Together with our partners, we strive to meet fundamental human needs: building trust with business partners, creating transparency in society, and enhancing economic mobility.
Bribery, fraud and money laundering are global problems in the modern world. These seemingly unrelated phenomena often are part of a much larger problem - criminals use accumulated funds to systematize and optimize criminal activity.
We adhere to high ethical standards and strive to do business only with clients who meet our strict standards and do not do business with clients if we have reason to believe that the risks are too high.
In accordance with our policy against money laundering, bribery, and corruption, we may refuse to provide services. This also means that sometimes our standards may be stricter than our legal obligations, and we may choose not to support certain client relationships or business activities, even if they are permitted by law.
We strongly support initiatives to increase the transparency of beneficial ownership for entities and legal arrangements in a way that enables competent authorities to determine beneficial ownership in a timely manner.
We apply a zero-tolerance approach to money laundering, bribery, and corruption and consider such activity unethical and contrary to proper corporate governance. Our company's management, employees, and associated individuals are prohibited from engaging in bribery and corruption.
Andrej Schmidt
Managing partner
People
Our people play a vital role in combating money laundering, bribery, and corruption. We have invested a significant amount of time and resources to ensure that our employees are properly equipped and give our employees the opportunity to report suspicious cases.
To constantly inform our employees about the importance of fighting corruption, we have launched a wide range of training and communication activities. In this way, we stimulate discussions on the topic of sanctions, combating money laundering, bribery, and corruption, and help our employees safely navigate complex situations in their daily work.
Processes
A key obligation for our company is to fully understand who we are doing business with. This requires us not only to identify our clients but also to thoroughly verify the accuracy of the information provided to us. It is important to note that all documents provided by clients are properly recorded and stored.
The specific scope of our customer due diligence obligations corresponds to the level of risk associated with a specific counterparty, business relationship, or transaction. Compliance with these obligations can be verified by an authorized supervisory body.
Our company practices active risk management in the field of money laundering prevention and anti-corruption to implement our strategy and ensure sustainable growth and business continuity. We strive to manage risks based on analytical data.
Risk management consists of risk analysis and internal security measures.
If we cannot be assured of the integrity of the counterparty, we are not entitled to establish or continue business relations, and any existing business relationships must be terminated. Non-compliance with these requirements can lead to penal sanctions.
Our policy against money laundering, sanctions, bribery, and corruption is aimed at properly reducing the risks identified by our company.
Our company conducts ongoing risk analysis to identify money laundering and terrorist financing risks and assess them individually for our business.
Based on the risk analysis, we develop organizational measures corresponding to the risk level to be able to adequately respond to identified dangers.
We regularly document the results of the risk analysis and update them as necessary.
The retention period for these documents is five years. It begins at the end of the calendar year in which the business relationship causing the obligations ended. In all other cases, it starts at the end of the calendar year in which the relevant information was established. The term can be extended up to ten years if a longer term is provided by law. After the retention period, the documents are destroyed.
All employees whose activities involve risks related to money laundering undergo appropriate reliability checks.
The company's top management is responsible for implementing measures to combat money laundering, bribery, and corruption. We regularly review the effectiveness of our measures and continuously develop our compliance system.
Technologies
Technologies play a pivotal role in our fight against financial crimes. That's why we invest significant resources in creating an integrated risk detection system.
We must always be confident that all the information we have about our customers is accurate, up-to-date, and complete. That's why we've created a unified, integrated ERP system within the company, which, to the maximum extent permitted by law, combines customer and transaction data, helping us to manage risks effectively. This helps us more efficiently detect and prevent criminal activity in a timely manner.
We are constantly striving to improve ways of detecting and preventing money laundering.
Partnership and Information disclosure
Working in partnership is vital for understanding and addressing the issues of combating money laundering, bribery, and corruption. That's precisely why we establish effective relationships with law enforcement agencies. By sharing data with law enforcement, we can better focus our collective efforts on protecting society.
If we have grounds to believe that assets have an illegal origin (i.e., we are dealing with "dirty money") or the assets are associated with the financing of terrorism, or the counterparty has not disclosed to us the name of the beneficiary on whose behalf he/she is acting, we are obliged to immediately report this to the Central Investigative Body for Financial Transactions, "Financial Intelligence Unit" (FIU). We also reserve the right to report.
