ANTI-MONEY LAUNDERING

Policy Statement

We are committed to preventing money laundering and complying with all relevant laws and regulations.

We have a zero-tolerance approach to money-laundering and have implemented measures and procedures in place to detect and prevent activities associated with money laundering and terrorist financing.

This policy does not form part of any employee’s contract of employment, and we may amend it at any time.

Definition

Money laundering is the process of concealing the origins of illegally obtained funds, typically by means of complex financial transactions to make them appear legitimate. This criminal activity often involves three stages: placement, layering and integration.

Prevention of Money Laundering

We have a number of money laundering prevention and detective measures that are implemented across the company and are not limited to:

Customer Due Diligence

 We verify the identity of customers and beneficial owners through reliable documentation

• Where required, we conduct thorough background checks on clients assessing their risk profiles

Transaction Monitoring

 Implementing real-time monitoring systems to detect unusual or suspicious transactions

• Establishing thresholds for transaction amounts that trigger additional scrutiny

Record Keeping

•  Maintaining comprehensive records of customer transactions and due diligence efforts

Procedure

All employees are required to remain vigilant with regard to acts of suspected money laundering. Any suspicious activity must be reported immediately to your Manager. Failure to report any suspicious activity may result in disciplinary action up to and including dismissal. If you are in any doubt as to whether any activity is suspicious or not, you must speak to your Manager for clarification before taking the matter to an outside body in line with our Whistleblowing Policy.

Where there is knowledge or suspicion of money laundering taking place, a report will be made to the National Crime Agency (NCA)

Safeguarding Concerns

We recognise that the decision to report a concern can be a difficult one to make and we will support you during the process.  We will not tolerate any harassment or victimisation (including informal pressures) and will take appropriate action to protect you when you raise a concern to us in good faith.

Every effort will be made to keep disclosures under this policy confidential, at least until a formal investigation is underway in line with our Whistleblowing Policy.

Consequences of Money Laundering

Employees found to be involved in facilitating money laundering activities will be subject to disciplinary action, which may lead to your summary dismissal.

Untrue Allegations

If you make an allegation, but the investigation does not confirm it, no action will be taken against you. If, however, you make an allegation maliciously, vexatious, or for personal gain, disciplinary action may be taken against you and, dependent upon the circumstances, this may be treated as Gross Misconduct.

Communication and Awareness

All employees where relevant will receive regular training on how to prevent and detect money laundering and how to recognise potential red flags.

All employees will be updated on emerging money laundering trends and techniques where relevant.

Our zero-tolerance approach to money laundering will be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.