Fraud Detection Policy

Revision History

Effective Date	Version	Summary Of Revisions	Author	Reviewer
	1.1	Creation of new Policy	SMC IT Team	Pravin Agarwal

1. Introduction

Company is required to disclose the adequacy of systems in place to safeguard the assets for preventing and detecting fraud and other irregularities. Policy has been formulated considering e-commerce frauds that the Company can be exposed to.

The Policy shall also provide guidance with respect to the prevention, detection, mitigation and investigation into fraudulent activities related to e-commerce.

2. Objective and Policy Statement

The Policy is established to detect, monitor, mitigate and report occurrence of insurance fraud in the Company. It would facilitate development of processes to prevent, detect and manage frauds. Further it will also ensure development of control measures at an organizational level and conducting investigations. The Company is committed to conducting business in an environment of fairness and integrity and will strive to protect itself from any fraud emanating from its operations.

3. Scope and Applicability

This Policy applies to any fraud or suspected fraud involving employees as well as shareholders, consultants, vendors, contractors, outside agencies doing business with the Company and/or any other parties having a business relationship with the Company including insurance advisors/corporate agents of the Company. The policy would also be applicable to policyholders and beneficiaries. Any investigation activity required will be conducted.

4. Review and approval of the policy

The policy will be reviewed and approved by Board of Directors. Risk Management and Fraud Monitoring Department shall assist in the review process and recommend necessary changes in the policy. Policy may be reviewed based on the newly released changes to Acts, regulatory requirements, independent audits and/or internal review.

Procedures

Sr. No.	Procedure Description	Reference
P-1.1	Board of Directors – The Board is responsible for overseeing the Fraud Control Framework and for approving, reviewing and monitoring compliance with the Policy. The Board may delegate this responsibility to the Risk Management Committee. First Line of Defence – Primary responsibility for the implementation and practice of fraud risk management, including core risk management principles of risk identification, measurement, management, monitoring & reporting rests with the first line of defence i.e. the concerned process owner / business / line function. Second Line of Defence – The Compliance and Risk functions are the second line of defence, who are responsible for reviewing and challenging the completeness and accuracy of the first line’s risk identification, measurement, management, monitoring and reporting. Third Line of Defence – Audit is the third line of defence. Audit is responsible for independent assessment on the effectiveness of the fraud controls framework design and operation, and is also responsible for reporting findings and concerns to the Management and the Company’s Audit and Risk Committees.	-
P-1.2	Procedures for Fraud Monitoring. The Company will have well defined procedures to identify, detect, investigate and report frauds. The Risk Management and Fraud Monitoring department will develop / manage systems & framework and analytical tool methodologies to identify potential fraud areas / red flags. Through sampling methodology, the team will identify patterns / trends to review processes and will put in place preventive and corrective measures. It also spreads awareness regarding fraud prevention across the Company to develop a culture of zero tolerance to fraud. All incidents and complaints with suspected fraudulent activity are investigated and analyzed. Queries are generated to initiate the investigation and post investigation conclusions, after due validation of evidences, are put up to the Disciplinary Authority for taking appropriate action. All Functional Heads are primarily responsible for day to day management of activities and in charge of maintaining, implementing and improving their systems, processes & controls so that they minimize the possibility of frauds and on a timely basis mitigate the impact of an identified fraud. The Heads of various departments at Corporate Office, and Regional HODs/Directors will submit a report regarding identification and reporting of fraud, if any, in their respective functional / geographical area.
P-1.3	Any employee who suspects or detects dishonest or fraudulent activity should report immediately, in any case, within 48 hours of its detection. While the reporting can be done by any employee / person who suspects / detects the fraud, Head of the Department / Office / Branch is responsible to ensure that the fraud is reported within the aforesaid timelines. Complete information as available should be provided at the time of reporting.
P-1.4	In case the Department / Region / Office have conducted a preliminary investigation of the fraud, the investigation report should be annexed at the time of incident reporting. If there is any doubt as to whether an action constitutes fraud, the Risk Management and Fraud Monitoring Department may be contacted for guidance. Employees and other individuals should not attempt to personally conduct investigations or interviews / interrogations related to any suspected fraudulent act.
P-1.5	Disciplinary action may be initiated against the employee(s) for not reporting or withholding information related to suspected or actual fraud. The Company urges its intermediaries, vendors, policyholders, beneficiaries & all concerned to act in a lawful & proper manner and to report allegations or irregularities in respect of any fraud to the Organization.
P-1.6	The Company ensures that all suspected / actual fraud incidents are investigated, the root cause is determined, appropriate action as per disciplinary matrix is taken, and mitigating controls are implemented to avoid recurrence of such incidents in future.
P-1.7	Risk Management and Fraud Monitoring department shall generate fraud mitigation communication within the Company at periodic intervals or on adhoc basis, as may be required. It must also ensure information flow to concerned departments with respect to frauds.
P-1.8	The Company will inform stakeholders about its Fraud Prevention Policy. The Company will incorporate necessary caution in the insurance contracts / relevant documents duly highlighting the consequences of submitting a false statement and / or incomplete statement, for the benefit of policyholders, claimants and beneficiaries. The Company will proactively identify and monitor frauds on an ongoing basis.
P-1.9	An ongoing awareness program is a key enabler to convey fraud risk management expectations, as well as an effective preventive measure. Awareness of fraud and misconduct schemes should be developed through periodic assessment, training, and frequent communication.
P-1.10	Any exception with respect to the Policy shall be reviewed by the Board. The exception request shall be submitted to the Risk Management and Fraud Monitoring department in the form of a Note addressing the Board with complete description of the said exception.
P-1.11	Fraud events are reported and presented at relevant Committees held periodically. The report details statistics of fraud cases, summary on key cases identified, loss amount, resolution and action etc. Concerned department is responsible for reporting of frauds in the format / template and within the timelines prescribed.

Service Parameters	Maximum TAT^* (calendar days)	Turnaround Time to be Calculated From
Written communication of decisions on the proposal / raising additional requirements on the proposal	7 days	Date of receipt of the proposal or the date of receipt of any requirement called for, whichever is later
Requests for refund including free look cancellation, surrender and withdrawal; refund of proposal deposit; refund of outstanding proposal deposit, if any	7 days	Date of receipt of (a) request, or (b) last necessary document, whichever is later
Post policy servicing requests	7 days	Date of receipt of (a) request, or (b) last necessary document, whichever is later
Resolution of Grievance	14 days	Endeavor to provide a resolution on the Grievance within 14 Days of receipt of Grievance

Service Parameters	Maximum Turnaround Time (calendar days)	Turnaround Time to be Calculated From
Written communication of decisions on the proposal / raising additional requirements on the proposal/decision on proposal	7 days	Date of receipt of the proposal or the date of receipt of any requirement called for, whichever is later
Post policy servicing requests	7 days	Date of receipt of (a) request, or (b) last necessary document, whichever is later
Requests for refund towards free look cancellation, surrender and withdrawal; refund of proposal deposit; refund of outstanding proposal deposit, if any	15 days	Date of receipt of request/last necessary document, whichever is later
Resolution of Grievance	14 days	Endeavor to provide a resolution on the Grievance within 14 Days of receipt of Grievance

Service Parameters	Maximum Turnaround Time (calendar days)	Turnaround Time to be Calculated From
Written communication of decisions on the proposal / raising additional requirements on the proposal	7 days	Date of receipt of the proposal or the date of receipt of any requirement called for, whichever is later
Requests for refund towards free look cancellation, surrender and withdrawal; refund of proposal deposit; refund of outstanding proposal deposit, if any	15 days^*	Time of receipt of call (working days)
Post policy Servicing requests	7 days	Date of receipt of (a) request, or (b) last necessary document, whichever is later
Resolution of Grievance	14 days	Endeavor to provide a resolution on the Grievance within 14 Date of receipt of Grievance

Process	Timeline
Filling up of proposal form	45 Days
Electronic copy of proposal form and payment acknowledgement	5 Days
One Time Password (OTP) for authentication	10 Minutes
KYC documentation	Customer relationship team will follow up on completion of proposal form
Medical scheduling	Customer relationship team will follow up on completion of proposal form
Acceptance of proposal form	15 days post completion of documentation & medicals, if any
Refund	15 days from the date of underwriting

1800 2666 3666

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Fraud Detection Policy

Revision History

1. Introduction

2. Objective and Policy Statement

3. Scope and Applicability

4. Review and approval of the policy

Procedures

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