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 the Centralus Group and, indeed, the international financial services community. The United Kingdom, in common with many other countries, has passed legislation designed to prevent money laundering and to combat terrorism.

Legal and regulatory framework

The principal requirements, obligations and penalties, on which Centralus financial crime systems and controls are based, are contained in:

• The proceeds of Crime Act 2002 (POCA), as amended by the:

i. Serious Organized Crime and Police Act 2005 (SOCPA); and the

ii. Proceeds of Crime Act (amendment) Regulations 2007;

·.The Terrorism Act 2000, as amended by the:

i. The Anti Terrorism, Crime & Security Act 2001; and the

ii. 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 on the prevention of money laundering I combating terrorist financing.

Centralus policies & principles

Centralus is responsible for the following policies covering:

a. Anti-Money Laundering I Counter-Terrorist Financing I Counter-Proliferation Financing;

b. Training;

c. Anti-Bribery & Anti-Corruption ; and

d. Introducers.

These policies and principles are designed to ensure that all group companies comply with the legal and reg ulatory requirements applicable in the UK as well as with their local obligations.

Anti–Money Laundering (A.M.L) policy

Cer1tralus A.M.L policy is designed to ensure that comply with the requirements and obligations set out in UK legislation, regulations, rules and industry guidance for the fin ancial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate

fin ancial crime. The A.M.L policy sets out the minimum standards which must be complied with by all Centralus Group companies and includes:

• Establi shing 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;

• Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

• The maintenance of appropriate records for the minimum prescribed periods;

• Training and awareness for all relevant employees ; and

• The provision of appropriate management information and reporting to senior management of the group’s compliance with the requirements.

Training

All employees receive train ing 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

Centralus has a zero tolerance policy towards bribery and corruption. Centralus recognizes that bribery and corruption have an adverse effect on communities wherever they occur. If endemic, they can threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Corruption is often associated with organized crime, money laundering and on occasions the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies.

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

Introducers

In addition to the anti-bribery and anti-corruption policy, Centralus 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 Centralu s. These third parties are termed “introducers” by Centralus. Potential examples would include senior advisors, lead generators and existing clients of Centralus Group. Centralus introducer policy is designed to protect Centralus against the bribery and corruption risks, reputational risk, and wider operational and conduct risks associated with introducers. Centralus employees must apply the specific controls and procedures set out in the policy.

Centralus Group governance & conformance

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

This statement is made pursuant to our company’s environmental initiatives and constitutes our group’s Environmental Policy Statement. This policy statement will be reviewed annually and published.

CENTRALUS is a fully committed member of its industry in minimising the impact of its activities on the environment.

The key points of its applied strategy in order to achieve this are:

1. Minimise waste by evaluating operations and ensuring they are as efficient as possible.
2. Minimise toxic emissions through the use of its materials and the source of its power requirements.
3. Actively promote and encourage recycling both internally, to its employees & officers, and amongst its customers and suppliers.
4. Source and promote a product range to minimise the environmental impact of both production and distribution.
5. Adopt a training programme for its personnel to raise awareness of environmental issues and enlist their support in improving the Company’s performance.
6. Meet and comply to the environmental legislation that relates to the Company.
7. Implement an accredited programme to offset the greenhouse gas emissions generated by our activities.

Where opportunities shall be identified, environmental initiatives may be extended to benefit the wider community; capturing the significance of social action and directly supporting the Company’s ethos and values.

This policy applies to all of the Company’s operations in the UK. This means that all employees, administrators, consultants, partners and businesses carried on by the Company and/or their subsidiaries, whether they are incorporated within the UK or not, must comply with it, with no exemptions.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery statement. This policy statement will be reviewed annually and published.

CENTRALUS has a zero tolerance approach to any form of modern slavery and human trafficking. We are committed to acting ethically, with integrity and transparency in all business dealings and to implementing effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chain.

We are a very unique organisation that specialises in assisting companies in streamlining staff employment and payroll processing by incentivising staff through benefits and loyalty programmes whilst providing staff longevity and tax breaks.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All directors have been briefed on the subject. As part of our initiative to identify and mitigate risks we:

• Continually audit & review our practices;
• Encourage the reporting of concerns and the protection of whistle blowers;
• Not knowingly, as a Company, support or deal with any business involved in slavery or human trafficking; and
• Have zero tolerance to slavery and human trafficking.

We expect all those in our supply chain to fully comply with our values. We use the following key performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Completion of in-house audits & staff training levels;
• Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations; and
• Investigations undertaken into reports of modern slavery and remedial actions taken in response.

The company directors and senior management shall have the responsibility to implement this policy statement and its objectives and shall provide adequate resources and investments to ensure that slavery and human trafficking does not take place within the organisation or within its supply chains.

Mission Statement

In Centralus we believe that our success is established, based on the professional and ethical behaviour of our people. Consequently, our reputation, both as individuals and as a firm, depends on it. As HR & Payroll professionals, we are responsible for adding value to the organisations we serve and contribute to their ethical success. We take on the responsibility for our individual decisions and actions. We are also advocates for the profession by engaging in activities that enhance its credibility and value.

Our clients place their trust in us and in the work that we do. So, for us, it is paramount that we follow the highest ethical standards by providing services of the highest quality; thus, creating a business environment that reflects our fundamental beliefs including continuous development and innovation, responsibility, integrity and confidentiality.

Purpose of the Code

Centralus is committed to maintaining the highest standards of ethical and professional conduct and competency in HR and recruitment. All members are encouraged to be advocates of promoting best practice within the profession and must comply with the standards set out in this Code of Conduct.

Our Code of Conduct highlights those key characteristics, which create an environment reflecting the highest professional and ethical standards.

Commitments

• To support the organisations we work with in achieving their objectives and goals.

• To inform and educate current and future professionals, the organisations we serve, and the general public about the 7 principles and practices that help the profession (selflessness, integrity, objectivity, accountability, openness, honesty & leadership).

• To build respect, credibility and strategic importance within our organisation, the business community and the communities in which we work.
• To positively influence workplace and recruitment practices.
• To encourage professional decision-making and responsibility.
• To encourage social responsibility.
• To comply with the law.

Actions

1. Adhere to the highest standards of ethical and professional behaviour.
2. Measure the effectiveness of HR in contributing to or achieving organisational goals.
3. Our work is consistent with the values of the profession.
4. Strive to achieve the highest levels of service, performance and social responsibility.
5. Advocate for the appropriate use and appreciation of human beings as employees.
6. Advocate openly and within the established forums for debate in order to influence decision-making and results.

Professional Development

As professionals, we must seek to continually develop our professional knowledge and competence.

Commitments

• To expand our knowledge in human resource management to further our understanding of how our organisation functions.
• To advance our understanding of how organisations work (“the business of the business”).
• To learn from appraisals and performance reviews and undertake further education and training, if necessary.

Actions

1. Pursue formal academic opportunities.
2. Commit to continuous learning, skills development and application of new knowledge related to both human resource management and the organisations we serve.
3. Contribute towards acquiring knowledge, the evolution of the profession and the development of individuals through learning, research and the dissemination of knowledge.
4. Pursue certification, where available, or comparable measures of competencies and knowledge.

Ethical Leadership

In Centralus, we believe in the need to exhibit individual leadership as a role model for maintaining the highest standards of ethical conduct.

Commitments

• To set the standards and be a role model for others.
• To earn individual respect and increase our credibility with those we serve.

Actions

1. Be ethical; act ethically in every professional interaction.
2. Question pending individual and group actions, when necessary, to ensure that decisions made are ethical and are implemented in an ethical manner.
3. Seek expert guidance, if ever in doubt, about the ethical propriety of a situation.
4. Through teaching and mentoring, champion the development of others as ethical leaders in the profession and in organisations.

Fairness and Justice

As human resource professionals, we are ethically responsible for promoting and fostering fairness and justice for all employees and their organisations.

Commitments

• To respect diversity and not discriminate against people.
• To create and sustain an environment that encourages all individuals, and the organisation itself, to reach their fullest potential in a positive and productive manner.

Actions

1. Treat people with dignity, respect and compassion to foster a trusting work environment free of harassment, intimidation and unlawful discrimination.
2. Ensure that everyone has the opportunity to develop skills and new competencies.
3. Provide an environment of inclusiveness and ensure commitment to diversity in the organisations we serve.
4. Develop, administer and advocate policies and procedures that foster fair, consistent and equitable treatment for all.
5. Regardless of personal interests, support decisions made by our organisation that are both ethical and legal.
6. Act in a responsible manner and practice sound management in the country         (-ies) in which the organisations we serve operate.

Conflicts of Interest

As HR professionals, we must maintain a high level of trust with our stakeholders. We must protect the interests of our stakeholders as well as our professional integrity and should not engage in activities that create actual, apparent or potential conflicts of interest.

Commitments

• To avoid activities that are in conflict, or may appear to be in conflict, with any of the provisions of this Code of Ethical and Professional Standards in Human Resource Management or with one’s responsibilities and duties as a member of the human resource profession and/or as an employee of any organisation.

 

Actions

1. Adhere to and encourage the use of published policies on conflicts of interest within your organisation.
2. Refrain from using your position for personal, material or financial gain or the appearance of such.
3. Refrain from giving or seeking preferential treatment in human processes.
4. Prioritise obligations to identify conflicts of interest or the appearance thereof; when conflicts arise, disclose them to relevant stakeholders.

 

Use of Information

We take into account and protect the rights of individuals, especially in the acquisition and distribution of information while safeguarding truthful communications and enabling informed decision-making.

Commitments

• To build trust among all the parts of the organisation by maximising the open exchange of information and, in parallel, eliminating anxieties about inappropriate and/or inaccurate attainment and sharing of information.
• Respect the confidentiality of both clients and candidates and comply with the relevant laws.

Actions

1. Acquire and circulate information through ethical and responsible means.
2. Ensure only appropriate information is used in decisions affecting the employment relationship.
3. Investigate the accuracy and source of information before allowing it to be used in employment-related decisions.
4. Maintain up-to-date and accurate HR information.
5. Safeguard restricted or confidential information.
6. Take appropriate steps to ensure the accuracy and completeness of all communicated information about HR policies and practices.​
7. Take appropriate steps to ensure the accuracy and completeness of all communicated information used in HR-related training.