MISL Ltd – Anti-Laundering & Bribery Policy

Last Reviewed [09/10/2024]

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1. Purpose

MISL Ltd is committed to conducting its business ethically, with integrity, and in full compliance with all applicable laws and regulations, including the UK Bribery Act 2010 and the Money Laundering Regulations 2017. This policy outlines the company’s approach to preventing and combating money laundering, terrorist financing, and bribery in all its operations.

 

2. Scope

This policy applies to all employees, directors, contractors, consultants, and third parties working on behalf of MISL Ltd. It covers all activities, transactions, and relationships, regardless of the location or nature of the work being performed.

 

3. Anti-Money Laundering (AML)

 

3.1 Definition of Money Laundering

Money laundering is the process of concealing, disguising, converting, transferring, or handling the proceeds of crime. It involves making illegally obtained funds appear legitimate.

 

3.2 Compliance with Money Laundering Regulations

MISL Ltd is committed to complying with the Money Laundering Regulations 2017 and other relevant laws. All employees must ensure they do not knowingly engage in or facilitate money laundering activities.

 

3.3 Key AML Procedures

To prevent money laundering, MISL Ltd implements the following procedures:

 3.3.1 Customer Due Diligence (CDD)

• Conducting identity verification on clients and third parties before entering into business relationships.
• Assessing the risk level of customers, including enhanced due diligence for high-risk clients (e.g., politically exposed persons (PEPs)).
• Regularly monitoring ongoing relationships to ensure continuous compliance.

 3.3.2 Suspicious Activity Reporting (SAR)

• Employees are required to report any suspicious activities or transactions immediately to the company’s Managing Director (MD).
• The MD will assess whether a Suspicious Activity Report (SAR) should be filed with the UK National Crime Agency (NCA).

 3.3.3 Record Keeping

• MISL Ltd maintains detailed records of customer identification, transaction documentation, and reports of suspicious activities for at least 5 years.

 

3.4 Responsibilities

• The MD is responsible for overseeing AML compliance, including CDD, SARs, and staff training.
• All employees must be vigilant and comply with this policy, report suspicious behaviour, and participate in training.

 

 

4. Anti-Bribery Policy

4.1 Definition of Bribery

Bribery is the offering, promising, giving, accepting, or soliciting of an advantage (financial or otherwise) as an inducement or reward for a person to improperly perform their duties. Bribery is illegal under the UK Bribery Act 2010.

 

4.2 Prohibition of Bribery

MISL Ltd strictly prohibits any form of bribery, whether directly or indirectly, in its business dealings. This includes:

• Bribes to or from government officials, clients, suppliers, or any third party.
• Offering or accepting gifts, hospitality, or other inducements that could be perceived as intended to influence business decisions.

 

4.3 Facilitation Payments

MISL Ltd prohibits facilitation payments (small payments to expedite routine government actions). Employees must not make such payments, even if they are common in certain jurisdictions.

 

4.4 Key Anti-Bribery Procedures

To ensure compliance with anti-bribery laws, MISL Ltd implements the following procedures:

 4.4.1 Gifts and Hospitality

• All gifts or hospitality offered or received must be reported to the MD.
• Gifts and hospitality must be reasonable, transparent, and not intended to influence business decisions.

 4.4.2 Third-Party Due Diligence

• Due diligence must be conducted before entering into agreements with third parties to ensure they are reputable and comply with anti-bribery laws.
• This includes agents, suppliers, and joint venture partners.

 4.4.3 Reporting Concerns

• Any employee who suspects bribery, corruption, or unethical behaviour must report it immediately to the MD.
• MISL Ltd guarantees that employees raising concerns will be protected from retaliation or victimization.

 4.4.4 Training and Awareness

MISL Ltd provides ongoing training for employees on anti-bribery laws, company policies, and how to report concerns.

 

4.5 Responsibilities

• The Compliance Officer is responsible for overseeing anti-bribery compliance, ensuring due diligence, and managing reports of bribery or corruption.
• All employees are required to avoid involvement in bribery, report any concerns, and adhere to the policy’s guidelines.

 

5. Whistleblowing

MISL Ltd encourages employees to report any violations or concerns related to this policy. The company will investigate all reported incidents and will not tolerate any retaliation against employees who raise concerns in good faith.

 

6. Consequences of Non-Compliance

Non-compliance with this policy, whether intentional or through negligence, may result in disciplinary action, up to and including termination of employment, as well as potential civil or criminal penalties in line with UK law.

 

7. Policy Review

This policy will be reviewed annually or as required by changes in applicable laws and regulations. Updates will be communicated to all employees and relevant stakeholders.