It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure..

The Company has adopted a risk based approach to AML. For the Customers to whom the Company provides services, this is demonstrated through the categorisation of their individual Clients during initial KYC checks and the subsequent monitoring of transactions that is then deployed. In general the Company takes the view that it has no appetite for breaches in laws and regulations related to Financial Crime, recognising that whilst incidents are unwanted, they cannot be entirely avoided.

Similarly, when providing services to Customers, the Company will establish KYC Procedures to identify and manage money laundering risk of the Customer’s Clients and ensure that the Customer reasonably knows its Client at the time of onboarding, and through the life cycle of the Client relationship.

This policy does not form part of any employee’s contract of employment and we may amend it at any time. It will be reviewed regularly.