- Introduction
Innoteq Engage Limited (“we”, “us”, “our” or “the Company”) is committed to conducting business with the highest ethical standards and in full compliance with all applicable laws and regulations regarding anti-money laundering (AML), anti-bribery, and anti-corruption practices. This policy outlines our commitment to preventing money laundering, bribery, and corruption in all forms and sets out the expectations for our employees, directors, contractors, and third-party partners.
- Policy Objectives
The objectives of this policy are to:
- Prevent the Company from being used for money laundering, bribery, or corruption.
- Establish clear procedures for identifying, reporting, and responding to suspected money laundering or bribery activities.
- Ensure that all employees and business associates understand their obligations and responsibilities under this policy.
- Promote a culture of transparency, accountability, and ethical conduct within the Company.
- Definitions
- Money Laundering: The process of concealing the origins of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses.
- Bribery: Offering, giving, receiving, or soliciting something of value to influence the actions of an individual in a position of authority.
- Corruption: The abuse of power or authority for personal gain, including but not limited to bribery, kickbacks, and other dishonest practices.
- AML Compliance
We are committed to preventing money laundering by following these key principles:
- Know Your Customer (KYC): We will implement and maintain appropriate KYC procedures to verify the identity of customers, clients, and business partners, particularly when establishing business relationships.
- Suspicious Activity Reporting: We will report any suspicious activities or transactions that may be linked to money laundering, fraud, or other criminal activities to the relevant authorities promptly.
- Ongoing Monitoring: We will ensure continuous monitoring of business relationships and transactions for signs of suspicious activities. This includes regular reviews of existing clients and transactions.
- Anti-Bribery and Anti-Corruption Commitment
We have a zero-tolerance policy towards bribery and corruption. The Company strictly prohibits:
- Offering, promising, giving, or receiving any form of bribe, kickback, or unlawful payment in relation to any business activity.
- Engaging in corrupt practices such as fraudulent misrepresentation, falsification of documents, or abuse of position for personal gain.
We expect all employees, directors, contractors, and third parties acting on behalf of the Company to:
- Refrain from offering, giving, or accepting bribes or other forms of illicit payments or benefits.
- Avoid any action or conduct that might give the appearance of bribery or corruption.
- Risk Assessment
We will regularly conduct risk assessments to evaluate the potential risk of money laundering, bribery, and corruption in the Company’s operations. These assessments will help us identify high-risk areas and put in place additional controls or due diligence measures where necessary.
- Reporting Obligations
- Employees: Employees must report any suspicion of money laundering, bribery, or corruption through our internal reporting channels, which include [email/helpline]. All reports will be treated with confidentiality, and no retaliation will be tolerated against anyone making a legitimate report.
- Third Parties: Contractors, suppliers, and business partners must immediately report any knowledge or suspicion of any bribery, corruption, or money laundering activities.
- Training and Awareness
We are committed to ensuring that all employees receive regular training on AML, anti-bribery, and anti-corruption policies and procedures. Training will be mandatory for new hires and will be refreshed periodically for all staff. The training will cover:
- Recognising and preventing money laundering and corruption risks.
- Reporting mechanisms and how to handle suspicious transactions.
- Legal consequences of non-compliance with AML and anti-bribery regulations.
- Due Diligence and Third-Party Relationships
We will conduct thorough due diligence before entering into relationships with third parties (e.g., contractors, suppliers, agents). This includes assessing the third party’s reputation, business practices, and financial stability to ensure that they adhere to our values and policies related to anti-money laundering, anti-bribery, and anti-corruption.
- Consequences of Non-Compliance
Failure to comply with this policy may result in disciplinary action, up to and including termination of employment or business relationships. In some cases, legal action may be taken. Non-compliance may also expose the Company to significant financial and reputational risks.
- Record Keeping and Documentation
We will maintain accurate records of all transactions and business activities that may involve the potential risk of money laundering, bribery, or corruption. These records will be kept for a minimum of Six (6) years to comply with relevant legal and regulatory requirements.
- Review and Monitoring
We will review and update this policy regularly to ensure it remains in compliance with applicable laws and reflects best practices in AML, anti-bribery, and anti-corruption. Monitoring and audits will be conducted periodically to ensure that all employees and business practices are in compliance with the policy.
- Contact Information
If you have any questions or concerns about this policy, or if you wish to report a potential violation, please contact with our Legal Compliance Department at: legal@innoteqengage.co.uk.
Last updated: 03/2025