MISL Ltd – Anti-Bribery & Corruption Policy

Last updated [13/11/2024]

Introduction

MISL Ltd is committed to conducting its business with the highest standards of integrity, professionalism, and compliance with all applicable laws. This policy establishes our approach to preventing bribery, corruption, money laundering, and terrorist financing across all aspects of our operations. It applies to all employees, directors, contractors, consultants, and third parties acting on behalf of MISL Ltd, ensuring ethical practices in all activities, transactions, and relationships, regardless of location or context.

1. Anti-Money Laundering (AML)

1.1  Definition

Money laundering is the act of disguising the proceeds of criminal activities to make them appear legitimate.

1.2 Compliance

MISL Ltd complies with the Money Laundering Regulations 2017 and prohibits all forms of involvement in or facilitation of money laundering.

1.3 Procedures

• Customer Due Diligence (CDD):

  • Verify identities of clients and third parties before business engagement.
  • Conduct enhanced due diligence for high-risk parties, such as politically exposed persons (PEPs).
  • Monitor relationships to maintain ongoing compliance.

• Suspicious Activity Reporting (SAR):

  • Employees must report suspicious activities or transactions to the Managing Director (MD).
  • The MD will assess whether to file a Suspicious Activity Report (SAR) with the UK National Crime Agency (NCA).

• Record-Keeping:

  • Maintain records of customer verification, transactions, and SARs for at least 5 years.

1.4 Responsibilities

• The MD oversees AML compliance, training, and reporting.
• All employees must remain vigilant, report concerns, and adhere to training requirements.

2. Anti-Bribery

2.1 Definition

Bribery involves offering, giving, receiving, or soliciting something of value to improperly influence the performance of duties or functions.

2.2 Policy Statement

MISL Ltd prohibits bribery in all forms, including:

• Offering or accepting bribes to or from government officials, clients, suppliers, or third parties.
• Providing or receiving gifts, hospitality, or inducements intended to improperly influence business decisions.

2.3 Facilitation Payments

Facilitation payments, even if customary in certain jurisdictions, are strictly prohibited.

2.4 Procedures

• Gifts & Hospitality:

  • Report all gifts and hospitality to the MD.
  • Ensure they are reasonable, transparent, and free of intent to influence decisions.

• Third-Party Due Diligence:

  • Conduct due diligence on agents, suppliers, and partners to ensure compliance with anti-bribery laws.

• Reporting Concerns:

  • Employees must report suspected bribery or corruption to the MD.
  • MISL Ltd guarantees protection for whistleblowers against retaliation.

• Training:

  • Regular training is provided to employees on anti-bribery laws, company policies, and reporting mechanisms.

2.5 Responsibilities

The Compliance Officer ensures compliance, oversees due diligence, and investigates reports of bribery.

3. Whistleblowing

MISL Ltd encourages employees to report concerns related to this policy. All reported incidents will be investigated thoroughly and confidentially. Employees raising concerns in good faith are protected against retaliation.

4. Consequences of Non-Compliance

Violations of this policy may lead to disciplinary action, up to and including termination of employment, as well as potential civil or criminal penalties under UK law.

5. Policy Review

This policy will be reviewed annually or upon changes to relevant laws and regulations. Updates will be communicated to all employees and stakeholders.