POLICY AGAINST CORRUPTION AND MONEY LAUNDERING

Download

This policy of ALGO GLOBAL LTD. (“ALGO GLOBAL”) regarding corruption and money laundering (“the Policy”) is issued with the objective of establishing institutional commitments to combat corruption and the execution of acts or operations involving resources of illicit origin (“money laundering”).

Scope of Application

This policy is applicable to all collaborators, employees, and managers of ALGO GLOBAL LTD., as well as to individuals and/or legal entities that have labor and/or commercial relationships with the company.

Objective

ALGO GLOBAL recognizes the importance of conducting its activities and business with transparency and legality, in addition to being able to provide reliable service to everyone who interacts with us.  For this reason, ALGO GLOBAL has zero tolerance for any type of corruption, bribery, money laundering and any other illegal practice. 

Acts of Corruption

At ALGO GLOBAL, we are firmly committed to refraining from engaging in acts of corruption. The following are situations that could constitute or encourage acts of corruption:

a) Conflict of interest:

It is essential for ALGO GLOBAL to operate in an honest and transparent manner; therefore, our employees must avoid any conflict of interest that may arise between their personal interests and the interests of the company.

In accordance with our internal policies, employees who find themselves in such a situation must immediately report it to their supervisor in order to prevent any potential harm to ALGO GLOBAL or the interests of third parties.

Furthermore, we request that suppliers, customers, collaborators, and any natural or legal entities engaged with ALGO GLOBAL adhere to this provision. Failure to do so may result in harm that could have legal consequences under applicable local and federal laws.

b) Gifts, courtesies, and benefits.

At ALGO GLOBAL, our employees must not accept gifts, courtesies or benefits from customers, collaborators or other natural and/or legal persons who have a business relationship with our company. This is to maintain a transparent and equitable work environment.

In case someone wishes to give a gift, courtesy, or benefit, that person must ensure that it is proportionate to all employees. In addition, ALGO GLOBAL will not give or accept money from any person for the purpose of influencing business decisions.

Furthermore, we require our employees and managers to adhere to internal regulations and avoid compromising the corporate integrity of ALGO GLOBAL. Consequently, they must not offer gifts, courtesies, or benefits to customers or others who may exert influence over business matters.

Bribes 

ALGO GLOBAL strictly prohibits making improper payments, either directly or indirectly, and receiving bribes from any authority that may influence the making of legal or business decisions that benefit ALGO GLOBAL.

Bribery is broadly defined as “giving, receiving, or soliciting any pecuniary interest or improper advantage to, from, or for a person for the purpose of influencing the acts of an officer or other person for personal gain or to secure a commercial advantage.”

To strengthen this policy, other definitions contained in current legal provisions will be considered.

Any act of bribery may be intended to:

  • Influence any act or decision.
  • Gain an undue advantage.
  • Inducing a person to incorrectly perform a relevant function or action.
  • Persuading a person to use his or her influence in the wrong way in an official act or decision.

At ALGO GLOBAL, we are committed to maintaining high ethical and legal standards, and to cracking down on any form of bribery or misconduct.

Donations and/or sponsorships

In the case of donations and sponsorships, ALGO GLOBAL agrees to adhere to the following criteria:

  • Compliance with applicable local laws. 
  • Alignment with the values and objectives of ALGO GLOBAL as a business, without pursuing personal profit or gain. 
  • The avoidance of seeking any unfair advantage or serving dishonest or improper purposes. • Appropriateness in value, ensuring that no expectation is created that the recipient should return the favor or act in a specific manner as a result of the donation or sponsorship. 
  • Conduct carried out in a transparent manner, with documentation detailing the identity of the recipient, the purpose, and the rationale behind the donation or sponsorship.

At ALGO GLOBAL, employees are constantly made aware of actions that could have legal consequences, and the importance of acting honestly and in accordance with organizational principles is emphasized.

If any employee has doubts or concerns about business actions or businesses that may be considered corruption, or that may lead to acts of corruption and/or crimes, they are requested to immediately report it to their direct supervisor or legal department.

In addition, customers, collaborators and other natural or legal persons who have business relations with ALGO GLOBAL, are requested to act in a legal manner and respect the provisions of this policy and any other policy of ALGO GLOBAL. Otherwise, the necessary measures will be taken to inform the competent authorities.

Persons who witness or suspect an act of corruption should immediately report it to the legal department via the email address lic.yumi.kondo@gmail.com 

Anti-Money Laundering

ALGO GLOBAL recognizes the importance of preventing and combating money laundering, an illegal practice that undermines the integrity of the financial system and trust in business transactions. In this regard, ALGO GLOBAL is committed to implementing robust and effective measures to prevent and detect any money laundering-related activity.

Policies and Procedures

ALGO GLOBAL has established clear policies and procedures to prevent money laundering. These policies include:

  • Due Diligence: ALGO GLOBAL conducts rigorous due diligence when establishing business relationships with customers, suppliers, and partners. The identity of the parties involved is verified and a risk analysis is performed to detect possible suspicious activity.
  • Transaction Monitoring: ALGO GLOBAL has transaction monitoring systems and tools in place to identify unusual or suspicious patterns of money laundering. Financial transactions are constantly monitored and reports are made in case of detection of suspicious activity.
  • Training and Awareness: Regular training is provided to all ALGO GLOBAL employees on the prevention of money laundering. They are provided with up-to-date information on relevant laws and regulations, as well as red flags and procedures to follow in the event of suspected money laundering.
  • Cooperation with Regulatory Authorities and Bodies: ALGO GLOBAL works closely with competent authorities and regulatory bodies in the prevention and detection of money laundering. The necessary information is provided and legal requirements are complied with in the event of investigations related to money laundering.
  • Responsibility and reporting of suspicious activity: All ALGO GLOBAL employees have the responsibility to report any suspected money laundering activity. They are encouraged to report immediately through established channels, such as the legal department or compliance officer. In addition, the confidentiality and protection of employees who make reports in good faith is guaranteed. Any type of retaliation against employees who report suspected money laundering activities is prohibited.
  • Commitment to transparency and legality: At ALGO GLOBAL, we are committed to maintaining high standards of transparency and legality in all our operations. The prevention of money laundering is a fundamental part of our corporate responsibility and we are determined to comply with applicable laws and regulations.

OBLIGATION OF KYC (KNOW YOUR CUSTOMER)

KYC compliance aims to establish guidelines for the prevention of money laundering and terrorist financing, ensuring adherence to applicable national and international regulations.

The scope of this obligation extends to all employees, officers, and third parties associated with ALGO GLOBAL, including customers, suppliers, and business partners.

ALGO GLOBAL is committed to adhering to the regulations set forth by the relevant authorities, such as the FATF, OFAC, the Saint Lucia Anti-Money Laundering Law, and other jurisdictions in which it operates.

PRINCIPLES AND GUIDELINES

  1. Know Your Customer (KYC)
    • A process for identifying and verifying customers will be implemented, gathering relevant and up-to-date information.
    • A risk assessment will be conducted to determine the level of due diligence to be applied.
  2. Transaction Monitoring
    • Procedures shall be established for the identification of unusual or suspicious transactions.
    • Transactions will be monitored based on predefined risk thresholds.
  3. Suspicious Transaction Report (STR)
    • Any suspicious activity must be reported to the compliance officer and, where appropriate, to the relevant regulatory authorities.
    • Confidentiality in the submission of reports will be maintained to preserve the integrity of the process.

By implementing robust policies and procedures, training our employees, and cooperating with competent authorities, we actively work to prevent and detect money laundering, ensuring the integrity of our operations and contributing to the overall integrity of the financial system.

As an additional measure to prevent money laundering, ALGO GLOBAL requires any natural or legal person who has a business relationship with the company to submit a series of documents. These requirements ensure transparency and compliance with applicable tax and legal regulations. The following are the necessary documents:

For individuals:

  1. Official ID: A legible copy of a valid official ID, such as an ID card or passport, is required.
  2. Proof of address: A recent document verifying the residence address, such as a utility bill or bank statement, is requested.
  3. Taxpayer Registry: The document issued by the corresponding tax authority must be provided.
  4. Proof of tax status: A document certifying the tax situation of the individual, issued by the competent tax authority, is required. and. Invoice with tax requirements: In case of making payments, an invoice that complies with the tax requirements established by the applicable legislation is requested.
  5. Confirmation of bank information: In case of receiving payments or transfers, confirmation of bank account information may be requested, and additional documents may be required if necessary.

For legal entities:

  1. Official identification of the Legal Representative: A legible copy of the official identification of the legal representative of the company must be presented.
  2. Articles of incorporation of the company: A copy of the articles of incorporation that establish the legal existence of the company is requested.
  3. Power of Attorney of the Current Legal Representative: A copy of the power of attorney designating the current legal representative of the company is required.
  4. Proof of address: A recent document verifying the business address, such as a utility bill or bank statement, is requested. and. Taxpayer Registration: The document issued by the corresponding tax authority must be provided.
  5. Proof of tax status: A document certifying the individual’s tax status, issued by the competent tax authority, is required.
  6. Invoice with tax requirements: In case of making payments, an invoice that complies with the tax requirements established by the applicable legislation is requested.
  7. Confirmation of bank information: In case of receiving payments or transfers, confirmation of bank account information may be requested, and additional documents may be required if necessary.

Once the legal area of ALGO GLOBAL reviews the documentation submitted, the bank information and the corresponding invoices will be verified in the accounting area.

Importantly, ALGO GLOBAL does not accept cash payments and is governed by St. Lucia’s official tax requirements, as well as the provisions set forth in the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.

To promote an environment of transparency and compliance, all persons who witness or have suspicions about an act of money laundering are encouraged

Persons who witness or suspect an act of money laundering should immediately report it to the legal department via the email address lic.yumi.kondo@gmail.com