Policy Statement

Corporate Connect is committed to preventing and combating all forms of financial crime within its operations and throughout its supply chain. We are dedicated to complying with all applicable anti-money laundering laws and regulations in the United Kingdom, including but not limited to the Money Laundering Regulations 2017 (as amended) and the Criminal Finances Act 2017.

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This policy outlines the steps we take to protect our company and our clients from liability.

 

Scope

This Anti-Money Laundering Policy (the "Policy") applies to all employees, officers, directors, agents, contractors, and other stakeholders of Corporate Connect. It covers all aspects of our business operations and includes guidelines for identifying, reporting, and preventing money laundering activities. We are committed to maintaining strict compliance within our business and will not tolerate any breach of this policy by our employees or associated partners in our supply chain.

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Legal Framework
2.1 Applicable Laws and Regulations

Corporate Connect shall fully comply with all relevant UK anti-money laundering laws and regulations, including but not limited to:

• The Money Laundering Regulations 2017 (as amended)

• The Proceeds of Crime Act 2002

• The Terrorism Act 2000

• The Criminal Finances Act 2017

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Anti-Money Laundering Program
3.1 Designated Money Laundering Reporting Officer (MLRO)

Corporate Connect shall appoint a designated Money Laundering Reporting Officer (MLRO) responsible for overseeing the AML program, ensuring compliance with AML laws, and acting as the primary point of contact with relevant authorities.

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Where specific risks are identified in relation to the framework of controls or a particular business relationship, the Compliance team will escalate such matters to the board of directors periodically.

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3.2 Risk Assessment
Corporate Connect shall conduct regular risk assessments to identify and evaluate money laundering risks associated with its products, services, customers, and geographic locations. These assessments will inform the development and adjustment of our AML procedures.

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3.3 Client Due Diligence (KYC)
Corporate Connectshall establish and implement risk-based Customer Due Diligence (KYC) procedures to verify the identity of customers, assess their risk profiles, and understand the source of funds. KYC measures shall include, but not be limited to:

• Obtaining customer identification documents

• Obtaining proof of operating address

• Identifying beneficial owners

• Conducting ongoing monitoring of customer transactions

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3.4 Supplier Due Diligence (SKYC)
Corporate Connect shall establish and implement risk-based Due Diligence (PKYC) procedures to verify the identity of all suppliers and employers of record used by the company. Audacia Plc will assess their risk profiles, beneficial owners, and confirm they maintain full compliance in accordance with our set Code of Conduct policy.

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SKYC measures during partner onboarding shall include, but not be limited to:

• Obtaining director identification documents

• Obtaining proof of operating address

• Identifying beneficial owners

• Conducting ongoing monitoring of transactions

• Verifying the current VAT and Employment Taxes position

• Searching the director on Companies House and inquiring about any other companies they have been an officer for previously, particularly any that have had an insolvency event

• Checking website presence and social media presence

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Weekly Checks

• Confirm that the company name, number, and VAT number on the invoice are the same as those you conducted due diligence on at the outset.

• Check a random sample of payslips to ensure that expenses and holiday pay are handled as expected. Record the payslips checked and the outcome on a weekly basis.

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Monthly Checks

• Conduct a live VAT check on the company. Print the screen and keep a record.

• Search Companies House to ensure that the company is up to date with its reporting obligations (Confirmation statement and Accounts).

• Employment Intermediary reporting should be provided monthly where required, and these reports can be cross-referenced against your internal records.

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3.5 Suspicious Activity Reporting
All employees and stakeholders are required to promptly report any suspicious activities or transactions related to money laundering to the MLRO. Reports will be treated confidentially, and no retaliation will be tolerated against those making legitimate reports.

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3.6 Record Keeping
Corporate Connect shall maintain accurate and up-to-date records of customer transactions, CDD documentation, and AML-related reports. These records will be retained for the period required by UK AML laws and regulations.

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3.7 Employee Training
Corporate Connect shall provide regular AML training to all employees to ensure they understand their responsibilities and can recognize suspicious activities. Training programs will be updated to reflect changes in AML laws and regulations.

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3.8 Independent Audits
Periodic independent audits of Corporate Connect's AML program shall be conducted to assess its effectiveness and compliance with applicable UK AML laws and regulations.

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Penalties for Non-Compliance
Non-compliance with this AML Policy or relevant UK AML laws and regulations may result in disciplinary actions, including but not limited to termination of employment or contractual relationships. It may also lead to civil or criminal penalties for individuals or the company.

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Conclusion
Corporate Connect is fully committed to preventing money laundering and adheres to all anti-money laundering laws and regulations in the United Kingdom. This Policy is subject to regular review and updates to ensure its continued effectiveness.

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Corporate Connect [August 2024]