Policy on Prevention of Money Laund

    Money laundering and terrorism financing have been named Top Luxury Group's principal tasks which are widely supported by international organisations-providers of consulting and financial services. Canada like may other countries have passed legislation for prevention of money laundering and financing terrorism. This law together with other elements of the industry regulatory framework and rules is a cornerstone of the obligations under the prevention of money laundering and funding terrorism policies for Canadian companies and determine penalties for non-compliance. These requirements are mandatory for our business cover our activities internationally. Our company may also use local policies and procedures developed under the local laws and regulations and affirmed by the governmental instructions of a particular jurisdiction in question.

    Principles and Policy

    Top Luxury Group may not be responsible for compliance and control of the following policies on:

    • Prevention of financing terrorism and money laundering;
    • Sanctions;
    • Anti-corruption.

    These principles have been developed by the company to comply with legal and regulatory requirements in Canada as well as other local jurisdictions.

    1. Policy on Prevention of Money Laundering (PML)

    The PML policy of our company is aimed at compliance with duties and obligations imposed by laws, provisions, rules, financial and trading industry guidelines of Canada. Including adequate measures of risk control and prevention in case the company may be used for committing financial crimes.The PML policy sets up minimum standards which must be observed by the company and included:

    • Appointment of an officer in charge of review of factual attempts to conduct money laundering using Top Luxury Group
    • Company officers in charge of such reviews have good experience and are responsible for the company's compliance with the related laws, rules and regulations;
    • Establishing and maintaining an approach for risk assessment and management of potential money laundering and financing terrorism;
    • Establishing and maintaining of due diligence for sufficient prevention, identification and review of the Know Your Client (KYC) software, including enhanced checks on customers who represent a higher risk;
    • Establishing and maintaining procedures and systems for constant customer monitoring;
    • Protocols for reporting suspicious activity;
    • Maintaining and keeping proper records and documents;
    • Training and communication to all involved employees;
    • Submitting relevant information and reports to the senior management of Top Luxury Group.
    2. Policy on Sanctions

    Top Luxury Group's sanction policy is aimed at effective compliance with all relevant sanction laws concerning each jurisdiction where it is applicable.

    Top Luxury Group must check sanction lists of the United Nations, European Union, HM Treasury and the US Office of Foreign Assets Control (OFAC) applicable to each jurisdiction in question where the company operates unless local legislation prohibits it. All employees go through the sanction policy training sessions at least once a year. Top Luxury Group employees whose work is closely related to high risks must be going through advanced training courses at least every three months. Non-compliance with this policy may result in disciplinary action taken including dismissal.

    3. Anti-corruption policy

    Top Luxury Group has the zero-tolerance policy for bribery and corruption. The company understands how bribery and corruption negatively impact the society wherever this takes place. Facts of corruption and bribery may jeopardise laws, democratic processes and fundamental human rights as well as have a bearing on the country as such by influencing free trade and competition. Corruption is often connected to organised crime, money laundering and, in some cases, financing of terrorism. Therefore, facts of corruption may lower the level and effectiveness of investments and subsidies, especially in financially unstable countries.

    Top Luxury Group strives to apply high standards of fairness to all business relations consistently. We abide the laws of Canada and the USA in a joint effort to fight corruption abroad. These efforts have an extra-territorial effect and cover the whole world, while we also confirm our full compliance with local laws on bribery in the relevant jurisdictions.

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