Financial Crime Compliance

Last updated 8 February 2023

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:

a. Giving and Receiving of Bribes

b. Giving or accepting Anything of Value of a person promising or asserting the ability to improperly influence a Public Official

c. 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

d. Gifts and Entertainment (unless permitted)

e. 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.

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