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Anti-Fraud and Anti-Corruption Policy in Last Mile Solutions Network

1. Introduction 

Threeforce BV trading under the name of Last Mile Solutions (hereinafter “LMS”) is committed to upholding the highest standards of integrity, transparency, and accountability within the e-mobility market. This Anti-Fraud and Anti-Corruption Policy (hereinafter: “Policy”) establishes a zero-tolerance approach to fraud and corruption in all business activities, with particular focus on the risks inherent in e-mobility services, charging infrastructure, and user management. This Anti-Fraud and Anti-Corruption Policy is also meant to establish rules applicable within the LMS network and among LMS’ services users, to prevent and fight against fraud and corruption within the e-mobility market. 

This policy applies to all LMS’ contractors, consultants, suppliers, partners (including roaming partners), clients, owners or operators of the charging infrastructure within the LMS network and its users (end-users) using charging or other services within the LMS network, as well as e-mobility service providers cooperating with LMS (hereinafter collectively referred to as “covered persons“). 

 

2. Definitions

For the purposes of this Policy, the following definitions are aligned with the e-mobility market context: 

Fraud: Any intentional act or omission designed to deceive or mislead to obtain an unjust or illegal advantage in the e-mobility ecosystem. This includes, but is not limited to, manipulating charging sessions, Misuse of RFID cards, altering tariffs on charging points, and submitting false claims for reimbursement. 

In the context of Payment Service Directive 2015/2366 (PSD2), two different categories of fraudulent transactions can be distinguished: 

Unauthorized transactions; 

Transactions resulting from the manipulation of the payer by the fraudster. 

Corruption: The abuse of entrusted power in the e-mobility market for private gain, including Bribery related to charging infrastructure contracts, misuse of digital tokens, and collusion between market participants. 

Bribery: Corruption that involves offering, giving, receiving, or soliciting anything of value to improperly influence business decisions regarding charging infrastructure, partnerships, or e-mobility services. 

Misuse: Fraud that involves the improper use of e-mobility products or services, such as charging points or roaming networks, that may cause financial loss without constituting direct fraud. 

Unauthorized Use refers to any use of RFID cards, tokens, User IDs (UIDs), or Contract IDs for identity verification, charging sessions, or access to charging infrastructure that is conducted without proper authorization. 

 

3. Legal Framework and Compliance 

LMS ensures and requires from all covered persons compliance with all relevant national and international laws and regulations regarding anti-fraud and anti-corruption in the e-mobility market, including but not limited PSD2, PSD3 and NIS2 guidelines on fraudulent transactions in digital payments.  

LMS also adheres to industry-specific regulations, such as AFIR, ensuring compliance with reasonable tariff practices and data protection guidelines. 

All covered persons are obliged to observe the abovementioned regulations and guidelines, as well as LMS’ notifications based on them. 

Non-compliance with these laws and this policy may result in civil or criminal liability, as well as reputational damage that can affect LMS, other covered persons and other individuals or entities responsible. 

 

4. Responsibilities 

4.1. LMS 

LMS is obliged and obliges its employees, representatives, management, as well as any other persons acting on its behalf to: 

  • Follow anti-fraud and anti-corruption regulations, as well as any internal policies in this regard. 
  • Avoid and report any situations that could result in Fraud or Corruption related to charging infrastructure, user data, roaming or any other services. 
  • Implement effective internal controls to detect and prevent fraud and corruption in the e-mobility ecosystem. 
  • Promote ethical behaviour and compliance across charging operations, roaming networks, and business collaborations. 
  • Ensure that compliance programs include e-mobility-specific risks, such as Misuse of charging point tariffs or manipulation of roaming agreements. 
  • Monitor adherence to this policy, conducting risk assessments focused on e-mobility fraud risks, and investigating any reported allegations.  
  • Ensuring that actions are taken to protect the integrity of the LMS platform and partnerships. 

4.2. Charging infrastructure owners, operators, e-mobility service providers and other partners and their personnel 

Charging infrastructure owners, operators, e-mobility service provider and other partners are expected to: 

  • Follow anti-fraud and anti-corruption regulations and this Policy. 
  • Inform its personnel, subcontractors, suppliers and clients (including end users), that are engaged in its e-mobility activity, about this Policy and enforce it towards them. 
  • Avoid any actions that could result in Fraud or Corruption related to charging infrastructure, user data, roaming, or any other services, and immediately report any suspicious or fraudulent activities to LMS to prevent and prohibit further misconduct. 
  • Implement effective internal controls to detect and prevent Fraud and Corruption in the e-mobility ecosystem. 
  • Promote ethical behaviour and compliance across charging operations, roaming networks, and business collaborations. 

4.3. Charging infrastructure and e-mobility services users (end users) 

Charging infrastructure and e-mobility services users are expected to: 

  • Follow anti-fraud and anti-corruption regulations and this Policy. 
  • Avoid actions that could result in Fraud or Corruption related to charging infrastructure, user data, or roaming services.

 

5. Prohibition of any Fraud activity 

Any Fraud actions are strictly prohibited. This includes, among others: 

  • Fraudulent use of RFID cards, tokens or IDs e.g. 
  • Unauthorized use of third-party of improper User ID (UID) or Contract ID, used for identity verification.  
  • RFID card Misuse: e.g. sharing or copying them to perform fraudulent charging sessions​, the sale or distribution of RFID cards with unregistered or duplicated UIDs, using an RFID card for multiple simultaneous sessions or in different geographic locations within an unreasonably short timeframe. 
  • Use of any mechanical or electronic device to replicate a charge card or User Identification (UID) for the purpose of unauthorized access to charging stations. 
  • Bypassing or circumventing safeguards or verification procedures implemented to conduct safe transactions. 
  • Use of fake data, including creating fake accounts/users, CPOs or eMSPs, e.g. 
  • Using third party details. 
  • Creating an offer on a hub with the intent to deceive or mislead. 
  • Gaining unauthorized connections from eMSPs to access sensitive data. 
  • Harvesting token data or any other confidential information without explicit authorization. 
  • Utilizing harvested data to create fake profiles or engage in fraudulent activities. 
  • Fraudulent use of charging infrastructure e.g. 
  • Unauthorized alteration or replacement of QR codes on charging stations. 
  • Use of any charging point for activities other than the charging of electric vehicles (unless otherwise expressly agreed in writing). 
  • Alteration of CDRs after their creation. 
  • Opening private (home) charging point for roaming for guests and other third parties without explicit permission.  
  • Tampering with charging stations or their communication systems to disrupt operations, manipulate data, or enable unauthorized access. 
  • Fraudulent exploitation of tariffs e.g. 
  • Manipulation of charging point tariffs for financial gain i.e. manipulate, adjust, or alter the tariff rates of a charging point with the intent to obtain financial gain through improper or deceptive means, for personal or commercial financial gain, at the expense of the platform, eMSPs, or other users. 
  • Setting artificially high tariffs on charging platforms while using a different, lower flat-rate card to personally or commercially charge at their own station, with the intent to profit from the tariff disparity. 
  • Conceal or fail to properly publish the EVSE information, in violation of price transparency regulations, in order to deceive other users or entities. 
  • Setting tariffs which are against the law, in particular art. 5.3 and art. 5.4 of AFIR (in case of CPO) or art. 5.5 of AFIR (in case of eMSP).  
  • Embezzlement i.e. the theft or misappropriation of e-mobility infrastructure, assets, or data entrusted to an individual or organization for management or safekeeping. 
  • Unauthorized use of virtual tokens and payment deferment e.g. 
  • Create or allow to create virtual tokens, whether associated with correct, incorrect, fictitious, or nonsensical identifiers, and permit the use of such tokens for services or transactions prior to the payment of an associated invoice or the establishment of a prepaid account. It is prohibited to: 
  • Register a user as a customer and permit them to initiate transactions or charges without upfront payment, security deposit, or a prepaid wallet. 
  • Allow the user to accrue charges or utilize services via virtual tokens without first ensuring the user’s payment obligation has been met or sufficiently secured. 
  • Unauthorized use of a payment card or other payment method to pay on payment terminal or via app. 
  • Use of temporary credit cards, with the intent to avoid or evade payment obligations.  
  •  is done to evade payment and remove personal data. In this case, transaction records and contact details will be retained as required by financial regulations and standard privacy rules. 
  • Send CDRs for fake transactions. 
  • Requesting unauthorized reimbursement or settlement. 
  • False contest of an amount of CDRs, invoice or other. 

 

LMS employs real-time authorization monitoring to detect irregularities in the use of RFID cards, charging points, and digital tokens.  

This includes revenue monitoring to flag cards or charge points with unusual or suspicious activity. 

 

6. Prohibition of any Corruption activity 

Covered persons must not offer, give, solicit, or receive any gifts, hospitality, or other incentives that could be interpreted as intending to influence business decisions within the e-mobility ecosystem.  

Any Bribery or other Corruption is strictly prohibited.  

Facilitation payments (e.g., payments made to expedite services such as contract approvals) are strictly prohibited unless legally required. 

 

7. Reporting and Whistleblower Protection 

7.1. Reporting Allegations 

Covered persons are encouraged to report any cases or suspicions of Fraud or Corruption connected with LMS charging network, particularly in relation to charging infrastructure, roaming networks, or RFID misuse. Reports can be made through anonymous hotlines or directly by e-mail to supervisors or compliance officers, including LMS Compliance Officer/Team: 

  • Director Fraud & Roaming Peter van Zuylen  

email address: Fraud@Lastmilesolutions.com or peter.vanzuylen@lastmilesolutions.com  

  •  Head of Legal & DPO Ilenia Lombardo 

email address: ilenia.lombardo@lastmilesolutions.com 

The whistleblower policy of LMS applicable to whistleblower reports is accessible via LMS website and directly, at request. 

 

7.2. Whistleblower Protection 

LMS is committed to protect individuals who report violations of law that involve Fraud or Corruption in good faith from retaliation, harassment, or any other adverse actions. Retaliation is strictly prohibited, and violators will face disciplinary action. The identity of whistleblower is a subject of legal protection which LMS is legally obliged to ensure. 

 

7.3. Investigation and Confidentiality 

All reports of suspected Fraud or Corruption submitted to LMS will be investigated thoroughly by an internal LMS’ investigation team or external experts, if necessary. The investigation will maintain confidentiality, with the identities of the whistleblower, accused, and witnesses protected. 

 

8. Protection of safeguards  

All covered persons shall respect LMS’ safeguard measures implemented in order to execute this policy and anti-fraud and anti-corruption regulations. Such safeguards shall not be removed, circumvented, violated or improperly disclosed to any unauthorized third party. 

LMS, as well as charging infrastructure owners, operators, e-mobility service providers and other partners within LMS’ charging network are obliged to protect such safeguards and implement their own internal and external policies and control procedures mitigating the risk of Fraud and Corruption. 

 

9. Disciplinary actions and legal consequences 

Covered persons found in violation of this policy will face, depending on the situation and legal relationship with LMS: disciplinary action, termination and financial reimbursement for losses incurred by LMS or other parties, as well as suspension of the services, terminating access to the account, the hub or other services. In severe cases, legal proceedings, including claims for damages, penalties or other remedies, and criminal prosecutions may also be initiated. 

In relations with LMS’ partners, clients, suppliers and contractors, infringement of this policy or anti-fraud or anti-corruption legal regulations shall be a legal basis for termination of the contract or suspension of the services by LMS with immediate effect. 

Violation of this Policy shall be also the basis for suspending or terminating the access to the charging infrastructure, account, the hub or other e-mobility services, as well as claiming financial remedies from users (end users) responsible for such violation both by LMS and other e-mobility participants (like CPOs and eMSPs affected by such a violation). Such actions shall be also treated as material violation of terms of the services applicable to the service in question. 

The user who disclosed its UID or Contract ID assumes full responsibility for any consequences arising from unauthorized use of UIDs or Contract IDs. 

 

10. Training and awareness 

Where possible, towards its partners, LMS will provide trainings on anti-fraud and anti-corruption topics, particularly regarding the unique risks to e-mobility.  

Covered persons, if justified, may receive mandatory onboarding training, with periodic updates. Participation in such trainings is mandatory. 

Covered persons are required to familiarize themself with this policy and to instruct their own employees or other personnel (if applicable) accordingly. 

 

11. Implementation and Review of Policy 

11.1. Distribution 

This policy will be distributed to all covered persons involved in LMS’ e-mobility operations. In case of covered persons’ employees or other personnel, as well as their subcontractors, suppliers, partners and clients (in particular end users), this is the duty of a particular charging infrastructure owner, operator, e-mobility service provider or other partner, to distribute this Policy accordingly. 

11.2. Review 

This Policy will be reviewed to address changes in e-mobility market regulations and emerging fraud risks. Updates will be communicated to all relevant stakeholders.