CMA Financial Corporation (“CMA”) is committed to maintaining the highest possible standards of ethics, openness, and honesty.

CMA is dedicated to ensuring that its employees and officers conform with the highest ethical standards and to reducing the risk or possibility of fraud and corruption.

The Strategy is intended to raise the profile of the standards of conduct expected of both employees and officers of CMA. This strategy identifies the relevant documents and actions to be taken by employees and officers in the event of any suspected violation of the policy and sets out the main principles for countering fraud and corruption.

Employees and officers should play a key role in counter-fraud initiatives. This includes proving a corporate framework within which counter-fraud arrangements will flourish, and the promotion of anti-fraud culture across CMA. This should provide a sound defense against internal and external abuse of the many state and Federal laws that govern CMA’s everyday business activities. CMA’s employees and managers are CMA’s best defense in preventing and detecting fraud and corruption.


In addition to CMA’s employees and officers, CMA also expects that individuals and organizations (e.g. agents, suppliers, consultants, contractors, and service providers) that it deals with will act with integrity and without thought or actions involving fraud and corruption. Where relevant, CMA will include appropriate clauses in its contracts about consequences of fraud and coercion; evidence of such acts are most likely to lead to a termination of the particular contract and may lead to prosecution.


The relevant definitions are as follows:

3.1  Fraud is the use of deception to obtain an unjust or illegal financial advantage. It may involve the “intentional distortion of financial statements or other records by persons internal or external to the organization, which is carried out to conceal the misappropriation of assets or otherwise to gain.” Fraud includes not only dishonest acts committed by employees and officers but also acts perpetrated against CMA by affiliated or non-affiliated third parties.

3.2  Corruption is the unlawful “offering, giving, soliciting or acceptance of an inducement or reward which may improperly influence the action of any person”, whether by an officer, employee, or third party.

3.3  This policy also covers the failure of officers, employees, or third parties to disclose an interest in order to gain financial or other benefit.


CMA has a duty to comply with Federal and state requirements and accordingly CMA has in place a number of documents that in themselves are relevant to the officers, employees, or third parties in conducting business in a manner that will prevent fraud and corruption. Senior management maintains these documents which can be reviewed at the request of an officer, employee, or third party.


CMA fully expects its officers and employees to comply with the principles and standards of this Policy in public life. These general principles of conduct are as follows:

• Selflessness
• Honesty and Integrity
• Objectivity
• Accountability
• Openness
• Personal Judgment
• Respect for Others
• Duty to Uphold the Law
• Stewardship
• Leadership

Responsibility for the anti-fraud culture is the joint duty of all those involved with CMA. The Policy should be directed against fraud and corruption whether it is attempted against CMA from outside or from within CMA’s own workforce.

CMA expects that employees and officers at all levels will lead by example in ensuring adherence to legal requirements, financial rules of procedure, codes of conduct, procedures and practices.

As part of this culture, CMA will provide clear routes by which concerns can be raised by both officers and employees and those outside who are providing, using or paying for CMA services. See paragraphs 7.3 below for the available routes for raising any concerns for the particular groups (i.e. officers, employees, and third parties).

Senior Management is expected to deal swiftly and firmly with those who defraud CMA or who are corrupt. Senior Management should be robust in dealing with financial malpractice.


7.1  Although this document specifically refers to fraud and corruption, it also equally applies to all financial malpractice. This includes a wide range of irregularities and criminal acts that are financial or finance-related. It includes for example the criminal acts of theft of “property”, which includes all assets and cash; false accounting; obtaining by deception; financial advantage by deception; computer abuse and computer crime. Also, it includes bribery and corruption. Employees and officers can be exposed to a number of “pressures”, from business associates, clients, and other members of CMA’s industry to act in a particular way in a particular case.

7.2  Employees and officers are an important element in CMA’s stance on fraud and corruption, and they are positively encouraged and expected to raise any concerns that they may have on these issues where they are associated with CMA’s activities.

7.3  Employees should contact the President should they wish to raise any concerns. Officers should normally raise concerns through their immediate line manager; however, it is recognized that they may feel inhibited in certain circumstances. In this case officers should contact either of the following CMA corporate attorney so appropriate actions can be made to protect the interest of the shareholders of CMA:



Members of the public or clients are able to raise concerns by way of writing to the CMA President. This correspondence should be marked as 'Private and Confidential' and sent appropriately to the following address:



7.4  Concerns will be treated in confidence, properly investigated and dealt with fairly. Those concerns raised anonymously will be investigated; however, it must be recognized that it may be necessary for the individual who raised the concern to come forward as a witness.

7.5  There is of course, a need to ensure that any investigation process is not misused; therefore, any internal abuse, such as raising malicious or vexatious allegations, may be dealt with as a disciplinary matter.


8.1  CMA’s employee and agent agreements detail a number of procedures and protocols that set out the framework for dealing with the everyday affairs of CMA and, as such, each employee and agent has a duty to comply with these provisions.

8.2  For officers, employees, and agents, appropriate procedures have been documented to ensure fairness and impartiality towards customers and those with whom CMA does business regarding the acceptance of fees or money connected in any way with CMA employment and declaring any possible conflicts of.

8.3  Managers are responsible for ensuring that adequate controls exist within financial and operational systems and that officers are adequately trained in operating the systems and procedures. All systems should be reviewed and developed in line with best practice to ensure efficient and effective internal controls exist. A system of internal control provides a framework for ensuring that assets are safeguarded, transactions are properly authorized, duties are segregated and material errors or irregularities are prevented or detected.

8.4  The adequacy and appropriateness of CMA’s financial and operational systems are independently monitored and assessed by both the President and CMA’s accounting firm. Senior Managers are expected to consider and act upon those audit recommendations made.

8.5  Employment recruitment is required to be in accordance with procedures laid down by CMA’s Senior Managers. In particular, appropriate measures such as pre-employment background screening must be obtained to confirm the honesty and integrity of key employees before being hired.


9.1  CMA will be robust in dealing with any financial malpractice, and will deal promptly and thoroughly with any person who attempts to defraud CMA or who emerges in corrupt practices, whether they are agents, officers, employees, consultants, contractors or other affiliated or non-affiliated third parties.

9.2  All suspicions of fraud and corruption must be reported to the appropriate named persons as detailed at paragraph 7.3 above. At the time of receiving the concern, the President or CMA corporate attorney will appoint an Investigation Officer who will undertake the investigation.

9.3  If there has been a criminal activity, for public accountability and deterrence reasons CMA will notify the Police. The President will notify the Police where this is appropriate or necessary.

9.4  CMA may engage in disciplinary procedures or legal action when the outcome of an investigation indicates improper behavior on the part of officers.

9.5  Where loss has been suffered through fraudulent activity, CMA will pursue the perpetrator for recovery, including taking appropriate legal action.


10.1  In the majority of cases, it is the diligence of officers, employees, and managers that detects acts of fraud and corruption.

10.2  The public may raise concerns by mailing CMA’s President. Contact details are the same as those detailed for the CMA President at paragraph 7.3 above.

10.3  Where circumstances justify it, surveillance (covert or otherwise) can be carried out.


11.1  CMA recognizes the importance of training in the delivery of high quality services. CMA supports the concept of fraud awareness training for managers and all staff involved in internal control systems to ensure that their responsibilities and duties in respect are regularly highlighted and reinforced. CMA will have periodic awareness training sessions.

11.2  Periodic training seminars will be provided for employees, managers, and agents on a wide range of topics including some that have direct and indirect links to the subject of fraud and corruption.

11.3  CMA will ensure that the existence of this Policy and its application are available for employees, managers, agents, and the public.


12.1  CMA reserves the right to make written changes to this Anti-Fraud and Corruption Policy upon immediate written or email notice. Notice of such a policy change posted on CMA’s corporate website is sufficient to satisfy this section.