Shuppy Limited (The Company) and ‘the Shuppy online marketplace platform’ (The Platform), takes a zero-tolerance approach to fraud, bribery, and corruption. We will uphold all applicable laws relevant to countering and investigating such activities. The company believes the cornerstone in preventing fraud is the creation of an environment that fosters morality, integrity and business conduct.
Fraud can be defined as: “Any illegal acts characterised by deceit, concealment, or violation of trust. These acts are not dependent upon the application or threat of violence or of physical force. Fraud is perpetrated by parties and organizations to obtain money, property, or services; to avoid payment or loss of services; or to secure personal or business advantage.”
Fraud may involve:
- Falsification or alteration of accounting records
- Misleading instructions for the collection and submission of Know Your Client (KYC) or Know Your Business (KYB) information
- Misappropriation of assets or theft
- Suppression or omission of the effects of transactions from records or recording of transactions without substance
- Intentional misapplication of accounting policies or willful misrepresentation of transactions or of the entity’s state of affairs
- Misappropriation of corporate or bank funds
- Misleading product or service description and visual representation
- Fraud may also involve manipulation of information system applications and data for personal advantage
Purpose & Scope
The purpose of this document is to:
- Understand The Platform system flow
- Outline the risks for fraud
- Name actions to prevent and limit these risks
Use of Platform
The Platform aids two types of users to meet and exchange in a business deal, Customers and Sellers. Customers can find & buy products, services & experiences and Sellers can list their products, services & experiences for Customers to buy. At the time of buying, the Customer must pay in full for the item(s) they have selected. This Payment is held in escrow until 14 days after the item(s) is dispatched when the funds are then transferred to the Seller and Shuppy Limited respectively. Any future returns or refunds are communicated & processed via the platform between the Seller & Customer.
Risks of Fraud
- A listing is created with fake images and in effect does not exist. The fraudster hopes to scam a potential Customer and gain funds by selling a non-existent product.
- A Shuppy representative verifies the Seller before they can sell on the platform and spot checks individual listing before they go live.
- Payouts are not transferred to Sellers until 14 days after items are dispatched to allow time for items to arrive with the Customer.
Fake Buyer and Seller Closed Loop Account Fraud
- A fraudster creates multiple fake buyer and seller accounts. The fake buyers pay the fake seller for nonexistent items using stolen credit cards.
- The Platform uses Stripe Connect Standard to process payments and verify both types of users before payments or payouts.
User Account Hijacked
- Unauthorised person takes over another User’s account to gain access to confidential User information.
- Hosting security, SSL Certificate, Recaptcha, Anti-Spam software and user sign in notifications help minimise the risk of unauthorised access to The Platform.
- The Platform does not store payment details such as credit card details, bank details, photo ID copies on The Platform’s hosting server. This information is collected via the payment provider’s (Stripe Connect Standard) API.
The management personnel of the Company constitute the front line of monitoring and preventing fraud. Managers are responsible to monitor business activities of staff and be aware of and alert to potential signs of fraud.
Employees, Consultants or Contractors (Staff)
Staff are responsible to act at all times with the highest degree of honesty, integrity, accountability, and propriety. Staff should conduct their duties in a manner the does not jeopardize, to the contrary, safeguards the Company’s resources and assets.
As a platform, using software technologies and our technical support team we aim to do our due diligence in preventing fraud by:
- Maintaining a secure platform
- Supervising the behaviour of our customers on our platform
- Analysing the refusal codes: a short message is associated with refusal codes to provide more details of the reason for the refusal
- Creating alerts and/or trigger 3D Secure according to users’ activity and/or irregular behaviours, for example: if a first-time user is paying more than the average basket value
- Per default, only allow pay-outs after items are dispatched
- Not process or validate any pay-outs for Sellers who are not KYC approved
- Accepting the standard 3D Secure trigger which will ensure 100% of transactions over €50 will be redirected to the issuing bank’s dedicated page to complete an extra security step
- Notifying Shuppy Hereupon detection of unusual behaviour or transactions
Anyone with information regarding fraud or other corrupt practices against the company or involving the company staff, is strongly encouraged to report this information by contacting us with any complaints here and will not be retaliated against for submitting such claim in good faith.
Depending on the nature, magnitude and the complexity of the fraud, investigations will be carried out by either the company’s counsel or by an external firm with specific expertise to deal with the particular allegation. Investigations will be conducted without regard to any person’s relationship to the organization, position or length of service. The investigating party will have full access to any files, information or witnesses to conduct the investigation and will keep records of all actions in the investigation, to ensure success in any future criminal, civil or disciplinary action. The investigating party will issue a report detailing the finding and conclusion of the investigation, including recommendations for future action. The company will inform other parties, including affected staff or external partners. In cases of substantiated fraud, Shuppy Limited will pursue disciplinary or criminal sanctions where appropriate and possible and will attempt to recover losses by any lawful means.