Privacy and Data Protection
 

The inappropriate disclosure or negligent handling of sensitive information could place our clients, the Firm and personnels, missions, projects, initiatives and programs at risk. To mitigate these risk, we follow information sensitivity classification systems and disclosure policies and procedures which forbids us to divulge sensitive information to third-parties unless recipients have been authorized by our clients and the relevant sovereign-states. Our people and agents are required to comply with these policies and procedures at all times. 

 

Anti-Bribery and Anti-Corruption
 

We seek to acquire business based on excellence and the merit of our initiatives. We work directly with head of states, ministers, public officials, candidates for office, employees, or officers of state-owned enterprises. Our activities can present bribery and corruption risk. As a result, we have designed direct and indirect policies and procedures to promote and achieve compliance with anti-bribery and anti-corruption laws. Our people are strictly prohibited from improperly providing anything of value to anyone in order to obtain or retain business or any improper business advantage. Our people are also prohibited from receiving or accepting bribes. We also perform enhanced due diligence and oversight of third-party relationships and prohibit payment facilitation, as well as the use of third parties or intermediaries and finders to route any payments. 
 

We remain vigilant about potential bribery concerns and escalate them immediately in accordance with the guidance provided with our policies.
 

Anti-Money Laundering
 

We work with integrity and in strict compliance with all applicable anti-money laundering laws and regulations. This means we must always ensure we do not receive or are being used to facilitate the flow of criminally-derived funds. To comply with these procedures, we adhere to KYC requirements, verify when applicable source of funds and results of investments and identify unusual or potentially suspicious activities that have no apparent legitimate business purpose or is outside of the ordinary course of a client’s or partners business activity. 
 

Sanctions 
 

We adhere to all applicable government economic and trade sanctions, including European Union, UK, US sanction regimes and the UN Sanctions List. These regimes prohibit us from dealing or providing services to certain groups, governing bodies, or targeted individuals and entities currently subjects to sanction measures. To comply with these, we verify the identity and background of personnels and stakeholders directly and indirectly involved with our projects including their directors, officers and controlling shareholders and check watch list, AML Black List and PEP databases. 

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