Fraud Detection Policy

Introduction

The Insurance Regulatory and Development Authority of India (IRDAI), vide its Guidelines on Insurance e-commerce bearing number IRDA/INT/GDL/ECM/055/03/2017 dated 9th March 2017, mandates a proactive fraud detection policy for insurance e-commerce activities, approved by the Board of Directors of the Company. Accordingly, this policy has been formulated considering potential risks, including e-commerce fraud, to which Zanifest Insurance Broker Private Limited (hereinafter referred to as “the Company” or “Zanifest”) may be exposed. This policy provides clear guidance with respect to the prevention, detection, investigation, and mitigation of fraudulent activities related to e-commerce and general operations.

Objective

This policy is established to prevent, detect, investigate, and mitigate insurance fraud within the Company. It facilitates the development of structured processes to manage fraud risks, ensure robust organizational controls, and conduct thorough investigations. Zanifest is committed to conducting business with complete fairness and integrity, adopting a“Zero-Tolerance” approach to fraud.

Applicability

This policy applies to any actual or suspected fraud involving the Company's officials, directors, employees, shareholders, vendors, contractors, business associates, policyholders, assignees, claimants, nominees, and any external agencies doing business with the company. Any investigation activity will be conducted impartially, regardless of the suspected wrongdoer's length of service or title.

Classification of Insurance Frauds

In accordance with IRDAI Circular IRDAI/SDD/MISC/CIR/009/01/2013, fraud in insurance is defined as an act or omission intended to gain a dishonest or unlawful advantage for the party committing the fraud or related parties. Categories include:

• a. Internal Fraud: Fraud/misappropriation against the Company by a Director, Manager, employee, or internal stakeholder (e.g., embezzlement, fraudulent financial reporting, cheque forgery, overriding decline decisions, inflating expense claims, or illegal data use).
• b. Policyholder Fraud: Fraud against the Company during the purchase, execution, or servicing of a policy (e.g., staging incidents, claiming fictitious damage, fraudulent medical or death claims, unauthorized policy surrenders or switches).
• c. Third-Party & Online Frauds: Spurious calls, fake/forged policy documents issued by third parties, online payment card frauds, merchant non-remittance of premium, cyber security attacks, or phishing/data leakage.

Composition of Fraud Investigation Unit (FIU)

The Fraud Investigation Unit shall be headed by the Head of Claims & Support, who shall, based on the nature of fraud under investigation, include employees from different units on an ad-hoc basis for immediate support and assistance.

Identification and Reporting

All confirmed, attempted, or suspected frauds detected by any department or individual must be reported to the functional head and Fraud Investigation Unit within 48 hours from detection.

Reporting Mechanism

Investigation Powers & Awareness

The FIU and Principal Officer are entrusted with full authority to investigate all suspected/actual fraudulent acts, including inspecting company records, digital files, desks, storage, and premises without prior notice. Employees receive regular training on Anti-Money Laundering (AML) and Code of Conduct.