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Anti-Fraud, Bribery and Corruption Policy


This statement is made on behalf of APEX Global Sport Group. References to “we”, “us” or “our” in this statement are to APEX Global Sport Group.  This document sets out the APEX Global Sport Group policy for detected - or suspected - fraud and incorporates best practice within the field regarding counter-fraud measures.


  • Fraud  is theft by deception. It is any deliberate intent to permanently deprive a person or organization of money or goods through the falsification of any records or documents.

  • Bribery is the accepting of gifts, money, hospitality or other favors in return for providing something of value to the briber

  • Corruption is where someone is influenced by bribery, payment or benefit in kind to unreasonably use their position to give some advantage to another.

  • Theft includes any misappropriation, stealing, malicious damage, and actual or attempted break-in.


APEX Global Sport Group has procedures in place that reduce the likelihood of fraud, bribery or corruption occurring. These include: procedures, rules and regulations, a system of internal control and a system of risk assessment.

Although APEX Global Sport Group directors hold shared responsibility for preventing fraud, bribery and/or corruption, all APEX Global Sport Group associates and other individuals have a part to play.

APEX Global Sport Group is committed to maintaining an honest and open atmosphere within the organization. It is therefore also committed to the elimination of any fraud, bribery or corruption and to the rigorous investigation of any such cases. 


APEX Global Sport Group expects anyone having any reasonable suspicions of fraud, bribery or corruption in relation to our activities to report them.  We recognize that whilst cases of theft are usually obvious, cases of fraud, bribery or corruption are harder to prove.

It is also APEX Global Sport Group policy that no individual will suffer in any way as a result of reporting reasonably held suspicions. 


Roles and Responsibilities

This section states the roles and responsibilities of associates in reporting fraud, bribery or corruption.

Associates are expected to act in accordance with APEX Global Sport Group rules regarding Conflicts of Interest. Associates also have a duty to protect the assets of APEX Global Sport Group, including information and goodwill as well as property, tangible and intangible.

APEX Global Sport Group policies, procedures, rules and regulations place an obligation on all associates to act in accordance with best practice.

All cases of theft, actual or suspected fraud or corruption, must be reported to one of the Directors of APEX Global Sport Group. If the case - or suspected case - in question relates to one of the Directors, it should be reported to the other two Directors. 

Any personal or family interests in any corporate bodies which do business with APEX Global Sport Group, or to which APEX Global Sport Group have submitted or is planning to submit, a business proposal, shall be formally declared.

For the record, and for openness and scrutiny, a Register of Interests shall be maintained, in which the interests of those persons referred to in this section shall be declared in writing. Written disclosures shall be entered in the Register, which shall be maintained by the Directors.

Reporting Fraud, Bribery or Corruption

This section outlines the action to be taken where fraud, corruption or other illegal acts involving dishonesty, are discovered or suspected. Reporting of all frauds and irregularities is essential to ensure:

  • consistent treatment of information;

  • proper investigation by an independent and experienced team;

  • the optimum protection of APEX Global Sport Group interests.


Any actual or suspected instance of fraud or corruption must be reported to the Directors immediately, with copies of any documents which are relevant. It is essential that individuals act at the time of their concerns, as time is likely to be of the utmost importance to prevent further loss to APEX Global Sport Group. However, individuals must not confront any individual that they suspect directly, nor should they contact the police directly.

If the suspicion involves a Director, the matter should be reported to the other two Directors.


Where financial impropriety is discovered, APEX Global Sport Group expectation is that the police will be involved.

Warning Signs

Whilst by no means being proof on their own, the circumstances below may indicate fraud, and should therefore raise suspicions:

  • altered hard copies of documents (correcting fluid, different pen or handwriting);

  • claim form details not readily checkable;

  • changes in normal patterns, e.g. of travel claim details;

  • text erratic or difficult to read or with details missing;

  • delay in completion or submission of claim forms;

  • lack of vouchers or receipts in support of expense claims, etc;

  • complaints from the public or from other associates;

  • insistence - on the part of a Director or other associate - on dealing exclusively with a particular individual or corporate client personally.

Revision of Policy

APEX Global Sport Group reserves the right to amend and/or withdraw this policy from time to time for any reason, including without limitation, to take account of changes in best practice and/or operational requirements.


APEX Global Sport Group. February 2022

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