David Lloyd Leisure Failure to Prevent Fraud Policy

This policy:

1. Sets out David Lloyd Leisure’s approach to the corporate offence of failure to prevent fraud, as introduced by the Economic Crime and Corporate Transparency Act 2023.
2. Is reviewed at least annually; and
3. Is endorsed by the Deuce Midco Limited Board. The Board does not condone fraud in any form and is responsible for fostering a culture of compliance and integrity

What is the purpose of the FTPF Policy?

The purpose of this Failure to Prevent Fraud Policy is to communicate David Lloyd Leisure’s commitment to preventing fraud in accordance with the Economic Crime and Corporate Transparency Act 2023. The policy aims to ensure that David Lloyd Leisure does not engage in, facilitate, or tolerate fraud of any kind, whether in the UK or overseas.

Fraud is a criminal offence and includes acts such as false representation, failing to disclose information, abuse of position, false accounting, and other fraudulent activities as defined by law.

Who does the Failure to Prevent Fraud Policy apply to?

This policy applies to all Associated Persons of David Lloyd Leisure, as defined by the Economic Crime and Corporate Transparency Act 2023. An "Associated Person" includes all individuals and entities who represent, or provide a service for or on behalf of, David Lloyd Leisure. This includes, but is not limited to, Directors, employees, contractors, agents, self-employed professionals, and, in some cases, external suppliers.

All Associated Persons are responsible for adhering to this policy

What David Lloyd Leisure is doing

• David Lloyd Leisure has implemented reasonable and proportionate fraud prevention procedures, including risk assessment, due diligence, and training, to support the effective implementation of this policy.
• David Lloyd Leisure complies with all relevant legislation.
• David Lloyd Leisure will report any known or suspected fraud to the relevant external authorities, as required by law.

What you need to do as a David Lloyd Leisure team member

1. Complete all required training on the Failure to Prevent Fraud.
2. Be vigilant and aware of potential fraud risks. If something appears suspicious or “too good to be true”, it should be treated with caution.
3. Follow all company procedures, such as supplier onboarding, due diligence, and risk assessment processes.
4. Report any known or suspected fraud to David Lloyd Leisure’s Whistleblowing hotline. All reports will be treated confidentially.

If you facilitate fraud, or fail to report known or suspected fraud, you may be subject to company disciplinary proceedings, which may be treated as gross misconduct. You may also be subject to criminal proceedings under the Economic Crime and Corporate Transparency Act 2023.