Statement of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policies and Principles

Money Laundering and Terrorist Financing have been identified as major threats to Top Impact Limited and, indeed, the international financial services community. The United Kingdom, along with many other countries, has passed legislation to prevent money laundering and combat terrorism.

Legal and Regulatory Framework

The principal requirements, obligations and penalties on which our company’s financial crime systems and controls are based derive from:

• The proceeds of Crime Act 2002 (POCA), as amended by the:
  • Serious Organized Crime and Police Act 2005 (SOCPA); and the
  • Proceeds of Crime Act (amendment) Regulations 2007;
• The Terrorism Act 2000, as amended by the:
  • The Anti Terrorism, Crime & Security Act 2001; and the
  • Terrorism Act (amendment) Regulations 2007;
• The Terrorism Act 2006;
• The Bribery Act 2010;
• The Money Laundering Regulations 2007, transposing the requirements of the E.U’s third money laundering directive;
• The FCA handbook of rules and guidance, and in particular, the senior management arrangements, systems and controls (SFFISC) sourcebook, which relates to the management and control of money laundering risk; and
• The Joint Money Laundering Steering Group (JMLSG) guidance for the UK financial sector prevents money laundering / combating terrorist financing.

Our Company’s Policies & Principles

Top Impact Limited is responsible for the following policies covering:

• Anti-Money Laundering ⁄ Counter-Terrorist Financing ⁄ Counter-Proliferation Financing;
• Training;
• Anti-Bribery & Anti-Corruption; and
• Introducers.

These policies and principles are designed to ensure that all group companies comply with the legal and regulatory requirements in the UK and with their local obligations.

Anti-Money Laundering (AML) Policy

Our company’s AML policy is designed to ensure compliance with the requirements and obligations set out in UK legislation, regulations, rules and industry guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate risks in firms that are used to facilitate financial crime. The AML policy sets out the minimum standards, which all our companies must comply with and includes:

• Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KFFIC) procedures, including enhanced due diligence for those customers presenting higher risk, such as politically exposed persons (peps) and correspondent banking relationships;
• Establishing and maintaining risk-based systems and procedures to monitor ongoing customer activity;
• Developing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
• Maintaining appropriate records for the minimum prescribed periods;
• Training and awareness for all relevant employees; and
• Providing appropriate management information and reporting to senior management of the group’s compliance with the requirements.

Training

All employees receive training on the Anti-Money Laundering and Counter-Terrorist Financing policies and principles at least once a year, with more detailed and advanced training for those whose roles involve major financial risks. Failure to comply with these policies and principles may give rise to disciplinary action, up to and including dismissal.

Anti-Bribery & Anti-Corruption Policy

We have a zero-tolerance policy toward bribery and corruption. Our company recognises that bribery and corruption adversely affect communities wherever they occur. They can threaten laws, democratic processes and fundamental human freedoms while distorting free trade and competition. Corruption is often associated with organised crime, money laundering and, on occasion, the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies.

We are committed to applying high standards of honesty and integrity consistently across our global operations and in all our business dealings. Fie is subject to the provisions of the UK bribery act 2010 and the US foreign corrupt practices act, which have an extra-territorial effect globally, as well as applicable local anti-bribery laws in relevant jurisdictions.

Introducers

In addition to the anti-bribery and anti-corruption policy, our company has an introducer clause described in the Introducer agreement. The clause covers the activities of all third parties that generate or retain business or secure a business benefit for us. These third parties are termed “introducers” by Top Impact Limited. Potential examples would include senior advisors, lead generators, and existing clients of Top Impact Limited. Our introducer policy protects Top Impact Limited against bribery and corruption risks, reputational risk, and broader operational and conduct risks associated with introducers. Our employees must apply the specific controls and procedures set out in the policy.

Top Impact Limited Governance & Conformance

Regular reviews of the effectiveness of these group policies are carried out in addition to audits periodically undertaken by Top Impact Limited’s internal audit function. This provides senior executive management oversight committees and the board audit committee with the necessary assurance regarding the operating effectiveness of the group’s controls relating to these policies.