Purpose
The purpose of this Anti-Bribery and Anti-Money Laundering (ABC and AML) Policy is to establish a clear framework for Ruxley Integrated Global Services Limited to conduct business ethically and in compliance with applicable laws and regulations. This policy aims to prevent and address bribery and money laundering activities within our operations and supply chains.
Scope
This policy applies to all employees, directors, officers, contractors, consultants, suppliers, and any other individuals or entities acting on behalf of Ruxley Integrated Global Services Limited, across all geographic locations and business units.
Anti-Bribery Policy
Commitment to Anti-Bribery
Ruxley is committed to conducting all business activities fairly, honestly, and transparently. We have a zero-tolerance policy toward bribery and corruption in any form, whether direct or indirect.
Definitions
- Bribery: Offering, giving, receiving, or soliciting anything of value to influence the actions of an official or other person in a position of authority.
- Corruption: The abuse of entrusted power for private gain.
Prohibited Conduct
- Employees and representatives of Ruxley must not engage in bribery or corruption, whether in dealings with government officials, private sector organizations, or individuals.
- Offering, promising, or giving gifts, hospitality, or any other benefits to obtain or retain business is strictly prohibited unless explicitly approved under this policy.
Gifts and Hospitality
- Any gifts or hospitality must be reasonable, proportionate, and transparent. Employees must seek approval from their manager before offering or accepting any gifts or hospitality.
- Records of all gifts and hospitality must be maintained and reported as required by the company.
Reporting Violations
Employees are encouraged to report any suspected or actual bribery or corruption incidents through the appropriate channels. Ruxley will ensure that all reports are treated confidentially and that whistleblowers are protected from retaliation.
Anti-Money Laundering Policy
Commitment to Anti-Money Laundering
Ruxley is committed to preventing money laundering and the financing of terrorism within our operations. We will comply with all applicable AML laws and regulations in the jurisdictions where we operate.
Definitions
- Money Laundering: The process of concealing the origins of illegally obtained money, typically by passing it through a complex sequence of banking transfers or commercial transactions.
- Financing of Terrorism: Providing financial support to individuals or groups that engage in violent acts to achieve ideological, political, or religious goals.
Risk Assessment
Ruxley will conduct regular risk assessments to identify potential vulnerabilities to money laundering and terrorist financing within our business operations and supply chains.
Customer Due Diligence (CDD)
- We will perform due diligence on clients, suppliers, and business partners to verify their identity and assess the risk of involvement in money laundering or terrorist financing.
- Enhanced due diligence will be required for high-risk customers or transactions.
Reporting Suspicious Activity
Employees are required to report any suspicious transactions or activities that may indicate money laundering or terrorist financing. Reports should be submitted to the Compliance Officer for investigation.
Training and Awareness
Ruxley will provide regular training to all employees on ABC and AML principles, ensuring that they understand their responsibilities under this policy. Training will cover:
- Understanding bribery and corruption risks.
- Recognizing signs of money laundering.
- Procedures for reporting suspicious activities or concerns.
Compliance and Enforcement
- All employees are responsible for complying with this ABC and AML Policy. Failure to adhere to these standards may result in disciplinary action, including termination of employment.
- Ruxley will conduct regular audits and reviews to ensure compliance with this policy and applicable laws.
Policy Review
This policy will be reviewed annually or as needed to ensure its effectiveness and compliance with applicable regulations and best practices. Updates will be communicated to all employees.
Signed: MD/CEO
