Privé Aero ("Privé Aero", "we", "us" or "our") is committed to conducting business honestly and to the highest standards of integrity. We have zero tolerance for fraud and are committed to preventing, detecting and responding to it. This policy applies to all directors, employees, agents, consultants, contractors and third parties acting for or on our behalf.
1. Purpose and Scope
This policy sets out our approach to managing the risk of fraud, the responsibilities of those working with us, and the procedures for reporting and responding to suspected fraud. It applies to all of our activities, including procurement, sales, finance and the handling of parts, documentation and payments.
2. What Is Fraud
Fraud is any intentional act or omission designed to deceive others, resulting in the victim suffering a loss or the perpetrator achieving a gain. In our sector this includes, without limitation, false or altered certification and traceability documentation, misrepresentation of the condition or origin of parts, false invoicing, payment diversion, bribery related fraud, theft, and manipulation of records.
3. Our Commitment
- We act honestly and fairly in all dealings and expect the same of everyone who works with us.
- We supply parts with accurate, verifiable certification and traceability, and we do not tolerate falsified or suspect unapproved parts.
- We maintain financial and operational controls designed to prevent and detect fraud.
- We investigate credible suspicions of fraud and take appropriate action.
4. Responsibilities
Management is responsible for establishing and maintaining effective controls to prevent and detect fraud within their areas. Everyone working for or with us is responsible for acting with integrity, complying with this policy and our procedures, and reporting any suspicion of fraud promptly.
5. Prevention and Controls
We apply proportionate controls to reduce the risk of fraud, including segregation of duties where practicable, verification of suppliers and documentation, authorisation controls over payments and changes to bank details, and record keeping that supports transparency and review. We verify part certification and traceability as part of our quality process.
6. Reporting a Concern
If you suspect fraud, or become aware of falsified documentation or suspect unapproved parts connected with us, report it at the earliest opportunity to management or to sales@priveaero.com. Reports made in good faith are treated seriously and confidentially. We will not tolerate retaliation against anyone who raises a genuine concern, even if it later proves to be mistaken.
7. Investigation
Credible reports are reviewed and, where appropriate, investigated in a fair and proportionate manner. We cooperate with regulators, airworthiness authorities and law enforcement where required, and we may report suspected unapproved parts to the relevant authority.
8. Consequences of Fraud
Any employee who commits or facilitates fraud may face disciplinary action, up to and including dismissal, as well as civil and criminal liability. We may end our relationship with any third party involved in fraud and pursue recovery of losses.
9. Review
We review this policy regularly and update it as needed. Questions can be sent to sales@priveaero.com.