRS may receive guidance covering topics such as phishing awareness, business email compromise, social engineering, password security, customer verification, recruitment fraud indicators, document verification, cybersecurity risks, financial controls, conflicts of interest, anti-bribery principles, incident reporting, confidentiality obligations, and responsible use of technology.

Training materials, governance documents, and awareness initiatives may be reviewed and updated periodically to reflect emerging fraud techniques, changes in legislation, technological developments, customer requirements, evolving cybersecurity threats, and operational experience.

VRS also encourages customers to maintain appropriate internal training and awareness programmes within their own organisations to complement the fraud prevention measures implemented by VRS. Effective fraud prevention is strengthened when both parties maintain strong governance, clear communication, and responsible operational practices.

The objective of ongoing awareness activities is not only to improve compliance, but also to foster sound professional judgement, encourage early reporting, strengthen organisational resilience, and reduce the likelihood of fraud occurring across the broader service delivery environment.

VRS recognises that fraud risks, financial crime techniques, cybersecurity threats, and methods of deception continue to evolve rapidly. Accordingly, maintaining an effective fraud prevention framework requires continual monitoring, periodic review, and ongoing enhancement of governance arrangements.

VRS may periodically review this Policy together with its operational procedures, financial controls, recruitment processes, information security measures, technology platforms, supplier relationships, customer onboarding processes, due diligence activities, contractual arrangements, and incident response procedures to identify opportunities for improvement.

Lessons learned from fraud investigations, customer feedback, cybersecurity incidents, attempted fraud, regulatory developments, technological innovation, industry best practices, internal reviews, and operational experience may be incorporated into future policy revisions, governance initiatives, operational improvements, and training programmes.

Where appropriate, VRS may also undertake internal audits, risk assessments, supplier reviews, security assessments, operational evaluations, or other governance activities designed to strengthen organisational resilience against fraud and financial crime.

Continuous improvement is regarded as a core component of VRS's governance framework and reflects our commitment to maintaining high standards of integrity, accountability, transparency, customer protection, and responsible international business operations.

This Fraud Prevention & Financial Crime Policy will be reviewed periodically to ensure that it continues to reflect applicable legislation, recognised governance standards, industry best practices, technological developments, emerging fraud risks, operational requirements, and the evolving needs of VRS and its customers.

VRS reserves the right to amend, update, supplement, replace, or withdraw this Policy where necessary to reflect changes in business operations, legal obligations, regulatory guidance, service offerings, information security practices, fraud risks, or organisational governance.

The most current version of this Policy will be published within the VRS Legal Centre and will become effective from the date specified in the published version unless otherwise stated.

Questions regarding this Policy, reports of suspected fraud, requests for clarification, or concerns relating to financial crime, unethical conduct, cybersecurity incidents, or dishonest business practices may be directed to:

Fraud & Financial Crime Reporting

• Email: fraud@virtualrecruitment.solutions

Legal & Compliance Enquiries

• Email: legal@virtualrecruitment.solutions

• Website: virtualrecruitment.solutions

VRS is committed to maintaining a business environment founded on honesty, transparency, accountability, ethical conduct, and responsible governance. Through the ongoing implementation of robust fraud prevention measures, continuous improvement initiatives, and collaboration with customers and stakeholders, we aim to protect the integrity of our services, safeguard confidential information, strengthen trust, and minimise the risk of fraud and financial crime across every aspect of our international recruitment support operations.