Anti-fraud Policy

Anti-fraud Policy


Cimina Funghi does not tolerate fraudulent behavior in any way and undertakes to fully respect the ethical values established by the company Code of Ethics. Cimina Funghi expects all people affected by this Policy to share the same attitude and commitment.

Cimina Funghi promotes consistent behavior on the part of the organization through guidelines and assigning roles and responsibilities in the prevention, detection and investigation of alleged or actual fraud against Cimina Funghi.

This Policy aims to strengthen awareness and knowledge of the risk of fraud, and to improve the internal control system for the prevention and detection of fraud.


This Policy applies to all Cimina Funghi employees, as well as to consultants, suppliers, customers, and any other person who has relations with Cimina Funghi.


Fraud is defined as any illegal and intentional act characterized by deception, hiding, or breach of the relationship of trust, committed with the aim of obtaining an unauthorized and unfair benefit and / or damaging Cimina Funghi, mainly through:

  • Misappropriation of tangible and intangible assets;
  • Commercial fraud;
  • Corruption;
  • Fraudulent and untruthful representation of company facts.

Suspicions of potential fraud or irregularities can be communicated via email to:
Appendix 1 includes operating instructions for reporting.
The reports received, as well as the identity of the author of the report, will be treated as confidentially as possible; the Company undertakes to protect anyone who communicates suspected or real cases of fraud from retaliation actions.


Reports on potential fraud and irregularities must be reported using the e-mail address reserved and strictly confidential for this purpose When reporting the report, the following instructions must be followed:

  • Language: The communication can be made in the mother language of the person making the report.
  • Content: The report should include at least if possible information on:
    – Description of what happened;
    – Person (s) involved;
    – Value of the irregular / fraudulent transaction, if known.
  • Conduct: The report must be made in good faith.

Misappropriation of company assets: Misappropriation is the theft of company assets, both tangible and intangible. It can be done in different ways, and includes the appropriation of proceeds, the theft of company assets or money, or making the company pay for goods or services not received. Examples of misappropriations are:

  • Theft, destruction, removal, improper and / or personal use of money, data, materials, equipment or other company assets.
  • Disclosure of confidential and / or proprietary information to third parties.

Commercial fraud: Examples of commercial fraud are: counterfeiting, fraud relating to product quality and fraud against the consumer. These are actions carried out with intentionality and deception, in order to tamper with and alter products, counterfeit trademarks and proprietary rights of intellectual and copyright works, untruthfully represent the quality of the products, as well as in order to threaten health of consumers and damage the brands and reputation of Cimina Funghi.

Corruption: offering, giving, receiving, soliciting the receipt or offer of goods of value (money, gifts, or other advantages with a monetary value higher than the limit defined by the Code of Ethics and by the company policies on the receipt and offer of gifts and expenses representation) in order to influence the action of a public official, or a private person operating at any level of a private organization, obtaining an unfair and unjustified advantage; encourage Cimina Funghi investments in business where the company’s employees have economic and / or family interests (so-called conflict of interest).

Employee: any person who works full or part time, on the basis of a permanent or fixed-term employment contract, to provide Cimina Funghi with a continuous service in exchange for remuneration.

Fraud: It can be defined as:

  • Any intentional act or omission, aimed at deceiving and with the effect of causing a loss to the detriment of those who have suffered this act of omission, and / or a gain in favor of those who committed it.


  • Any illegal act characterized by deception, hiding, or violation of a relationship of trust. These acts are not necessarily carried out with the use of violence or physical force. Fraud is committed by people, entities and organizations in order to obtain money, ownership of goods, or services; to avoid payment or loss of services, and / or to secure a personal or financial advantage.

Fraudulent and untruthful representation of company facts:

  1. False in the financial statements: false and intentional statements or omissions of amounts in the financial statements, in order to defraud the recipients of the same, when this involves a representation of the material aspects of the financial statements, not in line with generally accepted accounting principles (GAAP) . This fraudulent activity can be carried out through:
  • Manipulation, falsification or alteration of accounting records or supporting documents, on which the preparation of the financial statements is based;
  • Untrue and correct representation, or intentional omission in the financial statements of events, transactions or other relevant information;
  • Intentional improper application of accounting principles in relation to amounts, classification or methods of representation.

False financial statements are not necessarily the result of sophisticated manipulation. In fact, management could justify an incorrect representation with an aggressive and yet indefensible interpretation of complex accounting rules, or as a temporary deviation from correct accounting principles, even in relation to intra-annual versions of the financial statements, to be corrected when improved conditions allowed it.

The above definition of false accounting also applies to managerial accounting and reporting for internal use.

  1. Fraudulent representation: it is the intentional untruthful representation of material facts, in the awareness of their falsity, and on which third parties rely, in order to induce them to act and consequently suffer damage. Fraudulent representation can also be implemented through the intentional failure to communicate material facts, the omission of which makes documents and statements misleading and deceptive.