FINANCIAL CRIME COMPLIANCE

OUR COMMITMENT

TASConnect’s ambition is to tackle some of today’s most damaging crimes by making the financial system a hostile environment for criminals and terrorists.

Principles

The following principles reflect the minimum expectations of TASConnect.

  • Zero tolerance approach to Bribery and Corruption and will not tolerate the giving, offering, promise or receipt of bribes in any form, including kickbacks, by any person on its behalf, or for whom it is responsible, whether directly or via another party. TASConnect also takes its responsibility to counter the risk that it might be used to further financial crime (including crimes involving fraud or the laundering of the proceeds of such crimes) extremely seriously.
  • TASConnect ensure the business is backed by robust financial crime compliance efforts that address the inherent risk of the people, companies and markets that we serve.
  • Risk-based approach to an effective financial crime compliance (“FCC”). TASConnect allocates responsibilities for Financial Crime risk in a manner consistent with the three Lines of Defence model described in our Enterprise Risk Management Framework

ANTI-MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM PROGRAMME

Money Laundering is the process by which criminals attempt to hide and disguise the true origin and ownership of the proceeds of their criminal activities and thereby have these funds enter the normal economy to make it seem as if they have been obtained legitimately.

SANCTIONS COMPLIANCE PROGRAMME

TASConnect complies with all applicable sanctions through the FCC initiative. TASConnect has also established internal prohibitions and restrictions on certain types of business which are not prohibited by applicable sanctions but are imposed through TASConnect’s Policy based on certain risk decisions designed to minimise the potential of sanctions breaches and related risk.

TASConnect will not enter business of any kind, directly or indirectly, involving or for the benefit of Sanctioned Parties unless permitted. The prohibition applies even where such dealings would be permitted by applicable law.

Where parties are listed as the target of Sanctions by countries or organisations other than the UN, EU, UK or US, TASConnect and staff must comply with these sanctions if they apply to them and their business. Any potential conflicts of law must be escalated.

TASConnect will not enter business of any kind, directly or indirectly, involving or for the benefit of any person or entity located in a Sanctioned Country or Territory or with the government of that country or leadership of the territory, including all its agents, agencies, departments, and instrumentalities wherever they are in the world, unless otherwise permissible.

TASConnect has established Client Due Diligence standards to identify sanctions risk and ensure that TASConnect reasonably knows its client at the time of onboarding, and through the life cycle of the client relationship.

ANTI-BRIBERY AND CORRUPTION (“ABC”) PROGRAMME

Bribery and Corruption have a significant adverse effect on the social and economic development of the communities in which TASConnect operates. TASConnect adopts a zero-tolerance approach to Bribery and Corruption and will not tolerate the giving, offering, promise or receipt of bribes in any form, including kickbacks, by any person on its behalf, or for whom it is responsible, whether directly or via another party. TASConnect also takes its responsibility to counter the risk that it might be used to further financial crime extremely seriously.

TASConnect will not engage in Bribery or Corruption activities or create the appearance of Bribery and Corruption and are prohibited from:

  1. Giving and Receiving of Bribes
  2. Giving or accepting Anything of Value of a person promising or asserting the ability to improperly influence a Public Official
  3. The use of employment opportunities when vetting or hiring staff to obtain or retain business or a business advantage, or to influence a Public Official
  4. Gifts and Entertainment (unless permitted)
  5. Sponsorship and Donations (unless permitted)

FINANCIAL CRIME COMPLIANCE RELATED INITIATIVE

TASConnect is working hard to ensure the business is backed by robust financial crime compliance efforts that address the people, companies and markets.

Financial Crime Risk related principles:

  • Establish policies, operating standards, and control processes reasonably designed to create compliance with applicable legal and regulatory requirements and in line with risk assessment.
  • Comply with all applicable legal and regulatory requirements.
  • Support governments, law enforcement agencies and international bodies in combating financial crime.
  • Apply a high-level risk assessment.

 

©TASConnect

ENTERPRISE RISK MANAGEMENT

The Enterprise Risk Management (“ERM”) function is responsible for providing TASConnect’s Board and Management with a comprehensive and independent assessment of the risk exposure of the Company, effectiveness of the risk mitigation and management activities, and summary of the risk limits and utilisation. These activities effectively create an oversight function that provides a second line of defense to all other risk and control functions of the Company.

STRATEGY AND STRATEGIC RISK MANAGEMENT

TASConnect adopts the following principles to direct its risk management. The principles are reinforced by the Company’s risk culture, to identify and assess current and future risks, discuss these risks, and take prompt actions.

TASConnect will strive to balance the relationship between growth, risk and return. While there is often a tendency to focus on additional mechanisms for reducing risk, there may be opportunities to accept greater risks so long as the additional risk levels are understood and managed.

TASConnect’s ERM process begins with the statement of risk appetite (“RA”) and the setting of strategic, financial, and other business objectives during the planning and budgeting process. These objectives cascade through to lines of business, as appropriate. Management will assess if there is an effective alignment of the proposed long-term strategic objectives with the risk appetite approved by the Board. The strategic plan also includes a risk dimension through evaluation of forecasts and scenarios and outlines appropriate risk mitigation strategies. These objectives cascade through to lines of business, as appropriate.

  1. Balancing risk and return – TASConnect is required to manage risks within its approved Risk Appetite and maintain a low probability of an unexpected loss event that would materially undermine the confidence of its clients, external stakeholders, and investors;
  2. Conduct of business – TASConnect is required to demonstrate strong conduct, to be mindful of the reputational consequences of inappropriate conduct; and to achieve fair outcomes for clients, investors, and the markets in which TASConnect operates, while abiding by the spirit and letter of applicable laws and regulations;
  3. Responsibility and accountability – risk taking activities are disciplined, transparent, controlled and focused, particularly within its authorities;
  4. Anticipation – TASConnect seeks to consider future material risks to learn lessons from events that have produced adverse outcomes, and to increase awareness of known risks; and
  5. Competitive advantage – TASConnect seeks to achieve competitive advantage through efficient and effective risk management.

1.RISK APPETITE

As a key to maintaining an acceptable level of risk in light of the financial and strategic objectives of the Company, TASConnect will function within the approved risk appetite and limits of the Board. To support this framework, the ERM functions sets and enforces limit triggers and escalation policies that are consistent with the Board-approved risk appetite.

TASConnect’s risk appetite is the approved boundary for the risk that TASConnect is willing to undertake. It is set within the risk capacity which is defined as the maximum level of risk that TASConnect can assume, given its current capabilities and resources, before breaching constraints determined by capital and liquidity requirements, internal operating environment, or otherwise failing to meet the expectations of regulatory authorities and law enforcement agencies.

2.CONDUCT RISK MANAGEMENT

It is important for TASConnect to manage Conduct Risk in order to deliver positive outcomes to investors, shareholders, counterparties, employees, markets, and competition, and provide all employees with a fair and safe working environment that is free from discrimination, exploitation, bullying, harassment, or inappropriate language.

TASConnect will be responsible for ensuring that the employees identify, mitigate, and monitor Conduct Risk.

TASConnect must demonstrate that Conduct Risk is considered when making material strategic decisions that may impact clients, investors, shareholders, counterparties, employees, markets, and competition.

3.THREE (3) LINES OF DEFENCE

The primary responsibility for the ERM function is to ensure it is conducting its monitoring and oversight role adequately across all risk types.

TASConnect’s processes must implement a maker-checker model with roles and responsibilities outlined below:

Table 1: Risk Management Activities

Role Definition Key Responsibilities
First Line The business or function engaged in or supporting revenue generating activities who own and manage the risks in these activities.
  1. Identify and propose the risks required to undertake the revenue generating activities.
  2. Identify, assess, monitor and escalate risks and events to Second Line and the management team.
  3. Set and execute risk remediation plans.
  4. Own and design processes, controls and standards for adhering to Frameworks and Policies set by the Second Line.
  5. Validate and self-assess compliance to Policies and Standards, confirm the quality of validation, and provide evidence-based affirmation to Second Line (where relevant).
  6. Ensure that applicable laws and regulations are being complied with and escalate significant regulatory non-compliance matters and developments to the Second Line and Senior Management.
  7. Promote a healthy risk culture and good conduct.
Second Line The control functions independent of the First Line that provide oversight and challenge of risk management.
  1. Review First Line proposals and make decisions to approve or reject as appropriate.
  2. Oversee and challenge First Line risk taking activities.
  3. Own processes for setting Policies and Standards and monitoring compliance to the same.
  4. Own and manage processes for oversight and challenge.
  5. Intervene to curtail business if activities are not in line with RA, there is material non-compliance with policy requirements, or when operational controls do not effectively manage risk.
  6. Identify, assess, monitor and escalate risks and events to the ERC and to the Board.
  7. Review and challenge risk remediation plans set by the First Line to mitigate RA breaches or events.
  8. Ensure there are appropriate controls to comply with applicable laws and regulations. Escalate significant regulatory non-compliance matters and developments to ERC, Board and Management Team.
  9. Promote a healthy risk culture and good conduct.
Third Line The internal audit function provides independent assurance on the effectiveness of controls that support First Line’s risk management of business activities, and the processes maintained by the Second Line.
  1. Independently assess whether management has identified the key risks in the business and whether these are reported and governed in line with the established risk management processes.
  2. Independently assess the adequacy of the design of controls and their operating effectiveness.

4.REPORTING AND BREACH HANDLING PROCESS

4.1 For escalation-level breaches, the business (First Line) is to inform the ERM function and the respective Risk Framework Owner (“RFO”) to agree on treatment plans. The escalation-level breach together with the treatment plans must be tabled at the ERC for tracking until completion of the treatment plans and the RA Metric is no longer in breach.

4.2 For RA breaches, the business (First Line) is to inform the ERM function and respective RFO as soon as possible. This will be considered as a Material Event and requires further escalations in accordance.

4.3 Treatment plans for a RA breach are to be formulated within 72 hours of breach discovery. The treatment plans must be endorsed by the RFO and SCV RFO and approved by the Board. Treatment plans must be presented to the next ERC and the Board and must be tracked by these governance bodies until closure.

5.RISK PROFILE

TASConnect’s risk profile provides a complete and forward-looking profile of the elevated inherent risks that TASConnect is exposed to. It contains the following elements:

  1. A Process Universe that outlines the key operational elements and processes to deliver the client experience for the service/product offered by TASConnect.
  2. Inherent risk assessment conducted by the First Line (Process Owners) to identify and assess the inherent risks at each stage of the Process Universe. The Second Line (RFO/SME) approves the said risk assessment performed by the First Line.
  3. Controls are designed and installed to mitigate the inherent risks. First Line monitors the effectiveness of the controls through Key Control Indicators (“KCIs”) and/or Control Sample Tests (“CSTs”) to provide early warning of potential problems. This approach is an ongoing exercise to reflect on the latest risk exposure of TASConnect.
  4. Residual risks are assessed by the First Line (Process Owner) taking into account the design and operating effectiveness of controls implemented. The Second Line (RFO/SME) approves the residual risk assessment performed by the First Line (Process Owners).

6.RISK GOVERNANCE AND OVERSIGHT

This ERM framework is a unifying framework that is consistent with, and supported by, the Company’s values of integrity, team, service excellence, and winning. This ERM philosophy directs all of the TASConnect’s ERM activities and enables management to clearly understand the tradeoffs between risk and return in decision making.

Risk will be measured, either qualitatively or quantitatively, relative to specific performance measures associated with the objectives, whether financial, operational or otherwise, to be actionable. By using the same, or a congruent, unit of measure established for their objectives, the results are more meaningful to management and reduce the need for the development of separate measures. In doing so, ERM becomes embedded into management processes.

Effective ERM requires appropriate and timely information that supports management decisions.

6.1 First and Second Line staff to undertake regular horizon scanning to identify and monitor the impact of emerging risks to learn lessons from events that have produced adverse outcomes, and to raise awareness of known risks.

6.2 Risk management reports will contain risk information that allows TASConnect to appropriately identify, monitor and report on material risks.

6.3 Management must promptly escalate the following Material Events:

      1. any breaches,
      2. any events or issues,
      3. any residual risks, and
      4. any other issue.

 

©TASConnect

CODE OF CONDUCT

1.THE COMMITMENT TO HONEST AND ETHICAL CONDUCT

Why the Code matters

The Code is important because it outlines how TASConnect makes sure that the decisions TASConnect makes are the right ones.

Act responsibly and within the authority

TASConnect must be disciplined, responsible and take accountability for the risks the Company takes. When taking risks, they must be within the delegated authority and must be appropriate to the business area or activity. TASConnect’s policies are in place to help understand what limits and safeguards are in place.

Use good judgment

TASConnect recognise that employees may face complex situations which don’t have simple, clear-cut solutions. Use the Code’s decision-making framework to help make decisions well, appropriately and with care.

2.WORKPLACE CONDUCT

As an organisation, managing risk is a central part of TASConnect’s daily activities. TASConnect creates value for clients and produce long-term returns for shareholders by taking and managing risks in line with TASConnect’s strategy and within TASConnect’s risk appetite. Risk management is the set of end-to-end activities through which the Company makes risk-taking decisions and control and optimise the risk-return profile of TASConnect. It is a vital part of all activities across the Company, starting from the front line. Because of this, all TASConnect employees must make sure they manage risks effectively as part of their organisational responsibilities.

So, it is important that every aspect of TASConnect’s business is carried out within a framework of the delegated authority. Delegated authority is designed to protect employees as well as the Company. Understanding which limits and policies apply to the employees and to not take more risks than appropriate individuals’ role or seniority.

Employees must:

  • Understand the limits and policies that applies, and keep to them
  • Make sure they have appropriate authority before committing TASConnect to any transaction or contractual commitment
  • Be disciplined and take responsibility and accountability for the risks taken, making sure they are appropriate to the business or activity
  • Make sure that decisions made do not create reputational risk
  • Exercise strong financial control by acting within one’s financial authority and ensuring accurate record keeping
  • Use care, skill and diligence when carrying out any responsibilities or delegating to others

Use good judgement

Good judgment is used when facing situations which are challenging and unfamiliar, while staying within the delegated authority.

One should feel comfortable that they can support the decisions or action they take in light of the difficult situations faced. Being methodical and informed when considering solutions will help to deliver a positive outcome. Acting hastily, without involving manager in line and any other relevant colleagues, exposes one to poor decision-making and negative consequences.

Comply with laws, regulations and standards

It is vital that TASConnect complies with relevant laws, regulations and the Company standards in everything the Company does. Making sure that the Company operates within these laws, regulations and standards is the personal responsibility of every employee.

Always:

  • Act ethically, honestly, professionally and with integrity at all times
  • Comply with all relevant legal and regulatory requirements. Make sure all TASConnect employees know and understand them, and act in a way which follows their instructions and the spirit in which these rules are intended. Failing to do so, the consequences can be severe, including damage to the TASConnect brand, loss of clients, loss of confidence from the regulators and the public, suspension or withdrawal of the licences (if applicable) TASConnect holds and fines or other penalties
  • Comply with TASConnect’s standards unless local laws or regulations are either stricter than, or do not allow TASConnect’s standards – in which case local laws or regulations apply
  • Some countries have requirements for people, organisations or particular activities to be licensed, registered, or certified. These are regulatory requirements, and TASConnect must comply with them. It is TASConnect’s responsibility to make sure that the Company have the relevant licences, registrations and certificates that the employees need
  • Understand the legal and regulatory requirements involved in cross-border activities and keep to these requirements

Treat colleagues fairly and with respect

At TASConnect, the Company believes it is important that everyone can work in a fair, safe, inclusive and enjoyable place that encourages creativity, collaboration and continuous

improvement. These things are essential to TASConnect’s core valued behaviours.

Trust and fairness are also a central part of TASConnect’s approach to managing and developing people. By building on the strengths and abilities, the Company can help the employees to achieve their full potential. And if TASConnect is better as a team, the Company will be able to better serve all clients.

TASConnect expect all employees to treat colleagues fairly and with respect as all employees are entitled to a safe working environment that is free from discrimination, exploitation, bullying, harassment or inappropriate language.

Particular areas to take account of are shown below:

  • TASConnect values diversity and work together as a team. The Company is committed to providing equal opportunities and fair treatment in employment. TASConnect do not accept unlawful discrimination in the Company’s recruitment and employment on the grounds of race; colour; nationality; national or ethnic origins; gender; parental status; marital or civil partner status; sexual orientation; gender identity, expression or reassignment; HIV or AIDS status; employment status; flexibility of working arrangements; disability; age; religion; or belief.
  • TASConnect appoints, trains, develops, rewards and promotes based on merit and ability
  • TASConnect may take action to deal with disadvantage or under-representation among specific groups, with the aim of making sure the employment decisions are free from bias
  • TASConnect do not tolerate any exploitation or any bullying, harassment, discrimination against, or victimisation of any colleagues, clients, or visitors – whether spoken, written, physical or psychological.
  • TASConnect all have a duty to treat the people the Company come into contact with through work with dignity and respect
  • When using the Company’s tools and systems such as Outlook, Sharepoint or etc, TASConnect must make sure that the communications are appropriate. Employees should never use these in a way that breaches any of TASConnect’s policies, including those relating to communications and equal opportunities. All employees should not post or pass on any content that would affect any person’s rights or break the law and all communications are factual and do not contain offensive or abusive language

TASConnect is committed to dealing with any issues that are brought to the Company’s attention. TASConnect will thoroughly investigate complaints of harassment, exploitation, discrimination or victimisation and may take formal disciplinary action where misconduct has taken place.

Be open and honest with regulators – give them your full co-operation

To serve TASConnect’s clients and continue to operate, the Company must maintain strong and effective relationships with regulators and governments to keep the business licences and gain new ones. If TASConnect fails to meet any commitments, regulators may lose confidence in the Company and take action against the Company. This action could include substantial financial penalties and removing the business licences, which will damage TASConnect’s brand, reputation and ability to serve the clients.

3.SECURITY OVER INFORMATION AND ASSETS

As part of delivering or supporting the financial services, TASConnect may receive confidential information which may be about organisations, markets and the Company, as well as personal data of clients, colleagues, and other individuals. It is critical that how TASConnect use confidential information, including personal data, instils trust and confidence, not only in those directly affected, but in the broader community in which the Company operates. TASConnect is committed to handling confidential information, including personal data, respectfully and appropriately in line with TASConnect’s responsibilities in terms of bank secrecy and confidentiality, as well as privacy law.

All information and personal data gathered and dealings with TASConnect is confidential unless clearly said to be otherwise. TASConnect will only share confidential information on the Company’s internal platforms with those allowed to receive it. Confidential information, including personal data, must only be used to carry out work, in line with all laws, regulations, contracts and policies and procedures which apply, including relating to information security and information walls.

All employees must use skill, care and diligence in securing and handling confidential information, including personal data. This includes:

  • Not accessing any confidential information, including personal data, unless authorised to do so in line with their role
  • Accessing, storing and getting rid of confidential information
  • Protecting and handling confidential information including personal data to meet privacy requirements
  • Transferring it securely to others or within the Company
  • Not viewing it in public
  • Respecting information walls that may apply to it
  • Not using or disclosing confidential information, including personal data, on any social networking sites
  • Being vigilant for any signs of threats, including social engineering practices

TASConnect may also collect personal data for specified and legitimate work purposes only, and the Company respects individuals’ rights and regulatory requirements when handling it.

More generally, communications made about TASConnect must be accurate and reflect the Company’s views. Employees must not release confidential information or personal data or make representations about TASConnect to the media or on any public forum, including social media, without express authorisation. Only authorised staff may make comments to the media subject to clearance from Branding & Marketing, Legal, Risk and Compliance.

4.BUSINESS CONDUCT

Ensure fair outcomes for clients

TASConnect must always do the very best to deliver fair outcomes for clients. Clients are at the heart of everything that TASConnect does, and TASConnect is committed to providing clear and honest advice to them, and to making sure that the products offered are right for them. As well as being the right thing to do, providing fair outcomes for clients helps TASConnect to build and foster long-term relationships with them. This helps to improve the Company’s reputation and attract new business.

When dealing with all clients, the following minimum standards must be kept:

  • Make sure that products and services are designed with the clients’ needs in mind, including fair and reasonable pricing which has been clearly disclosed
  • Make sure all communications with clients are fair and not misleading
  • Make sure approval for new products and services (including features, strategic-partnership or significant variation to the existing products) have been obtained from internal key stakeholders (such as Legal, Risk and Compliance, Finance, Tax, etc, prior to launching
  • Give clients clear and concise information before they enter into products and services, so they understand the risks. This must be done for all clients, regardless of how experienced they might be or their usual risk tolerances
  • Follow applicable sales processes. Only market and sell the products and services which have been approved for sale
  • Make sure that products and services are appropriate and suitable, meet clients’ needs, and take into account their financial situation, objectives, risk tolerance and risk profile. Even if TASConnect may know the client well, but must never guess likely decisions on their behalf
  • Handle complaints in a friendly, fast, fair and effective way. Keep to all procedures for handling complaints and use client feedback to identify the root causes of issues. If TASConnect has all the facts and can identify a root cause, the Company will be able to improve the products and services and create better outcomes for clients

Compete fairly in the market place

TASConnect is committed to competing fairly. The risk relating to competition law is increasing including where the Company operates, as well as changing regulations. Most states and countries worldwide have developed competition-law regimes and all employees must comply with competition law at all times and in all countries where TASConnect operates. TASConnect is also responsible for complying with the Competition / Anti-Trust Policy.

Breaching competition law is extremely serious. Most competition authorities across the world can impose substantial fines for competition law (or antitrust) breaches, which can be up to 10% of TASConnect’s yearly turnover. And, competition investigations are extensive, disruptive to the business and ability to focus on the clients, and may result in criminal sanctions and imprisonment for the people involved.

Manage conflicts of interest

Managing conflicts of interest effectively allows TASConnect to act fairly, avoid legal and regulatory risks, and protect the Company’s brand, reputation, and own personal integrity.

Conflicts of interest fall into two broad categories – business and personal. When any actual or potential conflicts of interest is identified, TASConnect must act immediately to deal with them openly, honestly and effectively.

Business conflicts of interest can arise in the following situations:

  • Between TASConnect and the clients, suppliers or other third parties including general users of the markets in which TASConnect operates
  • Between clients and other third parties
  • Between different businesses within TASConnect

Personal conflicts of interest may arise when employees put personal interests ahead of those of a client, supplier, other third party or TASConnect. This would include instances where one have an interest or association (eg. an outside business interest) that may interfere with the Company’s interests or the interests of the clients. They may also arise where one have close personal relationships or close financial relationships with other colleagues.

  • Always act with independence and with integrity in all of the dealings
  • Think carefully and anticipate and properly identify all possible conflicts of interest
  • When changing the structure or make-up of any business activities, consider how these changes may create new conflict situations or change conflicts that have already been identified
  • Report any actual or possible conflict identified, immediately to the relevant Senior Management and Risk and Compliance
  • Conflicts of interest should be escalated, recorded and managed in a clear and effective manner in accordance with relevant policies and procedures
  • Make sure any conflict is dealt with in a clear, open and effective way
  • Get approval before one take part in outside business interests and close personal or financial relationships
  • Be familiar with the Conflicts of Interest Policy and comply with the conditions in them

Reject bribery and corruption

There is no room in this organisation for acts of bribery or corruption. Bribery and corruption are illegal, dishonest, and extremely damaging to the countries and communities where they take place. TASConnect must actively reject bribery and corruption in all its forms. When someone gives a benefit to someone else in order to influence that person’s behaviour, that is a bribe. When someone takes improper advantage of their position to make a gain for themselves, they are acting corruptly.

TASConnect must not give or accept bribes or take part in, or enable, any forms of corruption. It’s vital for employees to stay vigilant because the risk of bribery can arise in any of the operations, at any time where the Company is dealing with a third party. Bribery and corruption can take many forms – through procurement decisions, expenses, gifts and entertainment, hiring decisions, sponsorships, donations, the actions of the customers and so on.

TASConnect must take the time to consider how the day-to-day business activities might encounter or create the risk of bribery and corruption. This will help TASConnect to be better positioned to identify possible bribery and corruption. TASConnect must make sure that the transactions and activities the Company takes part in are not, and cannot be perceived as, an improper inducement for business.

Some important points to highlight:

  • Take particular care if the work involves interactions with Public Officials – including anyone working for government departments, regulators and state-owned enterprises. The rules in this area are more complicated, and the risk can be higher. If this applies to employee’s role, contact Risk and Compliance for more guidance
  • TASConnect can be held legally responsible for the actions of intermediaries and third parties who act on behalf the Company anywhere in the world. When dealing with third parties, TASConnect must make sure that the bribery and corruption risk has been assessed and controlled. This is why TASConnect has robust procurement policies in place
  • Some practices that may be considered normal where the work may actually be illegal under the UK Bribery Act or US Foreign Corrupt Practices Act, or create the perception of bribery or corruption somewhere else. As a result, this can have a negative effect on TASConnect. Employees must take this into account when deciding on the right thing to do, and get advice if necessary
  • If it genuinely feels that personal safety might be at risk when not taking part in bribery or a corrupt arrangement, report it to Risk and Compliance. This should also report the incident to the relevant authorities, where appropriate
  • Get to know the clients. If there is a meaningful and deep relationship with the clients, employees will be better placed to identify and detect potentially inappropriate behaviour
  • TASConnect’s policies explains the rules around giving and receiving gifts and entertainment to make sure they are allowed, properly approved, and recorded. These rules will help to protect the employees and employees are to be familiar with them

The guidance set out in TASConnect’s Anti-Bribery Policy and Procedures must be followed, and other policies which may govern bribery and corruption risk for specific activities. When making decisions to deal with any bribery and corruption risk, TASConnect must make sure these are properly and honestly documented.

Fight financial crime

Financial crime has an enormous global impact. When it is allowed to take place, it negatively affects society at all levels – from ruining the lives of people to threatening the global economy. Financial crime allows drug and human trafficking to take place, supports the smuggling and counterfeiting of goods, underpins illegal gambling and financing terrorist activity and tax evasion, among other criminal acts. TASConnect has a duty to protect the communities that the Company serves from the damaging effects of financial crime.

TASConnect is committed to preventing the laundered proceeds of crime (including those from tax evasion) and financing terrorism from being a part of the overall economy and financial system. TASConnect is committed to preventing the Company, the staff (and other associated people) from the criminal facilitation of tax evasion by the clients. Bribery and corruption cannot be tolerated. TASConnect is also committed to keeping to all legally binding sanctions, including measures against people and organisations and measures against specific countries (or nationals or residents of those countries).

TASConnect must play a strong and effective role in the fight against financial crime. The Company owes this to the customers as well as to the global financial system in which TASConnect operates.

TASConnect must cooperate fully with governments, regulators and other financial services providers to protect client accounts from fraud and to help tackle organised financial crime. TASConnect also must act with skill, care and diligence in the ongoing development of financial crime compliance programmes. All of the employees must apply TASConnect’s standards on financial crime compliance as well as any local anti-money laundering laws and regulations.

Some measures taken:

  • Thoroughly check the identity of the clients from reliable evidence as part of the Customer / Client Due Diligence (“CDD”) procedures, and get to know clients so as to recognise transactions which are inconsistent with their business or do not match the normal pattern of activity for which the account was set up
  • Report suspicious activity immediately (if it is about or suspected to be money laundering, Risk and Compliance must be contacted)
  • Understand and follow the sanctions restrictions
  • Report any suspicion of fraud immediately to line manager and contact Risk and Compliance
  • Employees to not get in the way of any reporting or investigation of any suspected financial crime
  • Complete financial crime compliance training
  • At all times, all employees to follow TASConnect’s anti-money laundering / counter terrorist financing, sanctions, anti-bribery and corruption policies and procedures

Do not engage in or support insider dealing

Insider dealing1 is a criminal offence in most states and countries and may lead to fines or prison if convicted. Insider dealing creates an unfair advantage and undermines the financial system. The nature of TASConnect’s work at times and/or potentially means that the Company is trusted to handle inside information in an appropriate way (if applicable). And TASConnect is all responsible for living the valued behaviours and demonstrating the Company’s commitment to being trustworthy.

Insider dealing includes dealing on own account or encouraging someone else to deal, based on the inside information held. Insider dealing may also take place if one reveals the information to anyone else, other than in the proper performance of work.

The Conflict of Interest standards and any other specific business procedures governing related personal account dealing activities (if any) must be abided by. This applies to transactions carried out by one’s own account or if one has influence over the investment decisions on the accounts of others (if applicable). TASConnect may treat this as a serious disciplinary matter when in breach of the Conflict of Interest rules.

Do not deal or cause someone else to deal:

  • When in possession of any inside information

If employees have, or have access to, inside information or possible inside information:

  • Escalate this in line with Conflicts and Information Walls standards and/ or the management of Inside Information standards (if applicable); and
  • Make sure that inside information is not shared with or revealed to any other people, other than in the proper performance of work

As a designated employee (if applicable), any potential dealing account intention must be informed or disclosed to Risk and Compliance.

5.SOCIAL RESPONSIBILITY

Respect the communities and the environment

TASConnect has the ability and responsibility to make positive change in the communities. TASConnect wants to make sure that the product and services that are provided supports sustainable economic and social development in the communities in which the Company operates.

The upcoming position statements and internal Environmental, Social and Governance risk management (ESG) framework will guide the business activities. They set out the environmental and social standards TASConnect expects of the clients, and the positive behaviours the Company encourages.

TASConnect has a duty to respect the human rights of others who may be affected by they Company’s actions and decisions, whether in the sourcing decisions, through providing products and services, or in how the employees work with each other including supporting the communities.

TASConnect is also establishing targets to manage the Company’s energy, paper and water usage. The Company’s commitment to meeting these targets means TASConnect is managing the resources responsibly.

TASConnect is also strictly non-political and do not get involved in political activities, support political parties or have any political links.

What TASConnect can do:

  • Identify opportunities to make a positive contribution to the communities and the environment
  • Making sure that providing products and services matches the ESG risk management framework
  • Being aware of how the day-to-day decisions made might affect the human rights of others, and acting within the policies to avoid negative outcomes (Reputational Risk)
  • Keeping to the policies on political activities, including the Sponsorship and Donations Policy

6.REPORTING CONCERNS

Speaking Up

TASConnect must maintain a culture of strong ethics, integrity, transparency, and openness. By Speaking Up employees help the Company to identify issues and deal with them.

Misconduct is damaging for everyone. It exposes TASConnect to significant risks and can damage the Company’s financial performance, reputation, and the trust of everyone who has an interest in the business.

The Company and employees all have an important role to play in protecting TASConnect ‘s reputation and the industry at large.

There may be a time when something at work that does not feel right. Speaking Up is a safe, confidential way to let the Company know of it. Some examples of when one should speak up:

  • Failing to comply with laws or legal obligations, including committing fraud or other criminal acts
  • Putting the health and safety of a person in danger
  • Damaging the environment
  • Breaching rules or regulatory requirements
  • Failing to comply with codes of conduct, business or country policies and procedures
  • Doing anything which has or is likely to have a negative effect on TASConnect’s reputation or financial well-being
  • Confidential information, including personal data, is lost or stolen
  • Deliberately concealing any of the above

It is enough to have a reasonable belief that any of the above situations has taken place, is taking place, or could take place. However, when Speaking Up, one must do so honestly and in good faith. Knowingly reporting untrue information is not acceptable.

There are a number of ways to raise a concern:

  • Speak to someone in one’s management chain or outside of one’s management chain, for example (a member of the Senior Management or Risk and Compliance)
  • Use the designated Speaking Up channel: email to Speakup [speakup@tasconnect.com]

 


1 Inside information is information of a precise nature, which has not been made public, relating directly or indirectly to issuers or financial instruments, which, if it were made public, would likely have a significant effect (either positive or negative) on the price of those financial instruments or the price of related derivative financial instruments to which it relates. Inside information can be information about the Company or information given about others.

 

©TASConnect

TASConnect and #dltledgers join hands to bring blockchain enabled trade solutions

Manufacturers and large enterprises are under tremendous pressure to ramp up ESG performance, grow employment in their home countries, and diversify supply chain risk. These are profound changes for the industry, and almost impossible to navigate without digital transformation.

In order to help our customers meet the challenge head on, TASConnect and #dltledgers executed Memorandum of Understanding (“MOU”) to bring a blockchain enabled class-leading technology solution set to our clients, allowing enterprises to diversify, manage and scale their physical and financial supply chain programmes and operations seamlessly.

“TASConnect is delighted to partner #dltledgers for value-added client solutions” said Kingshuk Ghoshal, co-founder and CEO of TASConnect. “The blockchain based physical supply chain solutions of #dltledgers along with the transformation solutions of TASConnect provide enhanced synergies to our common enterprise clients and banks.”

Besides improving digital transparency for better resilience and agility, the collaboration seeks to enable smart traceability of ESG metrics for compliance and capture needs of clients beyond their enterprise systems to their supply chain ecosystems.

“#dltledgers is working with large enterprises to digitalise their physical, transactional and financial supply chain. We are excited to announce our partnership with TASConnect as they bring added capabilities that our Customers’ often require around working capital finance across Financial Supply Chain.” said Farooq Siddiqi, CEO of #dltledgers. “With ready-to-use apps across Manufacturing, Banking and Finance, Commodities and Logistics, we are excited to jointly position Sustainability Visibility and Financing Apps to our joint customers working with talented TASConnect team.”

 


 

About TASConnect

Headquartered in Singapore, TASConnect is a wholly owned subsidiary of SC Ventures Holdings Limited and incubated through SC Ventures – Standard Chartered’s innovation, fintech investment and ventures arm. We are a leading working capital solutions platform connecting complex enterprise ecosystems to deliver economic value with end-to-end visibility and control. We are firm believers in the principles of co-creation and collaboration with our clients.

For more information, please visit http://www.tasconnect.com

 

About #dltledgers

#dltledgers, headquartered in Singapore, is a “no-code” expanded supply chain and digitization platform which uses blockchain technology to deliver industry-leading multi-enterprise supply chain business networks (MESCBNs). The platform focuses on “Digitization, Collaboration, and Authentication,” focused on delivering three key pillars of trust, privacy, and security. Over 4,000 businesses use the platform, participating in, financing, or supporting cross-border trades and executing over $4 bn-worth of transactions. #dltledgers’ integrated digital solution delivers transparency, visibility & adequate risk monitoring in real-time. Our clients are mainly large international trading firms, corporates, supply chain firms, and banks.

For more information, please visit http://www.dltledgers.com

TASConnect looks to address Vietnam’s underserved US$35 billion supply chain finance market

TASConnect, a SaaS supply chain fintech platform incubated through SC Ventures, Standard Chartered’s innovation, fintech investment and ventures arm, is looking to address Vietnam’s underserved supply chain finance market, which is forecasted to reach US$35 billion by the end of 2024.

“Riding on the tailwind of government efforts to digitise processes and improve the sourcing of accurate data, TASConnect will work with Vietnamese financial institutions, MNCs and regional banks to enhance Vietnam’s supply chain finance market,” said Kingshuk Ghoshal, co-founder and CEO, TASConnect. “TASConnect’s solution, which digitalises transactions between corporations and their trading partners, helps companies to expand their scale and scope of supply chain financing without incurring high capital expenditure on IT or human resources.”

Vietnam’s gross domestic product faces a 70% financing gap, even as the economy is benefiting from recent shifts in the global supply chain. This has led more Vietnamese conglomerates and MNCs to demand innovative solutions to unlock trapped liquidity in accounts payable and receivable, so they can scale better into cross-border supply chains.

TASConnect’s bank-agnostic SaaS supply chain finance platform is ready-to-deploy and easy to configure to suit diverse client business models and industries. The fintech’s solution unlocks value for organisations by enhancing efficiencies in accounts payable and receivable transactions, enabling access to increased funding sources, automating complex workflows, thereby giving businesses greater control of their processes. TASConnect offers holistic, customisable and multi-funder solutions for accounts payable and accounts receivable transaction throughout the supply and distribution chain. The fintech also provides value-added services beyond digitalisation and working capital, including, Know Your Customer checks, payments and foreign exchange conversion services, capabilities that are provided by third party solutions providers. Since the company’s launch in February 2022, TASConnect has integrated with large enterprises and regional banks, handling over 250,000 transactions while achieving a gross transaction value of over US$13 billion up to date.

“TASConnect’s mission is to democratise working capital finance,” Ghoshal said. “Unlike conventional bank offerings that are anchored on secured lending and legacy commercial credit processes, that lack seamless digital onboarding and servicing models, TASConnect offers an easy-to-deploy solution that can be customized for a wide variety of businesses.”

Large MNCs can leverage TASConnect to connect their value chain ‘last-miles’ to wider pools of funding sources to scale their supply chain networks sustainably. TASConnect’s platform provides increased visibility of commercial trade data, which allows traditional financiers to make better credit decisions when offering supply chain financing solutions.

 


 

About TASConnect
Headquartered in Singapore, Trade and Supply Chain Connect (TASConnect) is a wholly owned subsidiary of Standard Chartered Bank and incubated through SC Ventures – the Bank’s innovation, fintech investment and ventures arm.  

We are a leading technology solution provider for trade and supply chain finance automation, which gives organisations and their value-chain partners better access to liquidity, along with end-to-end digitalization, visibility, and control of their trade ecosystem. At TASConnect, we are firm believers in the principles of co-creation and collaboration with our clients.  
For more information, please visit www.tasconnect.com. Follow TASConnect on LinkedIn.

 

About Standard Chartered
Standard Chartered is a leading international banking group, with a presence in 59 of the world’s most dynamic markets and serving clients in a further 64. Our purpose is to drive commerce and prosperity through our unique diversity, and our heritage and values are expressed in our brand promise, here for good.

Standard Chartered PLC is listed on the London and Hong Kong Stock Exchanges.

For more stories and expert opinions please visit Insights at sc.com. Follow Standard Chartered on Twitter, LinkedIn and Facebook.

ISO 20022 and trade finance: how standardised approach will reshape the industry

What is the ISO 20022 Standards?

ISO 20022 is a standard for all stakeholders in the financial services industry, which significantly reduces the complexity of sending and deciphering information in a structure data format. This methodology can be used to develop structured financial messages and API resources to help reduce the data misinterpretation and ultimately unify existing messaging standards.

The use of ISO 20022 brings enormous benefits to the financial services industry, as it improves end-to-end processing across domains and geographies that currently uses vastly different standards and information formats.

 

How does the ISO 20022 create interoperability?

While MT103 and Fedwire each uses a different standard and syntax, both provide the same information as ISO 20022. An example of how ISO 20022 create interoperability across standards is, while the MT103 Single Customer Credit Transfer 2u ISO 2u st 20 the 52a “Ordering” “DebtorAgent” element being structured differently, it is still essentially describing the same business concept, which is the financial institution that services the account of the ordering customer (or debtor). As such, both concepts can be understood and mapped to the same ISO 20022 business components when processing the data.

 

How is ISO 20022 going to re-shape Trade and Supply Chain Finance?

Today, each bank has an online application where in a corporate will upload the bespoke files containing invoices for discounting (custom format). Such files formats are not standardized and imposes heavy transformation costs, consuming both time, money and resources to translate and decipher prior to book the trade and then process the payment via the MT or MX format message.

In the trade services area, a suite of ISO 20022 messages has been developed to cover e-invoice, invoice financing, demand guarantees and standby letters of credit, as well as factoring services.

 

What is the current stage of adoption?

While there will be a co-existence period from 2022 till 2025 for handling both the MT and MX for CBPR payments, some countries are more aggressive for local RTGS to completely shift to ISO 20022. The adoption of ISO 20022 throughout the correspondent is banking do Targeted to be complete by the end of 2025, ultimately seen as the de facto standard for global cross-border payments.

This sets a strong foundation for upcoming innovations in both the payments and trade space as technology players can leverage on these standards to look at who clients transact with, when are they transacting, and how are they transacting to provide deeper insights on client behavior which helps banks make better credit decisions.

Source: ISO 2022, SWIFT 6th Limited Edition 

TASConnect is selected as the Top 20 Hottest Startups of 2023

TASConnect has been selected as one of the top 20 hottest startups of 2023 by Singapore Business Review.


Kingshuk Ghoshal and Sujay S K

 

Co-founders: Kingshuk Ghoshal, Sujay S K
Total funding:
US$6M
Founding year:
2022

The bank-agnostic trade and supply chain finance platform was incubated through SC Ventures, Standard Chartered Bank’s innovation, fintech investment and ventures arm. It began commercial operations in the second quarter of 2022. TASConnect offers enterprises and financial institutions with scalable, customisable, and multi-funder solutions for Accounts Payable and Accounts Receivable by enabling the availability of working capital to last-mile suppliers and buyers in efficient and cost-effective ways. In 2022, the platform achieved revenue-generating status, recording a gross transaction value of more than US$10b by handling over 225,000 invoices. Amongst the platform’s pioneer clients is Lenovo.

 

SEE FULL LIST: 20 Hottest Startups of 2023

 


 

About Singapore Business Review

Singapore Business Review (SBR) is the definitive magazine for Singapore’s business elite. Founded in 2001, SBR is the only local business magazine in Singapore guaranteed to reach senior decision makers in the top 1,700 companies with combined sales of S$692 billion and 94% of listed companies.

Its print platform is published quarterly with circulation of 25,000 copies, while its online arm sbr.com.sg offers daily fresh and unique content with over 170,000 unique active users every month.

Singapore Business Review is part of the media company, “Charlton Media Group”, a leading B2B publication and events company in Asia with titles such as Hong Kong Business, Asian Banking & Finance, Insurance Asia, Asian Power, and Healthcare Asia.

How to leverage platform based supply chain finance solutions

Parvez Murshed (Head of Pre-Sales & Platform Solutions, TASConnect) is a banker with more than 20 years experience, specialising in Trade Supply Chain Finance and Transaction Banking through various leadership roles within Citigroup in Asia.


Choosing Between a Single and Hybrid SCF Platforms: A Decision for Multi-National Treasurers and CFOs

Today, treasurers and CFOs of large multi-national corporations often must spend time deciding whether to provide their Supply Chain Finance (SCF) mandate to a single large bank which has its own proprietary SCF platform, or to go with a platform that can bring in funders including multiple banks and other finance providers. There is also a hybrid model where banks have tied up with outside platform providers.

The banks are facing limitations in terms of keeping up with the developments in the markets and with new technology and client requests. Most banks are not able to provide real-time Management Information Systems (MIS) and customised reports per client needs. The biggest issue facing banks today is the scarce technology dollars. There are always unlimited asks from various markets, local regulatory compliance, specific clients’ requirements and ever shrinking budget pool for tech dollars. Multiple rounds of review before they can make enhancements to their platform. platforms today are clunky and do not have client friendly interface and dashboards.

 

Overcoming Banks’ Limitations with SCF Platforms: Consolidation and Customisation

Entering the era of platforms opens a door of flexibility and customisation for the clients. A Fintech-created platform will have the flexibility to create customised workflows, dashboards and enforce client’s rule sets and provide real-time reporting back to client’s ERP.

Some banks have not yet been able to develop APIs for their SCF platforms. As a result, host to host integration is the only option and can take months to implement. Clients also do not want to connect with multiple service providers and banks. For example , if you want your supplier’s KYC done for onboarding into a SCF program, a bank may take a month while some FinTech will be able to do this in about 48 hours pulling KYC data through various sources by API calls. If a bank wants to implement an ESG solution, they have to implement their own ESG framework, get multiple levels of internal approval and then sign up with an external service provider for monitoring of the ESG performance by the suppliers. However, SCF platform is able to consolidate all such ESG capabilities in one place and launch fast in the market. Taking cross-boarder payment and FX conversion as another instance, most banks have limited capability due to the footprint restrictions, especially in illiquid and developing markets. FinTech usually has a better market coverage and local payment system capabilities by integrating with multiple platforms.

While banks bring in liquidity into the SCF programs, they also have limitations in terms of how much credit facility they can allocate. Their distribution capabilities are also limited due to competition with other banks and higher return requirements for capital, which higher calls for skim le to higher pricing for the suppliers. The time taken for distribution can be long sometimes due to scarcity of credit lines and market condition. As a result, invoices may not get discounted on time and suppliers run out of cash. This could be more acute in markets like Vietnam or Indonesia where the secondary market is nascent or non-existent.

 

The Value of TASConnect as a Single Point of Convergence for Multi-National SCF Solutions

That’s where a platform provider like TASConnect adds tremendous value to the multi-national clients by working as their extended ERP and single point of convergence to bring multiple banks, funders and service providers to one place be it for financing, supplier KYC, FX or ESG . The flexibility and nimbleness from pre-to-post shipment create transparency and visibility to clients’ end-to-end trade and supply chain ecosystems. Clients do not have to connect with all the stakeholders individually anymore, to access the holistic SCF solutions. This is the future of platforms and TASConnect is already ahead of the game by creating the future, today.

 

Leveraging on supply chain finance platforms to help corporates accelerate sustainability

Lynette Lee (member, SC Ventures) focuses on driving initiatives and start ups in Sustainability (ESG) space within the Fintech innovation industry. She advances ESG-integration standards and drives the evolution of such stewardship through spearheading collaborative ventures with industries.


The Intersection of Supply Chain Finance and Sustainability: An Evolving Global Landscape

Ever since the COVID-19 pandemic, we can clearly see the evolution of global economy being intertwined with supply chain finance and sustainability. These are topics that have grown in importance for businesses and organizations if they want to be recognized as global players who til as corporate citizens that contribute to profit, planet and people in their journey.

 

Balancing Profit and Responsibility: The Growing Importance of Sustainable Supply Chain Finance

Supply chain finance involves managing the financing and cash flow of the supply chain, while sustainability is focused on the environmental, social and economic impacts in the supply chain. The success of companies that have incorporated sustainability (ESG) in their business led to operations increased interest in the pursuit of solutions that can balance the implementations ESG solutions alongside profitable management of supply chains. Demands for sustainable supply chain finance solutions that are both profitable and socially responsible has grown. supply chain, while reducing costs and increasing profits.

Organizations need to use a variety of strategies and technologies to meet the rising demands of sustainability and supply chain finance efficiently. Technology also plays a key role in supply chain finance and sustainability. and reduce costs. Artificial intelligence helps increase efficiency and reduce waste by analyzing and optimizing supply chain data. Predictive analytics can help organizations anticipate and respond to market changes and gain cash flow mobility.

 

Assessing the Impact of Supply Chains on Environment and Society: A Structured Approach

The first step is to use certified and recognized frameworks to prioritize the crucial and critical topics that impact their businesses.
This helps with two areas:

    1. Standardize the language between finance, sustainability operations and helps in communications to regulators, investors, financiers and customers.
    2. Set the baseline for double materiality measurements

Using this identifiable structure, businesses can confidently assess and evaluate the impact of the supply chain on the environment and society. They can now deep dive into environmental impacts of the materials and processes used, as well as the social shabus impacts of labor ps practice their strategy and solutions can be implemented to reduce the impact and increase efficiency.

Undeniably, supply chain finance and sustainability are two of the most important topics in today’s business landscape. Organizations must be aware of the trends, evaluate the impact of their supply chains, and use modern technologies that covers their ecosystem to reduce costs and ensure long term sustainability.

TASConnect is ISO27001:2013 certified

As of June 2022, TASConnect has successfully obtained the ISO 27001:2013 certification for the company’s Information Security Management System during its first year of commercial operations. In conjunction with the ISO team, TASConnect formulated, reviewed, and approved a predefined set of ISO27001 compliant policies as well as underwent a detailed audit process before finally receiving the certification.

As TASConnect plays a crucial role in seamlessly integrating into a client’s complex workflow and supply chain ecosystem, as such data privacy and cybersecurity are the utmost priority to establish trust and reliability with the clients. ISO 27001 certification demonstrates TASConnect’s commitment and ability to effectively implement and maintain a safe, secure, and resilient Software-as-a-Service platform, which ensures a high-degree of confidentiality, integrity, and visibility of critical data assets for clients.

To maintain the high security control standards, TASConnect routinely conducts Cybersecurity Governance Forums to regularly review the statuses of all in-scope controls. Compliance and adherence to the policy set is thus reviewed efficiently, and action items are tracked to closure in a timely manner.

Progressively, TASConnect will look to increase the review items through an automated dashboard to ensure reliability and further streamline the process. This ensures that the Technology Risk policy set is kept up to date as the organisation continues to evolved and mature.

 


 

About ISO27001:2013 Certification

ISO 27001 is one of the world’s best-known and the only auditable international standard that defines the requirements of an information security management system (ISMS). ISO 27001:2013 specifies the cyber security requirements for the continuous management and improvement of the organization’s ISMS. This includes the assessment and handling of information security risks pertaining to the nature of the organization.

Source: ISO/IEC 27001:2013