AML Policy

I. Introduction, Purpose and Scope

 

"Witzeal S. R. L, and all of its subsidiaries (“Witzeal”), are dedicated to conducting business with integrity, fairness, and adherence to the legal frameworks within each jurisdiction of operation. The purpose of this Policy is to delineate:

I. The definition of Money Laundering and Terrorist Financing;

II. Our approach to Anti-Money Laundering and Countering Financing of Terrorism (“AML & CFT”) across our business;

III. Your responsibilities in mitigating risks related to Money Laundering and Financing of Terrorism; and

IV. The prescribed procedures to be followed in the event of a potential or actual policy violation.

This Policy is applicable to all Witzeal employees, including board members, agency workers, volunteers, independent contractors, and third parties acting on behalf of the company (hereinafter referred to as “you”).

Approval for this Policy has been granted by the Board Risk and Sustainability Committee (BRSC) or its designate. Regular reviews and updates will be conducted on an annual basis, with more frequent revisions as dictated by changes in regulations or business requirements."

II. Statement of Policy

Key Definitions

Money Laundering: The process through which the proceeds of crime are concealed to obscure their illegal origin.

Financing of Terrorism: The provision, collection, or receipt of funds with the intent or knowledge that such funds will be employed for terrorist purposes.

Our Approach:

Witzeal is unwavering in its commitment to adhere to all Anti-Money Laundering and Countering Financing of Terrorism (AML & CFT) laws and regulations within the jurisdictions where it operates. This commitment includes preventing the utilization of our products or systems for purposes such as laundering criminal proceeds, financing terrorism, evading taxation, or bypassing applicable AML & CFT laws. The company reserves the right to suspend any customer or third-party relationship deemed contrary to relevant laws. To ensure compliant business practices, the following measures have been implemented:

• Policies, standards, and training to foster understanding of roles and responsibilities;
• Formal escalation channels to report suspicions of potential or actual AML & CFT violations; and
• Frameworks and procedures designed for continuous monitoring of AML & CFT risks across our global operations.

Summary of AML & CFT Policy Standards:

This Policy is fortified by standards aiming to establish a consistent benchmark across all subsidiaries. AML & CFT requirements include, but are not limited to: [list specific areas of requirements].

Tone from the top	IT system requirements
Governance and oversight	Third party due diligence
Training and awareness	Exiting relationships*
Business risk assessments	Internal and external reporting
Customer due diligence	Record-keeping
Employee due diligence	Independent program reviews

* Customer and Third Parties

Identification of Potential Red Flags:

On occasion, individuals and entities may attempt to obscure their true identity or circumvent the established controls in place to identify and prevent Money Laundering or Financing of Terrorism. It is imperative that you remain vigilant and promptly report any identified red flags in accordance with your local Anti-Money Laundering and Countering Financing of Terrorism (AML & CFT) procedures and escalation channels, including but not limited to:

• At Onboarding or Account Opening: Misleading, vague, or challenging-to-verify information provided in an effort to conceal true identity or circumvent onboarding procedures.

• Refusal to Provide Source for Funds or Necessary Information: Any unwillingness to furnish the source of funds or requested information during the due diligence process.
• Multiple Transactions Below Reporting Threshold: Deposits involving multiple transactions falling below the reporting threshold within a condensed timeframe.

• Inconsistent Transactional Activity: Activity that deviates from the apparent financial standing, established patterns of behaviour, or occupational information.

• Large and/or Rapid Movement of Funds: Unusually substantial or swiftly executed fund transfers misaligned with established behavioural norms.

• Transactions Involving Individuals or Entities Linked to Terrorism: Engaging in transactions with individuals or entities associated with a terrorist organization or terrorist activities.

• Indications from Open Source Searches: Information from open sources indicating potential support for violent extremism or radicalization.

Local Financial Crime teams are obligated to ensure the prompt submission of a Suspicious Activity Report (SAR) to the appropriate regulatory body as required.

III. Roles and Responsibilities

Employee Obligations:

Acquaint themselves with the content of this Policy;

• Ensure timely completion of relevant training within specified time frames;
• Adhere to guidance from our Procurement, Human Resource, and Financial Crime teams when engaging with customers, employees, or third parties, ensuring appropriate due diligence is conducted;
• Recognize their obligations to identify and promptly escalate red flags or seek clarification when uncertain;
• Report any breaches or wrongdoings, whether past, present, or anticipated in the future;
• When uncertain, seek guidance from their line manager and the local Financial Crime team.

Witzeal Management Responsibilities:

• Effectively communicate this Policy to their respective teams to foster awareness;
• Ensure team members understand their obligations in identifying and escalating red flags when necessary;
• Guarantee access to and assignment of all relevant trainings for team members;
• Monitor compliance within their teams, ensuring timely completion of training within allocated time frames;
• Report any identified breaches or wrongdoings, regardless of their temporal context.
• It is important to note that non-compliance with this Policy may result in disciplinary action, up to and including termination of employment or a business relationship, as deemed appropriate by the Compliance, Human Resources, or relevant line management.

IV. Monitoring, Assurance, and Breach Reporting

Compliance with this Policy undergoes regular monitoring, and assurance activities are conducted at defined intervals. If you have any concerns, it is crucial to raise them with individuals equipped to address them effectively, notably your Financial Crime team. Depending on the circumstances, you may opt to report internally or externally through our Independent Confidential Reporting Service.

Concerns related to potential breaches of this policy can be appropriately addressed by reaching out to your Compliance team, who are well-positioned to handle such matters. Alternatively, you may seek guidance from your line manager or trusted individuals such as Witzeal's Legal Counsel or Internal Audit. In cases where it is neither feasible nor desirable to address a particular concern through consultation with your line manager, or if a reportable matter remains unresolved following consultation, the submission of a report about the matter through the Speak-Up platform is recommended. For further details, please consult our Whistleblowing Policy.

V. Relevant Contact Details

For any inquiries regarding the content, context, or interpretation of this document, please contact:

help@witzeal.com